GM Financial Trust 2024-2 Navigates Legal Risks, Confirms Servicing Compliance

TL;DR

This auto loan securitization trust is a low-risk, pass-through entity, but keep an eye on the sponsor's legal woes, as they could indirectly impact performance.

AI Summary

GM Financial Consumer Automobile Receivables Trust 2024-2, a securitization entity, filed its 10-K for the fiscal year ended December 31, 2025, indicating no revenue or net income figures as it is a pass-through trust. The trust's primary business involves holding consumer automobile receivables, originated by AmeriCredit Financial Services, Inc. (dba GM Financial), and issuing asset-backed securities. Key business changes include the establishment of the trust on April 10, 2024, with an Indenture between the Trust and The Bank of New York Mellon, as Trustee. Risks highlighted include the sponsor, AmeriCredit Financial Services, Inc., being subject to 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, also faces legal actions related to its role in residential mortgage-backed securitization transactions. Strategic outlook focuses on continued compliance with servicing criteria, as evidenced by Management's Assertion and Independent Registered Public Accounting Firm reports from Ernst & Young LLP and KPMG LLP, confirming AmeriCredit Financial Services, Inc.'s material compliance with applicable servicing criteria for the year ended December 31, 2025.

Why It Matters

This 10-K provides crucial transparency for investors in the GM Financial Consumer Automobile Receivables Trust 2024-2, detailing the operational framework and compliance status of the underlying auto loan securitization. The disclosure of ongoing legal proceedings against the sponsor, AmeriCredit Financial Services, Inc., and the trustee, The Bank of New York Mellon, highlights potential risks to the trust's performance and the stability of cash flows to noteholders. For employees of GM Financial, it underscores the importance of robust compliance. In the broader market, it reflects the ongoing scrutiny and legal challenges within the asset-backed securities sector, particularly concerning servicer and trustee responsibilities, setting a precedent for competitive auto loan securitization trusts.

Risk Assessment

Risk Level: medium — The risk level is medium due to the disclosed legal proceedings against 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,' which could 'materially and adversely affect the interests of the noteholders or the servicer's ability to perform its duties.' While there is no single obligor representing more than 10% of pool assets and no external credit enhancement, these legal risks introduce uncertainty.

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 impact the servicer's capacity and the trust's overall stability. While the trust itself is a pass-through entity with no direct financial operations, the health of its key counterparties is paramount for the performance of the asset-backed securities.

Financial Highlights

debt To Equity

N/A

revenue

$0

operating Margin

N/A

total Assets

$0

total Debt

$0

net Income

$0

eps

$0

gross Margin

N/A

cash Position

$0

revenue Growth

N/A

Key Numbers

• 2025-12-31 — Fiscal Year End Date (The period covered by this 10-K filing.)
• 2024-04-10 — Indenture Date (Date the Indenture was established between the Trust and The Bank of New York Mellon.)
• 10% — Significant Obligor Threshold (No single obligor represents more than 10% of the pool assets, indicating diversification.)

Key Players & Entities

• GM Financial Consumer Automobile Receivables Trust 2024-2 (company) — Issuing entity of asset-backed securities
• AFS SENSUB CORP. (company) — Depositor for the trust
• AMERICREDIT FINANCIAL SERVICES, INC. (company) — Sponsor and Servicer for the trust, also known as GM Financial
• The Bank of New York Mellon (company) — Trustee and Trust Collateral Agent for the trust
• Wilmington Trust Company (company) — Owner Trustee for the trust
• Clayton Fixed Income Services LLC (company) — Asset Representation Reviewer for the trust
• 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.
• SEC (regulator) — Securities and Exchange Commission

FAQ

Risk Factors

• Sponsor Legal and Regulatory Proceedings [high — legal]: AmeriCredit Financial Services, Inc. (dba GM Financial), the sponsor, is subject to various legal and regulatory proceedings. These include potential class actions that could result in substantial damages and significant reputational harm, impacting the trust's operations.
• Trustee Legal Actions [medium — legal]: The Bank of New York Mellon, acting as Trustee, faces legal actions related to its past involvement in residential mortgage-backed securitization transactions. While not directly tied to this trust, it indicates potential operational risks associated with the trustee.
• Servicing Compliance [medium — operational]: The trust's operations are dependent on AmeriCredit Financial Services, Inc.'s compliance with applicable servicing criteria. While reports from Ernst & Young LLP and KPMG LLP confirm material compliance for the year ended December 31, 2025, any future non-compliance could impact the trust.

Industry Context

The auto finance industry is characterized by intense competition among lenders, including captive finance companies like GM Financial, banks, and independent finance companies. Key trends include evolving consumer preferences for vehicle types, increasing adoption of electric vehicles, and fluctuating interest rates impacting loan demand and affordability. Regulatory scrutiny on lending practices and data privacy remains a significant factor.

Regulatory Implications

The trust's operations are subject to Regulation AB, which governs the disclosure requirements for asset-backed securities. Compliance with servicing criteria is paramount, as evidenced by the independent audits. Legal and regulatory proceedings against the sponsor and trustee represent potential risks that could indirectly affect the trust's stability and investor confidence.

What Investors Should Do

1. Monitor legal and regulatory proceedings against AmeriCredit Financial Services, Inc.
2. Review the annual compliance reports for servicing criteria.
3. Assess the financial stability of The Bank of New York Mellon as Trustee.

Key Dates

• 2024-04-10: Indenture Establishment — Marks the formal establishment of the securitization trust and the agreement between GM Financial Consumer Automobile Receivables Trust 2024-2 and The Bank of New York Mellon as Trustee.
• 2024-04-10: Sale and Servicing Agreement — Defines the roles of the Issuer, Servicer (AmeriCredit Financial Services, Inc.), Seller, and Trust Collateral Agent, crucial for the operational flow of the securitization.
• 2024-04-10: Purchase Agreement — Details the transaction between AmeriCredit Financial Services, Inc. as Seller and AFS SenSub Corp. as Purchaser, outlining the transfer of assets into the trust.
• 2024-04-10: Asset Representations Review Agreement — Establishes the process for reviewing the underlying assets, involving the Trust, Servicer, and an independent Asset Representation Reviewer.
• 2025-12-31: Fiscal Year End — The reporting period for which the 10-K provides financial and operational information, confirming compliance with servicing criteria.

Glossary

Pass-through trust

A type of trust that passes income and principal payments directly to the beneficiaries or security holders without significant deductions or management. (Explains why GM Financial Consumer Automobile Receivables Trust 2024-2 has no revenue or net income figures.)

Consumer automobile receivables

Loans made to consumers for the purchase of vehicles, which are then pooled and securitized. (Represents the core assets held by the trust and underlying the issued securities.)

Indenture

A legal document that outlines the terms and conditions of a bond or debt issuance, including the rights and obligations of the issuer and the trustee. (Governs the relationship between the trust and its trustee, The Bank of New York Mellon, for the asset-backed securities.)

Servicing criteria

A set of standards and requirements that a servicer must meet when managing the underlying assets of a securitization, such as collecting payments and handling delinquencies. (Key to investor confidence, as compliance is regularly audited and reported.)

Asset Representations Reviewer

An independent third party responsible for reviewing the characteristics of the underlying assets in a securitization pool to ensure they meet the representations and warranties made by the seller. (Plays a role in the governance and risk management of the securitization by verifying asset quality.)

Year-Over-Year Comparison

As this is the first 10-K filing for GM Financial Consumer Automobile Receivables Trust 2024-2, established on April 10, 2024, there are no prior year figures to compare against. The filing primarily serves to establish the trust's operational framework and initial compliance status for the period ending December 31, 2025. Key risks identified are inherent to the structure and parties involved from inception.

Filing Documents

• a10-k_gmcar2024x2x2025.htm (10-K) — 73KB
• exhibit311_gmcar2024-2x2025.htm (EX-31.1) — 8KB
• exhibit331_gmcar2024-2x2025.htm (EX-33.1) — 122KB
• exhibit332_gmcar2024-2x2025.htm (EX-33.2) — 87KB
• exhibit341_gmcar2024-2x2025.htm (EX-34.1) — 9KB
• exhibit342_gmcar2024-2x2025.htm (EX-34.2) — 12KB
• exhibit351_gmcar2024-2x2025.htm (EX-35.1) — 6KB
• capture.jpg (GRAPHIC) — 13KB
• capture1.jpg (GRAPHIC) — 13KB
• image.jpg (GRAPHIC) — 3KB
• imagea.jpg (GRAPHIC) — 5KB
• 0002013919-26-000012.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 April 10, 2024, between GM Financial Consumer Automobile Receivables Trust 2024-2 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 2024-2 (File No. 333-275606-01) with the SEC on April 11, 2024). Exhibit 4.2 Amended and Restated Trust Agreement, dated as of April 10, 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 2024-2 (File No. 333-275606-01) with the SEC on April 11, 2024). Exhibit 4.3 Sale and Servicing Agreement, dated as of April 10, 2024, among GM Financial Consumer Automobile Receivables Trust 2024-2, 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 2024-2 (File No. 333-275606-01) with the SEC on April 11, 2024). Exhibit 10.1 Purchase Agreement, dated as of April 10, 2024, between Am

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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