GM Financial Trust 2024-4 Navigates Legal Risks, Maintains Servicing Compliance

TL;DR

**This auto loan securitization is a pure play on underlying asset performance and servicer integrity, but watch out for the sponsor's mounting legal woes.**

AI Summary

GM Financial Consumer Automobile Receivables Trust 2024-4, a securitization entity, filed its 10-K for the fiscal year ended December 31, 2025. 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 within its automobile receivables portfolio. There is no external credit enhancement or derivative instruments altering cash flow characteristics, suggesting a reliance on the underlying asset performance. 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, impacting its ability to perform servicer duties. The Bank of New York Mellon, as trustee, is also a defendant in RMBS-related lawsuits, alleging expansive duties. Despite these legal exposures, both AmeriCredit Financial Services, Inc. and The Bank of New York Mellon asserted compliance with applicable servicing criteria for the year ended December 31, 2025, with independent registered public accounting firms Ernst & Young LLP and KPMG LLP providing reports.

Why It Matters

This 10-K provides a crucial look into the operational health and risk landscape of a significant securitization vehicle for GM Financial's auto loans. For investors in asset-backed securities, the absence of external credit enhancement means the performance of the underlying auto loan pool and the servicer's capabilities are paramount. The ongoing legal challenges faced by AmeriCredit Financial Services, Inc. and The Bank of New York Mellon introduce potential operational and financial risks that could indirectly affect the trust's stability and the timely distribution of payments to noteholders, distinguishing it from competitors with more robust credit support structures.

Risk Assessment

Risk Level: medium — The risk level is medium due to the significant legal and regulatory proceedings faced by the sponsor, AmeriCredit Financial Services, Inc., as detailed in Item 1117. These proceedings, including potential class actions, could lead to 'substantial damages, settlements, fines, penalties, diminished income or reputational harm,' directly affecting the servicer's ability to perform its duties for the trust. Additionally, The Bank of New York Mellon, as trustee, is also involved in RMBS-related lawsuits, adding another layer of potential operational disruption.

Analyst Insight

Investors should closely monitor the legal proceedings involving AmeriCredit Financial Services, Inc. and The Bank of New York Mellon, as adverse outcomes could impact the trust's operational stability and the servicer's capacity. Given the lack of external credit enhancement, a deeper dive into the performance metrics of the underlying auto loan pool is warranted to assess the intrinsic quality of the assets.

Financial Highlights

total Assets

Not Disclosed

total Debt

Not Disclosed

Key Numbers

• 10% — Maximum percentage of pool assets represented by a single obligor (No single obligor exceeds this threshold, indicating diversification.)
• 2025 — Fiscal year end (The period covered by the 10-K filing.)
• 2024-4 — Trust series designation (Identifies the specific securitization trust.)
• 333-275606-03 — Commission file number of the issuing entity (SEC identifier for the trust.)
• 0002036780 — CIK number of issuing entity (Central Index Key for the trust.)

Key Players & Entities

• GM Financial Consumer Automobile Receivables Trust 2024-4 (company) — Issuing entity
• AFS SENSUB CORP. (company) — Depositor
• AMERICREDIT FINANCIAL SERVICES, INC. (company) — Sponsor and Servicer (dba GM Financial)
• 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) — No single obligor represents more than 10% of pool assets, no external credit enhancement, no derivative instruments.

FAQ

Risk Factors

• Sponsor Legal and Regulatory Proceedings [high — legal]: AmeriCredit Financial Services, Inc. (dba GM Financial) is involved in various legal and regulatory proceedings, including potential class actions. These could lead to substantial damages and reputational harm, potentially impacting its ability to fulfill its servicer duties for the trust.
• Trustee Legal Exposure [medium — legal]: The Bank of New York Mellon, acting as trustee, is named as a defendant in RMBS-related lawsuits. Allegations in these lawsuits may impose expansive duties on the trustee, potentially affecting its operational capacity and fiduciary responsibilities.
• Reliance on Servicer Performance [high — operational]: The trust's performance is heavily reliant on the servicing capabilities of AmeriCredit Financial Services, Inc. Any adverse developments impacting the sponsor's financial health or operational integrity could directly affect the management and performance of the underlying automobile receivables.
• Absence of External Credit Enhancement [high — financial]: The securitization structure lacks external credit enhancement or derivative instruments. This means that the performance of the notes and certificates is solely dependent on the quality and performance of the underlying automobile receivables pool, increasing exposure to credit losses.

Industry Context

The automobile finance industry is characterized by intense competition among lenders, with a significant portion of the market served by captive finance companies like GM Financial. Trends include increasing adoption of digital loan origination and servicing platforms, evolving consumer preferences for vehicle ownership models, and ongoing scrutiny of lending practices by regulators.

Regulatory Implications

The trust and its sponsor operate within a heavily regulated financial environment. Potential legal actions against the sponsor and trustee, as well as general regulatory oversight of securitization and consumer lending, pose ongoing compliance risks and could necessitate adjustments to business practices.

What Investors Should Do

1. Monitor Sponsor and Trustee Legal Proceedings
2. Assess Underlying Asset Performance
3. Review Servicing Compliance Reports

Key Dates

• 2025-12-31: Fiscal Year End — Marks the end of the reporting period for the 10-K filing, providing the latest financial and operational data.
• 2024-10-16: Indenture, Trust Agreement, Sale and Servicing Agreement, Purchase Agreement, Asset Representations Review Agreement executed — These agreements establish the legal framework, roles, and responsibilities for the GM Financial Consumer Automobile Receivables Trust 2024-4, including the securitization and servicing of the automobile receivables.
• 2024-10-17: Form 8-K filed detailing key agreements — Provides immediate public disclosure of the material agreements governing the trust's operations and the securitization transaction.

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 2024-4 is a securitization entity, highlighting its role in transforming automobile loans into tradable securities.)

Obligor

A party that owes an obligation, typically a debt, to another party. (In this context, obligors are the individual borrowers of the automobile loans within the trust's pool. The diversification of obligors is a key risk indicator.)

External Credit Enhancement

Third-party guarantees or support mechanisms designed to reduce the credit risk of a securitized pool of assets. (The absence of external credit enhancement means the trust's securities are fully exposed to the credit performance of the underlying automobile loans.)

Derivative Instruments

Financial contracts whose value is derived from an underlying asset, group of assets, or benchmark. (The lack of derivative instruments indicates that the cash flow characteristics of the trust's assets are not being modified or hedged through complex financial products.)

Servicer

The entity responsible for managing the underlying assets, including collecting payments, handling delinquencies, and performing other administrative tasks. (AmeriCredit Financial Services, Inc. acts as the servicer, and its performance is critical to the trust's operations and the timely payment of securities.)

Trustee

A financial institution appointed to hold and manage assets on behalf of the beneficiaries of a trust, ensuring compliance with the trust agreement. (The Bank of New York Mellon serves as trustee, overseeing the trust's assets and operations, and is subject to potential legal challenges.)

Regulation AB

SEC rules governing the disclosure requirements for asset-backed securities, including information about the underlying assets, servicer, and credit enhancement. (The filing references specific items within Regulation AB (e.g., 1112(b), 1114(b)(2), 1115(b)), indicating compliance with these disclosure standards for securitized assets.)

Year-Over-Year Comparison

As this is the initial 10-K filing for GM Financial Consumer Automobile Receivables Trust 2024-4, a direct comparison of key metrics to a previous filing is not applicable. However, the absence of external credit enhancement and the reliance on the sponsor's servicing capabilities are critical structural points that investors must consider from inception.

Filing Documents

• a10-k_gmcar2024x4x2025.htm (10-K) — 73KB
• exhibit311_gmcar2024-4x2025.htm (EX-31.1) — 8KB
• exhibit331_gmcar2024-4x2025.htm (EX-33.1) — 122KB
• exhibit332_gmcar2024-4x2025.htm (EX-33.2) — 87KB
• exhibit341_gmcar2024-4x2025.htm (EX-34.1) — 9KB
• exhibit342_gmcar2024-4x2025.htm (EX-34.2) — 12KB
• exhibit351_gmcar2024-4x2025.htm (EX-35.1) — 6KB
• capture.jpg (GRAPHIC) — 13KB
• capture1.jpg (GRAPHIC) — 13KB
• image.jpg (GRAPHIC) — 3KB
• imagea.jpg (GRAPHIC) — 5KB
• 0002036780-26-000013.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 16, 2024, between GM Financial Consumer Automobile Receivables Trust 2024-4 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 2024-4 (File No. 333-275606-03) with the SEC on October 17, 2024). Exhibit 4.2 Amended and Restated Trust Agreement, dated as of October 16, 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 2024-4 (File No. 333-275606-03) with the SEC on October 17, 2024). Exhibit 4.3 Sale and Servicing Agreement, dated as of October 16, 2024, among GM Financial Consumer Automobile Receivables Trust 2024-4, 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 2024-4 (File No. 333-275606-03) with the SEC on October 17, 2024). Exhibit 10.1 Purchase Agreement, dated as of October 16, 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.

View Full Filing

View this 10-K filing on SEC EDGAR