Carvana Trust Discloses Filing Lapses, Bolsters Compliance

TL;DR

**Carvana's filing snafu for another trust is a red flag for operational risk, even if this trust is unaffected; watch for consistent execution of their new compliance protocols.**

AI Summary

Carvana Auto Receivables Trust 2021-N1, a securitization entity, filed its 10-K for the fiscal year ended December 31, 2025, reporting no single obligor represents 10% or more of its pool assets and no external credit enhancement or derivative instruments are in place. The filing highlighted a material instance of noncompliance by the Sponsor, Carvana, LLC, regarding the untimely filing of Forms 10-D and ABS-EE for the Carvana Auto Receivables Trust 2024-P4 transaction on February 11, 2025, which were due within fifteen calendar days of the January 2025 distribution date but filed on February 12, 2025. This specific noncompliance did not affect the asset-backed securities covered in this 10-K, nor did it impact investor distributions or servicer certificates for the 2024-P4 transaction. In response, Carvana, LLC has implemented new policies, including additional attorney oversight, compliance checks, a comprehensive filing log with EDGAR hyperlinks, and enhanced reviews of servicer certificates, to ensure timely and accurate SEC filings for all future transactions within five business days of monthly distribution dates.

Why It Matters

This 10-K reveals operational compliance issues at Carvana, LLC, the sponsor, specifically regarding SEC filing timeliness for a different trust, Carvana Auto Receivables Trust 2024-P4. While the direct financial impact on Carvana Auto Receivables Trust 2021-N1 investors is minimal, as distributions were timely and correct, it signals potential weaknesses in Carvana's internal controls and regulatory adherence. For investors in Carvana-sponsored securitizations, this raises questions about the reliability of reporting processes, potentially increasing perceived risk and impacting the market's confidence in future Carvana-backed offerings compared to competitors with flawless compliance records. Employees involved in these processes face increased scrutiny and new procedural burdens.

Risk Assessment

Risk Level: medium — The risk level is medium due to the disclosed material instance of noncompliance by the Sponsor, Carvana, LLC, regarding the untimely filing of Forms 10-D and ABS-EE for the Carvana Auto Receivables Trust 2024-P4 transaction on February 11, 2025. Although this specific issue did not impact the Carvana Auto Receivables Trust 2021-N1 or investor distributions, it indicates a systemic weakness in regulatory compliance processes that could recur or affect other Carvana-sponsored trusts.

Analyst Insight

Investors should monitor Carvana's subsequent 10-D and 10-K filings across all its securitization trusts to verify the effective implementation of the new compliance policies and procedures. A sustained period of timely and accurate filings would rebuild confidence, while further lapses could signal deeper systemic issues warranting re-evaluation of investment in Carvana-backed assets.

Financial Highlights

debt To Equity

0.0

revenue

$0

operating Margin

0%

total Assets

$0

total Debt

$0

net Income

$0

eps

$0

gross Margin

0%

cash Position

$0

revenue Growth

N/A

Key Numbers

• December 31, 2025 — Fiscal Year End (Reporting period for this 10-K)
• February 11, 2025 — Discovery Date of Noncompliance (Date Sponsor discovered unfiled reports for 2024-P4 transaction)
• February 12, 2025 — Filing Date of Delayed Reports (Date Forms 10-D and ABS-EE for 2024-P4 were filed)
• 15 calendar days — Required Filing Timeline (Period within which Forms 10-D and ABS-EE should have been filed after January 2025 distribution date)
• 5 business days — New Compliance Timeline (Period within which procedural enhancements will be completed after monthly distribution date)

Key Players & Entities

• Carvana Auto Receivables Trust 2021-N1 (company) — issuing entity
• Carvana, LLC (company) — sponsor and administrator
• Carvana Receivables Depositor LLC (company) — depositor
• Bridgecrest Credit Company, LLC (company) — servicer
• Computershare Trust Company, National Association (company) — collateral custodian and indenture trustee
• Mike McKeever (person) — President of Carvana Receivables Depositor LLC
• SEC (regulator) — regulatory body for filings
• Carvana Auto Receivables Trust 2024-P4 (company) — transaction affected by filing noncompliance
• Grant Thornton LLP (company) — attestation report provider for Servicer and Sponsor
• PWC (company) — attestation report provider for Indenture Trustee and Collateral Custodian

FAQ

Risk Factors

• Untimely SEC Filings for Other Transactions [medium — regulatory]: Carvana, LLC, the Sponsor, experienced a material instance of noncompliance due to untimely filing of Forms 10-D and ABS-EE for the Carvana Auto Receivables Trust 2024-P4 transaction. The reports were due within fifteen calendar days of the January 2025 distribution date but were filed on February 12, 2025, one day late. This specific noncompliance did not impact the 2021-N1 transaction.
• Reliance on Sponsor for Filings [medium — operational]: The Carvana Auto Receivables Trust 2021-N1 is dependent on its Sponsor, Carvana, LLC, for timely and accurate SEC filings. The recent delay in filings for the 2024-P4 transaction highlights a potential operational risk if similar issues were to occur with the 2021-N1 transaction's reporting requirements.
• No External Credit Enhancement [high — financial]: The securitization structure for Carvana Auto Receivables Trust 2021-N1 does not include any external credit enhancement or derivative instruments. This means that investors bear the full credit risk of the underlying pool of auto receivables without any third-party support.
• Concentration of Obligors [low — financial]: The filing explicitly states that no single obligor represents 10% or more of the pool assets. This indicates a diversified pool of underlying auto loans, mitigating the risk associated with any single borrower's default.

Industry Context

The auto finance industry, particularly within the securitization market, is highly regulated and relies on timely and accurate disclosures. The competitive landscape involves numerous originators and securitizers, all subject to evolving SEC requirements like Regulation AB. Trends include increasing focus on data transparency and robust compliance frameworks to maintain investor confidence.

Regulatory Implications

The material instance of noncompliance regarding untimely filings for the 2024-P4 transaction underscores the importance of rigorous internal controls and adherence to SEC deadlines. While this specific issue did not affect the 2021-N1 trust, it signals a potential operational risk for the sponsor and necessitates enhanced oversight to prevent future breaches.

What Investors Should Do

1. Monitor Carvana, LLC's compliance with its enhanced filing policies to ensure timely and accurate reporting for all future transactions, including 2021-N1.
2. Assess the operational risk associated with the sponsor's past filing delays and evaluate the effectiveness of the implemented corrective actions.
3. Understand that investors in the 2021-N1 transaction bear the full credit risk of the underlying auto receivables due to the absence of external credit enhancement.

Key Dates

• 2021-03-25: Closing Date of Carvana Auto Receivables Trust 2021-N1 — Marks the establishment of the trust and the initial securitization of auto receivables.
• 2025-01-XX: January 2025 Distribution Date for 2024-P4 Transaction — The distribution date triggering the filing deadline for Forms 10-D and ABS-EE for the 2024-P4 transaction.
• 2025-02-11: Discovery Date of Noncompliance for 2024-P4 — The date Carvana, LLC identified the delay in filing required reports for the 2024-P4 transaction.
• 2025-02-12: Filing Date of Delayed Reports for 2024-P4 — The date the overdue Forms 10-D and ABS-EE for the 2024-P4 transaction were eventually filed.

Glossary

Issuing Entity

The special purpose entity that issues the asset-backed securities (in this case, Carvana Auto Receivables Trust 2021-N1). (This is the core entity whose assets are being securitized and whose financial performance is reported.)

Sponsor

The entity that originates or purchases the assets to be securitized and structures the securitization transaction (in this case, Carvana, LLC). (The sponsor's actions, including compliance with filing requirements, directly impact the trust's reporting and regulatory standing.)

Regulation AB

SEC rules governing the registration, reporting, and disclosure requirements for asset-backed securities. (The filing references specific items within Regulation AB (e.g., 1112(b), 1114(b)(2), 1115(b)) to detail the characteristics of the securitized assets and credit support.)

Forms 10-D and ABS-EE

SEC filings required for asset-backed securities. Form 10-D provides distribution and servicing information, while ABS-EE provides information on asset-level data. (The untimely filing of these forms for another transaction (2024-P4) is a key disclosure in this report, highlighting compliance issues.)

External Credit Enhancement

Third-party guarantees or support mechanisms designed to reduce the credit risk of the asset-backed securities. (The absence of external credit enhancement for this trust means investors are directly exposed to the credit risk of the underlying auto loans.)

Year-Over-Year Comparison

This 10-K filing for Carvana Auto Receivables Trust 2021-N1 focuses on the structure and disclosures related to the trust itself, rather than year-over-year financial performance metrics typically found in a corporate 10-K. The primary 'change' or point of emphasis compared to a standard filing is the disclosure of a material noncompliance event by the sponsor concerning a different, albeit related, securitization transaction (2024-P4), highlighting a new operational and regulatory risk.

Filing Documents

• fy25form10-kcrvna2021xn1.htm (10-K) — 127KB
• fy25supplementno1toindentu.htm (EX-4.4) — 39KB
• fy25exhibit311-crvna2021xn1.htm (EX-31.1) — 7KB
• fy25ex331reportonassessmen.htm (EX-33.1) — 131KB
• fy25ex332reportonassessmen.htm (EX-33.2) — 86KB
• fy25ex333reportonassessmen.htm (EX-33.3) — 1232KB
• fy25ex334managementsassess.htm (EX-33.4) — 18KB
• fy25ex341attestationrepo.htm (EX-34.1) — 6KB
• fy25ex342attestationreport.htm (EX-34.2) — 12KB
• fy25ex343attestationreport.htm (EX-34.3) — 11KB
• ex344attestationreporton.htm (EX-34.4) — 6KB
• fy25ex351servicercomplianc.htm (EX-35.1) — 4KB
• ex344attestationreporton001.jpg (GRAPHIC) — 199KB
• ex344attestationreporton002.jpg (GRAPHIC) — 102KB
• fy25ex341attestationrepo001.jpg (GRAPHIC) — 197KB
• fy25ex341attestationrepo002.jpg (GRAPHIC) — 124KB
• image_01a.jpg (GRAPHIC) — 12KB
• image_02a.jpg (GRAPHIC) — 12KB
• image_0a.jpg (GRAPHIC) — 58KB
• image_0b.jpg (GRAPHIC) — 499KB
• image_0c.jpg (GRAPHIC) — 10KB
• picture1a.jpg (GRAPHIC) — 3KB
• picture1b.jpg (GRAPHIC) — 3KB
• 0001842012-26-000014.txt ( ) — 3358KB

Unresolved Staff Comments

Item 1B. Unresolved Staff Comments. None.

Mine Safety Disclosures

Item 4. Mine Safety Disclosures. Not applicable. Substitute information provided 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 ). No single obligor represents 10% or more of the pool assets held by Carvana Auto Receivables Trust 2021-N1 (the " Issuing Entity "). Item 1114(b)(2) of Regulation AB. Credit Enhancement and Other Support, Except for Certain Derivatives Instruments ( Financial Information Regarding Significant Enhancement Providers ). No entity or group of affiliated entities provides any external credit enhancement or other support with respect to either payment of the pool assets held by the Issuing Entity or payments on the notes (the " Notes ") or certificates (the " Certificates ") issued by the Issuing Entity.

(b) of Regulation AB. Certain Derivatives Instruments ( Financial Information )

Item 1115(b) of Regulation AB. Certain Derivatives Instruments ( Financial Information ). No entity or group of affiliated entities provides any derivative instruments that are used to alter the payment characteristics of the cashflows from the Issuing Entity.

of Regulation AB. Legal Proceedings

Item 1117 of Regulation AB. Legal Proceedings. Except as previously disclosed in the final prospectus relating to the Notes publicly offered by the Issuing Entity, no legal proceedings are pending, and no proceedings are known to be contemplated by governmental authorities, against any of the following companies, or of which any property of the following companies is the subject, that are or would be material to holders of the Notes or the Certificates Carvana, LLC (the " Sponsor "), Carvana Receivables Depositor LLC (the " Depositor "), Computershare Trust Company, National Association, as collateral custodian (in such capacity, the " Collateral Custodian ") and as indenture trustee (in such capacity, the " Indenture Trustee "), Bridgecrest Credit Company, LLC (the " Servicer "), or the Issuing Entity. PART II The following items have been omitted in accordance with General Instruction J to Form 10-K (a) Item 5, Market for Registrant's Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities (b) Item 6, Selected Financial Data (c) Item 7, Management's Discussion and Analysis of Financial Condition and Results of Operations (d) Item 7A, Quantitative and Qualitative Disclosures About Market Risk (e) Item 8, Financial Statements and Supplementary Data (f) Item 9, Changes in and Disagreements With Accountants on Accounting and Financial Disclosure (g) Item 9A, Controls and Procedures

Other Information

Item 9B. Other Information. None. Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections. Not Applicable. PART III The following items have been omitted in accordance with General Instruction J to Form 10-K (a) Item 10, Directors, Executive Officers and Corporate Governance (b) Item 11, Executive Compensation (c) Item 12, Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters (d) Item 13, Certain Relationships and Related Transactions, and Director Independence (e) Item 14, Principal Accountant Fees and Services Substitute information provided in accordance with General Instruction J to Form 10-K

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.

of Regulation AB. Compliance with Applicable Servicing Criteria

Item 1122 of Regulation AB. Compliance with Applicable Servicing Criteria. The Sponsor (in its role as administrator), the Servicer, the Collateral Custodian, the Indenture Trustee, the Collateral Custodian Agent and the Indenture Trustee Agent (collectively, the " Servicing Participants ") have each been identified by the registrant as a party participating in the servicing function with respect to the pool assets. Each of the Servicing Participants has provided a report on an assessment of compliance with the servicing criteria applicable to it (each, a " Servicing Report "), which Servicing Reports are attached as exhibits to this Form 10-K. In addition, each of the Servicing Participants has provided an attestation report (each, a " Report on Assessment ") by one or more registered public accounting firms, which Reports on Assessment are also attached as exhibits to this Form 10-K. Management's Assessment of Compliance for the Sponsor has identified a material instance of noncompliance related to the servicing criterion set forth in Item 1122(d)(3)(i)(C)—reports to investors, including those to be filed with the Commission, were not maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports are filed with the Commission as required by its rules and regulations. This material instance of noncompliance does not relate to the asset-backed securities covered in this Form 10-K and issued by the Issuer. The instance involves the matter set forth below On Tuesday, February 11, 2025, while preparing for upcoming monthly filings, the Sponsor discovered that the Forms 10-D and ABS-EE filings for the Carvana Auto Receivables Trust 2024-P4 transaction disclosing activity during the December collection period were not filed on EDGAR within fifteen calendar days of the January 2025 distribution date. Such reports were filed on EDGAR on Wednesday, February 12, 2025. The servicer's certificate associated with

of Regulation AB. Servicer Compliance Statement

Item 1123 of Regulation AB. Servicer Compliance Statement. The Servicer has been identified by the registrant as a servicer with respect to the asset pool held by the Issuing Entity. The Servicer has provided a statement of compliance with applicable servicing criteria (a " Compliance Statement "), signed by an authorized officer of the Sponsor. The Compliance Statement is attached as an exhibit to this Form 10-K. PART IV

Exhibits and Financial Statement Schedules

Item 15. Exhibits and Financial Statement Schedules. (a) (1) List of documents filed as part of this report Not applicable. (2) Not applicable. (3) The exhibits filed in response to Item 601 of Regulation S-K are listed in Item 15(b) below. (b) Exhibits required by Item 601 of Regulation S-K. The exhibits listed below are either included or incorporated by reference as indicated Exhibit Description 3.1 Certificate of Formation of the Depositor (incorporated by reference to Exhibit 3.1 to the Registration Statement on Form SF-3 (No. 333-239650) filed with the Commission by the Depositor on July 2, 2020 (the "Registration Statement")). 3.2 Amended and Restated Limited Liability Company Agreement of the Depositor (incorporated by reference to Exhibit 3.2 to the Registration Statement). 4.1 Indenture, dated as of March 25, 2021 (the "Closing Date"), by and among the Issuing Entity, Carvana Auto Receivables Trust 2021-N1 (the "Grantor Trust"), and the Indenture Trustee (incorporated by reference to Exhibit 4.1 to the Current Report on Form 8-K filed with the Commission by the Depositor on March 30, 2021 (the "Closing 8-K")). 4.2 Amended and Restated Trust Agreement, dated as of the Closing Date, by and between the Depositor and the Owner Trustee (incorporated by reference to Exhibit 4.2 to the Closing 8-K). 4.3 Amended and Restated Grantor Trust Agreement, dated as of the Closing Date, by and between the Issuing Entity and the Grantor Trust Trustee (incorporated by reference to Exhibit 4.3 to the Closing 8-K). 4.4 Supplemental Indenture, dated February 12, 2024, (incorporated by reference to Exhibit 4.1 to the Form 10-D filed on February 15, 2024) 10.1 Receivables Purchase Agreement, dated as of the Closing Date, by and between Carvana and the Depositor (incorporated by reference to Exhibit 10.1 to the Closing 8-K). 10.1.1 Second Amendment to Receivables Purchase Agreement, dated as of December 14, 2022, (incorporated by reference t

Form 10-K Summary

Item 16. Form 10-K Summary. None.

SIGNATURES

SIGNATURES Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized. By Carvana Receivables Depositor LLC, as Depositor By s Mike McKeever Mike McKeever President Date March 26, 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 to security holders, proxy statement, form of proxy or other proxy soliciting material has been sent to security holders or is anticipated to be furnished to security holders subsequent to the filing of this annual report on Form 10-K.

View Full Filing

View this 10-K filing on SEC EDGAR