Carvana Trust Discloses Filing Lapses, Boosts Oversight

TL;DR

**Carvana's compliance hiccup on a separate trust is a red flag for operational risk, but their swift corrective action is a bullish sign for future securitization stability.**

AI Summary

Carvana Auto Receivables Trust 2021-N4, an asset-backed securities issuer, filed its 10-K for the fiscal year ended December 31, 2025. The filing primarily details compliance with servicing criteria and legal disclosures rather than traditional financial performance metrics like revenue or net income, as it is a securitization trust. A key disclosure is 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 2021-N4 trust's assets or investor distributions, which were timely and correct. Carvana, LLC has implemented new policies, including additional attorney oversight, compliance checks, and a comprehensive filing log, to prevent future filing delays. No single obligor represents 10% or more of the pool assets, and no external credit enhancement or derivative instruments are provided by significant entities.

Why It Matters

This 10-K provides crucial transparency for investors in Carvana Auto Receivables Trust 2021-N4, detailing the operational health of the securitization. While the disclosed filing noncompliance by Carvana, LLC for a different trust (2024-P4) did not directly impact 2021-N4's assets or distributions, it highlights potential systemic risks in Carvana's compliance infrastructure. For investors, this signals the importance of robust internal controls in ABS sponsors, especially in a competitive auto lending market where operational efficiency and regulatory adherence are paramount. The implemented corrective actions by Carvana, LLC are vital for restoring investor confidence and ensuring future regulatory compliance across its securitization programs.

Risk Assessment

Risk Level: medium — The risk level is medium due to the disclosed material instance of noncompliance by Carvana, LLC (the Sponsor) regarding untimely SEC filings for a related trust (Carvana Auto Receivables Trust 2024-P4) on February 11, 2025. While this specific issue did not affect the 2021-N4 trust's assets or distributions, it indicates a weakness in the Sponsor's internal controls for regulatory reporting, which could potentially impact other trusts or future filings if not effectively addressed. The prompt implementation of new policies and procedures, including additional attorney oversight and compliance checks, mitigates this risk.

Analyst Insight

Investors should monitor Carvana, LLC's future SEC filings across all its securitization trusts to confirm the effectiveness of the newly implemented compliance procedures. While the 2021-N4 trust's assets were unaffected, this incident underscores the importance of due diligence on the sponsor's operational integrity. Consider this a cautionary note on Carvana's internal controls, but not a direct threat to the 2021-N4 trust's performance.

Financial Highlights

total Assets

N/A

total Debt

N/A

Key Numbers

• 2025-12-31 — Fiscal Year End (The period covered by this 10-K filing.)
• 2026-03-26 — Filing Date (Date the 10-K was filed with the SEC.)
• 2025-02-11 — Discovery Date of Noncompliance (Date Carvana, LLC discovered untimely filings for the 2024-P4 trust.)
• 2025-02-12 — Date of Late Filing (Date Forms 10-D and ABS-EE for 2024-P4 were filed, one day late.)
• 15 — Calendar Days (Required filing timeline for Forms 10-D and ABS-EE after distribution date.)
• 0% — Percentage of Pool Assets (No single obligor represents 10% or more of the pool assets.)

Key Players & Entities

• Carvana Auto Receivables Trust 2021-N4 (company) — issuing entity
• Carvana, LLC (company) — sponsor
• Carvana Receivables Depositor LLC (company) — depositor
• Computershare Trust Company, National Association (company) — collateral custodian and indenture trustee
• Bridgecrest Credit Company, LLC (company) — servicer
• Carvana Auto Receivables Trust 2024-P4 (company) — transaction affected by filing noncompliance
• Mike McKeever (person) — President of Carvana Receivables Depositor LLC
• SEC (regulator) — regulatory body for filings
• Grant Thornton LLP (company) — attestation report provider for Servicer and Sponsor
• PWC (company) — attestation report provider for Computershare Trust Company N.A.

FAQ

Risk Factors

• Untimely Filing of Required Reports [medium — regulatory]: Carvana, LLC, the Sponsor, experienced a material instance of noncompliance due to the untimely filing of Forms 10-D and ABS-EE for the Carvana Auto Receivables Trust 2024-P4 transaction. These filings were due within 15 calendar days of the January 2025 distribution date but were filed on February 12, 2025, one day late. While this specific instance did not impact the 2021-N4 trust, it highlights potential operational weaknesses in timely reporting by the Sponsor.
• Reliance on Sponsor for Reporting [medium — operational]: The Carvana Auto Receivables Trust 2021-N4 is reliant on its Sponsor, Carvana, LLC, for timely and accurate filing of various reports, including Forms 10-D and ABS-EE. The recent late filing for a different trust (2024-P4) indicates a risk of similar occurrences affecting future reporting for the 2021-N4 trust, potentially impacting transparency and investor confidence.
• Compliance with Servicing Criteria [low — legal]: The 10-K filing includes reports on the assessment of compliance with applicable servicing criteria for the Servicer, Indenture Trustee, Collateral Custodian, and Sponsor. While no material instances of noncompliance are detailed for the 2021-N4 trust itself, ongoing adherence to these criteria is crucial for the trust's operational integrity and legal standing.

Industry Context

The auto finance industry, particularly the securitization market, is highly regulated and relies on timely and accurate disclosures. Trends include increasing scrutiny on origination quality and servicer performance. The market is competitive, with entities like Carvana leveraging technology to streamline operations, but this also introduces operational risks related to system failures or reporting lapses.

Regulatory Implications

The material instance of noncompliance by the Sponsor regarding late filings for a different trust (2024-P4) underscores the importance of robust internal controls and compliance procedures. While not directly impacting the 2021-N4 trust, it signals a potential area of heightened regulatory focus on reporting timeliness for all Carvana-sponsored securitizations.

What Investors Should Do

1. Monitor Sponsor's Compliance Procedures
2. Review Servicing Criteria Compliance Reports
3. Assess Pool Diversification

Key Dates

• 2021-12-15: Closing Date — Marks the inception of the Carvana Auto Receivables Trust 2021-N4 and the issuance of notes and certificates.
• 2022-12-14: First Amendment to Receivables Purchase Agreement — Indicates ongoing contractual adjustments related to the purchase of receivables, potentially affecting the pool composition or terms.
• 2025-01-XX: January 2025 Distribution Date — The distribution date for which the 2024-P4 trust's filings were subsequently delayed.
• 2025-02-11: Discovery Date of Noncompliance — The date Carvana, LLC identified the untimely filing for the 2024-P4 transaction.
• 2025-02-12: Date of Late Filing for 2024-P4 — The actual date Forms 10-D and ABS-EE for the 2024-P4 trust were filed, one day after the 15-day deadline.
• 2025-12-31: Fiscal Year End — The end of the reporting period for this 10-K filing.

Glossary

Issuing Entity

The trust that issues asset-backed securities, in this case, Carvana Auto Receivables Trust 2021-N4. (This is the central entity whose assets and operations are being reported on.)

Sponsor

The entity that originates or purchases the assets to be securitized and facilitates the securitization process. Here, it is Carvana, LLC. (The Sponsor's actions, including reporting compliance, directly impact the trust's disclosures and operational integrity.)

Regulation AB

SEC rules governing the registration, reporting, and disclosure requirements for asset-backed securities offerings. (The filing is structured to comply with various items within Regulation AB, such as Item 1112(b) regarding significant obligors.)

Forms 10-D and ABS-EE

SEC filings required for asset-backed securities. Form 10-D provides periodic distribution and servicing information, while ABS-EE provides information on asset-level data. (The untimely filing of these forms for a related trust highlights potential reporting risks.)

Servicing Criteria

A set of standards that servicers of securitized assets must adhere to, assessed and reported on annually. (Compliance with these criteria is a key aspect of the trust's operational health and is reported on in the 10-K.)

Year-Over-Year Comparison

This 10-K filing for Carvana Auto Receivables Trust 2021-N4 focuses on compliance with servicing criteria and legal disclosures, rather than traditional financial performance metrics. A key difference from a typical corporate 10-K is the absence of revenue, net income, or EPS figures, as this is a securitization trust. The primary new information relates to a material instance of noncompliance by the Sponsor (Carvana, LLC) concerning untimely filings for a different trust (2024-P4), highlighting operational risks in reporting, although this did not affect the 2021-N4 trust's operations or distributions.

Filing Documents

• fy25form10-kcrvna2021xn4.htm (10-K) — 126KB
• fy25exhibit311-crvna2021xn4.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_0.jpg (GRAPHIC) — 12KB
• image_01.jpg (GRAPHIC) — 12KB
• image_03.jpg (GRAPHIC) — 58KB
• image_0a.jpg (GRAPHIC) — 499KB
• image_0c.jpg (GRAPHIC) — 10KB
• picture1.jpg (GRAPHIC) — 3KB
• picture12.jpg (GRAPHIC) — 3KB
• 0001845211-26-000014.txt ( ) — 3318KB

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-N4 (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 wit

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 December 15, 2021 (the "Closing Date"), by and among the Issuing Entity, Carvana Auto Receivables Trust 2021-N4 (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 December 20, 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). 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 First Amendment to Receivables Purchase Agreement, dated as of December 14, 2022, (incorporated by reference to Exhibit 10.1 to the Form 10-D filed on December 15, 2022). 10.2 Receivables Transfer Agreement, dated as of the Closing Date, by and

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