Carvana Trust Flags Filing Lapses, Boosts Compliance

TL;DR

**Carvana's administrative slip-up on SEC filings for a related trust is a red flag for operational risk, even if this specific trust wasn't directly impacted.**

AI Summary

Carvana Auto Receivables Trust 2024-P3's 2025 10-K filing primarily details compliance with servicing criteria for its asset-backed securities. The trust, sponsored by Carvana, LLC, reported no single obligor representing 10% or more of its pool assets, nor any external credit enhancement or derivative instruments altering cashflows. A material instance of noncompliance was identified for the Sponsor, Carvana, LLC, related to 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 filed one day late on February 12, 2025. This specific noncompliance did not impact the Carvana Auto Receivables Trust 2024-P3, and all distributions to investors for the affected transaction were correct and timely. In response, Carvana, LLC has implemented new policies, including additional attorney oversight, compliance checks, and a comprehensive log of transactions and filings, to ensure timely SEC submissions for all future reports.

Why It Matters

This filing highlights operational risks within Carvana's securitization process, specifically regarding regulatory compliance. While the identified noncompliance for Carvana Auto Receivables Trust 2024-P4 did not directly affect Carvana Auto Receivables Trust 2024-P3, it signals potential systemic issues in Carvana, LLC's internal controls for SEC filings. For investors, this raises questions about the robustness of Carvana's administrative functions supporting its asset-backed securities, potentially impacting investor confidence and the perceived reliability of future filings. The competitive landscape for auto loan securitization demands impeccable compliance, and any lapses could make Carvana's offerings less attractive compared to peers with flawless regulatory records.

Risk Assessment

Risk Level: medium — The risk level is medium due to a material instance of noncompliance identified for 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 the reports were filed one day late on February 12, 2025, and did not affect the current trust's assets or investor distributions, it indicates a weakness in internal controls over regulatory reporting for the sponsor.

Analyst Insight

Investors should monitor Carvana, LLC's subsequent 10-D and 10-K filings across all its trusts to confirm the effectiveness of the new compliance procedures. While the direct financial impact on Carvana Auto Receivables Trust 2024-P3 is minimal, the administrative lapse suggests broader operational diligence concerns that warrant close observation.

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

• 1 — number of material instances of noncompliance (related to Carvana Auto Receivables Trust 2024-P4 filings)
• 1 — number of days late for specific SEC filings (Forms 10-D and ABS-EE for Carvana Auto Receivables Trust 2024-P4)
• 0% — percentage of pool assets represented by any single obligor (no single obligor represents 10% or more of pool assets)

Key Players & Entities

• Carvana Auto Receivables Trust 2024-P3 (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
• Vervent Inc. (company) — backup servicer
• Clayton Fixed Income Services LLC (company) — asset representations reviewer
• February 11, 2025 (date) — date of discovery of filing noncompliance
• February 12, 2025 (date) — date of late filing for Carvana Auto Receivables Trust 2024-P4
• Mike McKeever (person) — President of Carvana Receivables Depositor LLC

FAQ

Risk Factors

• Timely SEC Filing Compliance [medium — operational]: A material instance of noncompliance was identified for the Sponsor, Carvana, LLC, related to 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 filed one day late on February 12, 2025. This specific noncompliance did not impact the Carvana Auto Receivables Trust 2024-P3.

Industry Context

The auto receivables securitization market is a significant component of the broader asset-backed securities (ABS) landscape. It allows originators like Carvana to access capital markets by pooling auto loans and selling them to investors. Key trends include evolving regulatory scrutiny, particularly around disclosure and compliance, and investor demand for yield in a fluctuating interest rate environment. The performance of these ABS is closely tied to the credit quality of the underlying auto loans and the operational efficiency of the servicers.

Regulatory Implications

The identified material instance of noncompliance, though related to a different trust (2024-P4), highlights the critical importance of timely and accurate SEC filings for all securitization vehicles. Regulators like the SEC place a high emphasis on these disclosures for investor protection. Failure to comply can lead to increased scrutiny, potential penalties, and damage to the sponsor's reputation.

What Investors Should Do

1. Monitor Carvana, LLC's compliance procedures.
2. Review the Asset Representations Review Agreement (Exhibit 10.6).
3. Confirm the absence of external credit enhancement or derivatives.

Key Dates

• 2024-09-17: Closing Date — Marks the inception of the Carvana Auto Receivables Trust 2024-P3 and the execution of key agreements like the Indenture and Receivables Purchase Agreement.
• 2025-02-11: Original Filing Due Date for 2024-P4 Forms 10-D and ABS-EE — This date highlights the original deadline for related trust filings, the breach of which led to a reported noncompliance.
• 2025-02-12: Actual Filing Date for 2024-P4 Forms 10-D and ABS-EE — The one-day delay in filing for the 2024-P4 transaction represents the identified material instance of noncompliance.

Glossary

Issuing Entity

The trust or special purpose entity that issues the asset-backed securities. (Refers to Carvana Auto Receivables Trust 2024-P3, the entity whose assets are securitized.)

Regulation AB

SEC rules governing the registration, reporting, and disclosure requirements for asset-backed securities. (The filing is structured to comply with various items of Regulation AB, detailing pool assets, credit enhancement, and derivatives.)

Servicer

The entity responsible for managing the pool of assets, including collecting payments from obligors and distributing them to investors. (Details about the servicer's compliance with servicing criteria are a key focus of the filing.)

Sponsor

The entity that initiates the securitization process, typically by originating or purchasing the assets to be securitized. (Carvana, LLC is identified as the Sponsor, and its compliance actions are noted.)

Indenture Trustee

A trustee appointed under an indenture to represent the interests of the noteholders. (The Indenture Trustee is a key party in the securitization structure, overseeing the terms of the notes.)

Depositor

An entity that purchases assets from the sponsor and transfers them to the issuing entity. (The Depositor plays a role in the transfer of receivables into the trust.)

Year-Over-Year Comparison

This filing pertains to the Carvana Auto Receivables Trust 2024-P3, which was established on September 17, 2024. As such, a direct year-over-year comparison of financial metrics like revenue growth or margin changes is not applicable for this specific trust in this report. The primary focus is on the initial structure, compliance with servicing criteria, and the absence of significant obligors or external credit enhancements. The key comparative element is the identified operational lapse in timely filings for a different, though related, trust (2024-P4).

Filing Documents

• fy25form10-kcrvna2024xp3.htm (10-K) — 122KB
• fy25exhibit311-2024xp3.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) — 58KB
• image_02.jpg (GRAPHIC) — 12KB
• image_0a.jpg (GRAPHIC) — 499KB
• image_0c.jpg (GRAPHIC) — 10KB
• picture1.jpg (GRAPHIC) — 3KB
• picture12.jpg (GRAPHIC) — 3KB
• 0001999856-26-000014.txt ( ) — 3313KB

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 2024-P3 (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 and the Indenture Trustee (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 such Form 1

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. 333-263473) filed with the Commission by the Depositor on March 11, 2022 (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 September 17, 2024 (the "Closing Date"), by and among the Issuing Entity, Carvana Auto Receivables Trust 2024-P3 (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 September 19, 2024 (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). 10.2 Receivables Transfer Agreement, dated as of the Closing Date, by and between the Depositor and the Issuing Entity (incorporated by reference to Exhibit 10.2 to the Closing 8-K). 10.3 Receivables Contribution Agreement, dated as of the Closing Date, by and between the Issuing Entity and the Grantor Trust (incorporated by reference to Exhibit 10.3 to the Closing 8-K). 10.4 Servicing Agreement, dated as of the Closing Date, by and among the Issuing Entity, the Grantor Trust, the Servicer, the Indenture Trustee and Vervent Inc. (the "Backup Servicer") (incorporated by reference to Exhibit 10.4 to the Closing 8-K). 10.5 Backup Servic

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