Carvana Trust Discloses Late Filings, Bolsters Compliance

TL;DR

**Carvana's securitization arm fumbled SEC filings, but quickly shored up controls – watch for execution on new compliance measures.**

AI Summary

Carvana Auto Receivables Trust 2024-P4, a securitization entity, filed its 10-K for the fiscal year ended December 31, 2025, on March 26, 2026. The filing indicates no single obligor represents 10% or more of the pool assets, and no external credit enhancement or derivative instruments are provided by any entity or group of affiliated entities. 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 December collection period, which were due within fifteen calendar days of the January 2025 distribution date but filed on February 12, 2025. Despite this, the servicer's certificate was delivered timely, and all distributions to investors were correct and timely. Carvana, LLC has implemented new policies, including additional attorney oversight, compliance checks, and a comprehensive log with hyperlinks to EDGAR submissions, to prevent future filing delays. The Servicer, Bridgecrest Credit Company, LLC, and other Servicing Participants reported no material noncompliance.

Why It Matters

This 10-K reveals a critical operational lapse by Carvana, LLC, the sponsor of Carvana Auto Receivables Trust 2024-P4, in its SEC filing compliance. While the late filing of Forms 10-D and ABS-EE did not impact investor distributions or servicer certificates, it signals potential weaknesses in internal controls that could erode investor confidence if not effectively addressed. For investors in Carvana-backed asset-backed securities, this highlights the importance of scrutinizing operational risks beyond credit performance. The competitive landscape for auto ABS relies heavily on transparency and timely reporting, making such compliance issues a potential differentiator for more robust issuers.

Risk Assessment

Risk Level: medium — The risk level is medium due to the disclosed material instance of noncompliance by Carvana, LLC regarding the untimely filing of Forms 10-D and ABS-EE for the Carvana Auto Receivables Trust 2024-P4 transaction. While distributions to investors were correct and timely, the failure to meet SEC filing deadlines, specifically missing the fifteen-calendar-day window for January 2025 distribution date filings, indicates a procedural weakness that could lead to regulatory scrutiny or reputational damage if not fully resolved.

Analyst Insight

Investors should monitor Carvana, LLC's subsequent filings to confirm the effectiveness of the new compliance policies and procedures, including additional attorney oversight and comprehensive logging. While the immediate financial impact was minimal, consistent and timely SEC reporting is a fundamental expectation for asset-backed securities, and any further lapses could signal deeper operational issues.

Financial Highlights

debt To Equity

Not Disclosed

revenue

Not Disclosed

operating Margin

Not Disclosed

total Assets

Not Disclosed

total Debt

Not Disclosed

net Income

Not Disclosed

eps

Not Disclosed

gross Margin

Not Disclosed

cash Position

Not Disclosed

revenue Growth

Not Disclosed

Key Numbers

• 10% — Maximum percentage of pool assets represented by a single obligor (No single obligor represents 10% or more of the pool assets, indicating diversification.)
• 15 calendar days — Required filing timeline for Forms 10-D and ABS-EE (The Sponsor failed to file within this period for the January 2025 distribution date.)
• February 11, 2025 — Date Sponsor discovered filing error (Discovery of the late filing for December collection period activity.)
• February 12, 2025 — Date Forms 10-D and ABS-EE were filed (These forms were filed one day after discovery, exceeding the 15-day deadline.)
• December 31, 2025 — Fiscal year end date (The period covered by this 10-K filing.)
• March 26, 2026 — Filing date of the 10-K (The date this annual report was submitted to the SEC.)

Key Players & Entities

• Carvana Auto Receivables Trust 2024-P4 (company) — Issuing Entity
• Carvana, LLC (company) — Sponsor and administrator, responsible for late filings
• 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) — Securities and Exchange Commission
• Grant Thornton LLP (company) — Auditor for Servicer and Sponsor attestation reports
• PWC (company) — Auditor for Indenture Trustee and Collateral Custodian attestation reports
• Clayton Fixed Income Services LLC (company) — Asset Representations Reviewer

FAQ

Risk Factors

• Untimely Filing of Required Reports [medium — operational]: The Sponsor, Carvana, LLC, experienced a material instance of noncompliance due to the untimely filing of Forms 10-D and ABS-EE for the December collection period. These forms were due within 15 calendar days of the January 2025 distribution date but were filed on February 12, 2025, one day after discovery of the error. While corrective actions have been implemented, including enhanced attorney oversight and compliance checks, the delay indicates potential weaknesses in internal controls.
• Compliance with Regulation AB Filing Requirements [medium — regulatory]: The timely filing of Forms 10-D and ABS-EE is a critical requirement under Regulation AB for securitization trusts. The failure to meet the 15-day deadline, even if corrected promptly, could attract regulatory scrutiny and potentially lead to penalties or further investigations if it becomes a pattern. The disclosure highlights the importance of robust compliance processes for all parties involved.
• Diversification of Pool Assets [low — financial]: The securitization pool consists of auto receivables where no single obligor represents 10% or more of the pool assets. This indicates a diversified portfolio of underlying loans, which generally reduces the concentration risk associated with any single borrower's default impacting the overall performance of the trust.
• Absence of External Credit Enhancement [medium — financial]: The trust does not benefit from any external credit enhancement or support from third parties. This means that the credit quality of the underlying auto receivables and the structural integrity of the securitization itself are the primary sources of protection for investors. The absence of external support places greater reliance on the performance of the collateral and the servicer.
• No Derivative Instruments Utilized [low — financial]: The securitization does not employ any derivative instruments to alter the payment characteristics of the cash flows. This simplifies the structure and reduces counterparty risk associated with derivative counterparties. Investors are therefore exposed directly to the performance of the underlying receivables without the complexities or potential risks of derivatives.

Industry Context

The auto finance industry, particularly the securitization of auto receivables, is a significant segment of the broader credit markets. Companies like Carvana rely on securitization to fund their origination of auto loans. The industry is sensitive to economic conditions, interest rate movements, and regulatory oversight. Competition is intense, with both traditional lenders and newer fintech players vying for market share. Recent trends include increased focus on data analytics for underwriting and servicing, as well as evolving regulatory expectations around consumer protection and disclosure.

Regulatory Implications

The material instance of noncompliance regarding the untimely filing of Forms 10-D and ABS-EE by the Sponsor, Carvana, LLC, highlights potential weaknesses in internal controls and compliance procedures. While corrective actions have been noted, regulators will likely monitor future filings closely. Failure to adhere to SEC reporting requirements under Regulation AB can lead to increased scrutiny, potential fines, and reputational damage.

What Investors Should Do

1. Monitor future filings for compliance.
2. Assess the impact of the Sponsor's compliance issues on overall trust governance.
3. Review the underlying asset pool characteristics for diversification and credit risk.

Key Dates

• 2024-12-17: Closing Date — Marks the official inception of the Carvana Auto Receivables Trust 2024-P4 and the date of the Indenture.
• 2025-01-XX: January 2025 Distribution Date — The due date for the December collection period's Forms 10-D and ABS-EE, which were subsequently filed late.
• 2025-02-11: Sponsor Discovers Filing Error — The date Carvana, LLC identified the noncompliance with filing deadlines for the December collection period.
• 2025-02-12: Forms 10-D and ABS-EE Filed — The actual filing date of the required reports, which was beyond the stipulated 15-day deadline.
• 2025-12-31: Fiscal Year End — The end of the reporting period covered by this 10-K filing.
• 2026-03-26: 10-K Filing Date — The date this annual report for the fiscal year ended December 31, 2025, was submitted to the SEC.

Glossary

Regulation AB

A U.S. Securities and Exchange Commission (SEC) regulation that governs the disclosure and reporting requirements for asset-backed securities offerings. (This regulation dictates many of the filing requirements (like Forms 10-D and ABS-EE) and disclosures made within this 10-K filing, including those related to significant obligors and credit enhancement.)

Significant Obligor

An obligor whose obligations represent 10% or more of the pool assets in an asset-backed securities transaction. (The filing explicitly states that no single obligor meets this threshold, indicating diversification within the pool of auto receivables.)

Credit Enhancement

Mechanisms used in securitization to reduce the credit risk of the underlying assets and protect investors from losses. This can include overcollateralization, subordination, or guarantees. (The absence of external credit enhancement means investors rely solely on the quality of the collateral and the servicer's performance.)

Derivative Instruments

Financial contracts whose value is derived from an underlying asset, index, or rate. In securitization, they can be used to alter cash flow characteristics or hedge risks. (The disclosure confirms that no such instruments are used, simplifying the trust's structure and reducing counterparty risk.)

Sponsor

The entity that initiates the securitization process, typically by originating or purchasing the assets to be securitized and arranging for their transfer to a securitization vehicle. (Carvana, LLC is identified as the Sponsor, and its compliance failures regarding timely filings are a key point of disclosure.)

Servicer

The entity responsible for managing the underlying assets (e.g., collecting payments, handling delinquencies) after securitization. (Bridgecrest Credit Company, LLC is the Servicer, and it reported no material noncompliance.)

Form 10-D

A report filed by asset-backed issuers with the SEC that provides information about the status of the securitized assets and any material events that occurred during a reporting period. (The untimely filing of this form by the Sponsor is a central compliance issue highlighted in the report.)

Form ABS-EE

A report filed by asset-backed issuers with the SEC that provides detailed information about the underlying assets and the structure of the securitization, often filed annually or upon certain events. (Similar to Form 10-D, the late filing of this form by the Sponsor is a key compliance concern.)

Year-Over-Year Comparison

This filing represents the initial 10-K for the Carvana Auto Receivables Trust 2024-P4, as it pertains to the fiscal year ended December 31, 2025. Therefore, a direct comparison of key metrics like revenue growth, margin changes, or specific financial highlights to a prior year's filing is not applicable. The primary focus of this report is on the structure, disclosures, and initial operational events, including a notable instance of noncompliance by the Sponsor regarding filing deadlines.

Filing Documents

• fy25form10-kcrvna2024xp4.htm (10-K) — 122KB
• fy25exhibit311-2024xp4.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
• 0001999854-26-000014.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-P4 (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 relates 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 10-D was

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 December 17, 2024 (the "Closing Date"), by and among the Issuing Entity, Carvana Auto Receivables Trust 2024-P4 (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 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 Servicin

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