Carvana Trust 2025-P4 Reports Compliance, Sponsor Flags Filing Lapses

TL;DR

**Carvana's securitization trust is operationally sound, but the sponsor's past filing gaffes are a red flag for future deals.**

AI Summary

Carvana Auto Receivables Trust 2025-P4, a securitization entity, filed its 10-K for the fiscal year ended December 31, 2025, primarily detailing compliance with servicing criteria rather than traditional financial performance. The filing explicitly states that 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 material instance of noncompliance was 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, which were filed one day late on February 12, 2025. This specific noncompliance did not impact the 2025-P4 trust's distributions or asset servicing. 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 transactions. Other Servicing Participants, including Bridgecrest Credit Company, LLC, Computershare Trust Company, National Association, and Clayton Fixed Income Services LLC, reported no material instances of noncompliance.

Why It Matters

This 10-K provides crucial transparency for investors in Carvana Auto Receivables Trust 2025-P4, an asset-backed security, by detailing the compliance of its servicing participants. The disclosed material noncompliance by Carvana, LLC, the Sponsor, regarding late SEC filings for a prior trust (2024-P4) highlights operational risks that could erode investor confidence in Carvana's broader securitization program, even if the current trust's assets were unaffected. While the immediate impact on 2025-P4 noteholders is minimal due to timely distributions, consistent operational missteps could lead to increased scrutiny from regulators like the SEC and potentially higher borrowing costs for Carvana in future securitizations, impacting its competitive position against rivals like Ally Financial or Capital One in the auto lending space.

Risk Assessment

Risk Level: medium — The risk level is medium due to the disclosed material instance of noncompliance by Carvana, LLC, the Sponsor, regarding late SEC filings for the Carvana Auto Receivables Trust 2024-P4 transaction on February 11, 2025. While this specific issue did not affect the 2025-P4 trust's distributions or asset servicing, it indicates a weakness in internal controls and compliance procedures that could impact future securitizations or regulatory standing. The absence of external credit enhancement also means investors rely solely on the performance of the underlying auto receivables.

Analyst Insight

Investors should monitor Carvana's future SEC filings closely to ensure the new compliance procedures are effective and prevent recurrence of filing delays. While the 2025-P4 trust appears stable, this operational lapse by the sponsor warrants caution regarding Carvana's overall securitization program and its ability to manage regulatory requirements consistently.

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

• December 31, 2025 — Fiscal year end (Reporting period for the 10-K)
• February 11, 2025 — Date of discovery of late filing (Sponsor discovered Forms 10-D and ABS-EE for 2024-P4 were not filed)
• February 12, 2025 — Date of late filing (Forms 10-D and ABS-EE for 2024-P4 were filed one day late)
• 10% — Threshold for significant obligor (No single obligor represents 10% or more of pool assets)

Key Players & Entities

• Carvana Auto Receivables Trust 2025-P4 (company) — Issuing Entity
• Carvana, LLC (company) — Sponsor and administrator, identified with material noncompliance
• Carvana Auto Receivables Trust 2024-P4 (company) — Prior transaction affected by late SEC filings
• Carvana Receivables Depositor LLC (company) — Depositor
• Bridgecrest Credit Company, LLC (company) — Servicer
• Computershare Trust Company, National Association (company) — Collateral Custodian and Indenture Trustee
• Clayton Fixed Income Services LLC (company) — Asset Representations Reviewer
• Vervent Inc. (company) — Backup Servicer
• Mike McKeever (person) — President of Carvana Receivables Depositor LLC
• SEC (regulator) — Securities and Exchange Commission

FAQ

Risk Factors

• Untimely SEC Filings by Sponsor [medium — operational]: 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 forms were due on February 11, 2025, but were filed one day late on February 12, 2025. This specific delay did not affect the 2025-P4 trust's distributions or asset servicing.
• Compliance with Regulation AB [medium — regulatory]: The filing primarily details compliance with servicing criteria under Regulation AB. Key aspects include confirming no single obligor represents 10% or more of the pool assets and the absence of external credit enhancement or derivative instruments from affiliated entities. Adherence to these regulations is crucial for investor confidence and the smooth operation of the securitization trust.

Industry Context

The auto finance industry, particularly within the securitization market, is heavily regulated and relies on robust servicing and disclosure practices. Trends include increasing focus on transparency and compliance with regulations like Regulation AB, driven by investor demand for clarity on asset quality and operational integrity. The market is competitive, with entities like Carvana leveraging technology to manage large volumes of auto loans, while also facing scrutiny over reporting timeliness and accuracy.

Regulatory Implications

The identified instance of untimely filing by the Sponsor, Carvana, LLC, highlights potential regulatory risks associated with SEC reporting deadlines. While this specific event did not impact the 2025-P4 trust, it underscores the importance of stringent internal controls and processes to ensure ongoing compliance with all filing requirements under Regulation AB. Failure to do so could lead to increased regulatory scrutiny and potential penalties.

What Investors Should Do

1. Monitor Sponsor's Compliance Remediation
2. Assess Servicing Participant Performance
3. Review Asset Pool Diversification

Key Dates

• 2025-11-25: Closing Date of Indenture — Marks the official establishment of the securitization trust and the terms under which the notes and certificates are issued and governed.
• 2025-11-26: Filing of Form 8-K regarding Closing — Publicly announces the closing of the securitization transaction, providing investors with key details and incorporated exhibits.
• 2025-02-11: Original Due Date for 2024-P4 Forms 10-D and ABS-EE — The date by which the Sponsor was required to file critical reporting documents for the prior securitization transaction.
• 2025-02-12: Actual Filing Date for 2024-P4 Forms 10-D and ABS-EE — The date the Sponsor filed the overdue reports, highlighting a one-day delay and triggering a compliance issue.
• 2025-12-31: Fiscal Year End — The reporting period covered by this 10-K filing, detailing the trust's compliance and operational status.

Glossary

Issuing Entity

The special purpose entity (SPE) created to issue securities backed by a pool of assets, in this case, auto receivables. (This is the core entity of the securitization, Carvana Auto Receivables Trust 2025-P4, whose operations and compliance are detailed in the filing.)

Regulation AB

SEC rules governing the registration, reporting, and disclosure requirements for asset-backed securities. (The filing is structured around compliance with various items of Regulation AB, particularly concerning servicing criteria and significant obligors.)

Significant Obligor

An obligor whose obligations represent 10% or more of the pool assets. (The filing explicitly states that no single obligor meets this threshold for the 2025-P4 trust, indicating diversification within the pool.)

External Credit Enhancement

Third-party guarantees or support mechanisms designed to protect investors from losses on the securitized assets. (The absence of external credit enhancement means the performance of the notes and certificates relies solely on the quality of the underlying auto receivables and the servicer's performance.)

Derivative Instruments

Financial contracts whose value is derived from an underlying asset, used here to alter cash flow characteristics. (The absence of derivative instruments simplifies the transaction structure and reduces counterparty risk.)

Servicer

The entity responsible for collecting payments from obligors, managing the receivables, and distributing funds to investors. (The performance of the servicer is critical to the trust's operations, and compliance with servicing criteria is a key focus of the filing.)

Sponsor

The entity that originates or purchases the assets to be securitized and initiates the securitization process. (Carvana, LLC is the sponsor, and its compliance, particularly regarding SEC filings, is a key point of discussion in the report.)

Indenture Trustee

A fiduciary appointed to represent the interests of the noteholders under the indenture agreement. (The Indenture Trustee plays a crucial role in overseeing the trust's compliance and ensuring adherence to the terms of the indenture.)

Year-Over-Year Comparison

This filing for Carvana Auto Receivables Trust 2025-P4 focuses on the operational and compliance aspects of the securitization trust as of its closing date and fiscal year-end. Unlike a traditional company's 10-K, it does not present comparative financial performance metrics such as revenue growth or net income, as the trust is a static pool of assets. The primary 'comparison' point relates to the identified compliance issue with the Sponsor's prior filing for the 2024-P4 transaction, highlighting corrective actions taken to prevent recurrence.

Filing Documents

• fy25form10-kcrvna2025xp4.htm (10-K) — 123KB
• fy25exhibit311-2025xp4.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
• 0002037952-26-000014.txt ( ) — 3315KB

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 2025-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 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 November 25 , 2025, (the "Closing Date"), by and among the Issuing Entity, Carvana Auto Receivables Trust 2025-P 4 (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 November 26 , 2025 (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 Serv

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