Ally Auto Trust 2022-1 Reports Clean Servicing, Trustee Faces RMBS Headwinds

TL;DR

**Ally Auto Receivables Trust 2022-1 is operationally sound, but keep an eye on U.S. Bank's ongoing legal battles; they're a ticking time bomb for the trustee, not the trust directly.**

AI Summary

Ally Auto Receivables Trust 2022-1, a securitization entity, filed its 10-K for the fiscal year ended December 31, 2025, indicating no significant obligors or external credit enhancement for its pool assets or notes. The trust reported no current or threatened legal proceedings that would materially adversely affect the performance of its notes. Ally Bank and U.S. Bank Trust Company, National Association, as Servicing Participants, each filed reports on assessment of compliance with SEC Regulation AB Servicing Criteria for the year ended December 31, 2025, with no material instances of noncompliance identified. Ally Bank also provided a Servicer Compliance Statement for the same period. The filing highlights the ongoing legal challenges faced by U.S. Bank National Association, the indenture trustee, related to residential mortgage-backed securities (RMBS) and student loan trusts, specifically the NCMSLT Action, though U.S. Bank denies liability and is vigorously contesting these claims. The trust's structure, established on May 18, 2022, involves Ally Auto Assets LLC as depositor and Ally Bank as sponsor and servicer.

Why It Matters

This 10-K provides critical transparency for investors in Ally Auto Receivables Trust 2022-1, confirming the robust compliance of its servicing participants, Ally Bank and U.S. Bank Trust Company, National Association, with SEC Regulation AB. The absence of significant obligors or external credit enhancement means the performance of the notes is directly tied to the underlying auto loan pool. While the trust itself faces no direct legal threats, the ongoing RMBS and student loan litigation against U.S. Bank National Association, the indenture trustee, introduces a layer of systemic risk for investors, potentially impacting the trustee's operational focus or financial stability, which could indirectly affect the trust's administration. This competitive context underscores the importance of diligent trustee oversight in the broader securitization market.

Risk Assessment

Risk Level: medium — The risk level is medium due to the significant ongoing legal proceedings against U.S. Bank National Association, the indenture trustee, as detailed in Item 1117. While these lawsuits (RMBS and the NCMSLT Action) are not directly against Ally Auto Receivables Trust 2022-1, they could impact the trustee's capacity or reputation, potentially affecting the trust's administration. U.S. Bank denies liability and is contesting these claims vigorously, but the outcome remains uncertain.

Analyst Insight

Investors should monitor the progress of the legal proceedings against U.S. Bank National Association, the indenture trustee, as reported in future filings. While the trust's servicing is compliant, any adverse outcome for U.S. Bank could introduce indirect operational or reputational risks to the securitization, warranting a review of the trustee's role and potential successor provisions.

Financial Highlights

total Assets

N/A

total Debt

N/A

Key Numbers

• 2025 — Fiscal Year End (The reporting period for this 10-K.)
• 333-262894-01 — Commission File Number (Identifies Ally Auto Receivables Trust 2022-1 with the SEC.)
• 0001922474 — Central Index Key Number (Unique identifier for Ally Auto Receivables Trust 2022-1.)
• March 27, 2026 — Filing Date (Date the 10-K was officially filed.)
• May 10, 2022 — Prospectus Date (Date of the prospectus referenced for Item 1119 information.)

Key Players & Entities

• Ally Auto Receivables Trust 2022-1 (company) — issuing entity
• Ally Auto Assets LLC (company) — depositor
• Ally Bank (company) — sponsor and servicer
• U.S. Bank National Association (company) — indenture trustee and successor special servicer
• U.S. Bank Trust Company, National Association (company) — Servicing Participant and Indenture Trustee
• BNY Mellon Trust of Delaware (company) — Owner Trustee and Paying Agent
• Clayton Fixed Income Services LLC (company) — Asset Representations Reviewer
• Elliot Kahan (person) — President of Ally Auto Assets LLC
• December 31, 2025 (date) — fiscal year end
• May 18, 2022 (date) — original trust agreement date

FAQ

Risk Factors

• Indenture Trustee Legal Challenges [medium — legal]: U.S. Bank National Association, the indenture trustee, is facing ongoing legal challenges related to residential mortgage-backed securities and student loan trusts, specifically the NCMSLT Action. While U.S. Bank denies liability and is contesting these claims, any adverse outcome could potentially impact its ability to fulfill its duties as indenture trustee for Ally Auto Receivables Trust 2022-1.

Industry Context

The auto finance industry, particularly within the securitization market, relies on consistent performance of auto loan pools. Securitization trusts like Ally Auto Receivables Trust 2022-1 are crucial for providing liquidity to originators and offering investment opportunities. However, the market is sensitive to economic conditions affecting borrower repayment capabilities and interest rate fluctuations impacting the value of receivables.

Regulatory Implications

Compliance with SEC Regulation AB is paramount for asset-backed securities. The filing demonstrates adherence to servicing criteria through reports from Ally Bank and U.S. Bank Trust Company, National Association, and their respective independent accountants. Any future changes in Regulation AB or related interpretations could impact disclosure requirements and operational standards for such trusts.

What Investors Should Do

1. Monitor U.S. Bank's legal proceedings
2. Review Servicing Criteria Compliance Reports
3. Acknowledge absence of credit enhancement and significant obligors

Key Dates

• 2022-05-18: Establishment of Ally Auto Receivables Trust 2022-1 — Marks the inception of the securitization trust and the effective date for key agreements like the Indenture and Trust Agreement.
• 2025-12-31: Fiscal Year End — The period covered by the Servicing Criteria compliance reports and Servicer Compliance Statement.
• 2026-02-26: U.S. Bank Trust Company, National Association Attestation Report Date — Indicates the completion of the registered public accounting firm's attestation for U.S. Bank's compliance with servicing criteria for the year ended December 31, 2025.
• 2026-03-06: Ally Bank Attestation Report Date — Indicates the completion of the registered public accounting firm's attestation for Ally Bank's compliance with servicing criteria for the year ended December 31, 2025.
• 2026-03-27: 10-K Filing Date — The official date the annual report was filed with the SEC, providing the most current overview of the trust's status.

Glossary

Issuing Entity

The special purpose entity (Ally Auto Receivables Trust 2022-1) established to issue notes and certificates backed by a pool of assets. (This is the core entity of the securitization structure being reported on.)

Regulation AB

SEC rules governing the registration, reporting, and disclosure requirements for asset-backed securities. (The filing includes compliance reports related to Regulation AB Servicing Criteria, ensuring adherence to disclosure and operational standards.)

Indenture Trustee

A financial institution appointed to act on behalf of the noteholders, ensuring the terms of the indenture are met. (U.S. Bank Trust Company, National Association serves this role, and its own legal challenges are noted as a potential risk.)

Servicer Compliance Statement

A statement provided by the servicer (Ally Bank) confirming its compliance with the terms of the servicing agreement and applicable servicing criteria. (This statement, along with the attestation report, provides assurance on the operational performance of the servicer.)

Significant Obligors

The largest obligors whose receivables constitute a significant portion of the asset pool. (The filing explicitly states there are no significant obligors for this trust, simplifying risk assessment related to concentration.)

External Credit Enhancement

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

Year-Over-Year Comparison

This 10-K filing for Ally Auto Receivables Trust 2022-1 covers the fiscal year ending December 31, 2025. As this is a specific securitization trust filing, direct year-over-year financial metric comparisons (like revenue growth or net income) are not applicable in the same way as for a corporate entity. Instead, the focus is on the operational and compliance aspects of the trust, such as the Servicing Criteria compliance reports and the absence of new material risks or legal proceedings directly impacting the trust's performance, beyond the noted challenges of the indenture trustee.

Filing Documents

• aart2022-112_31x2510xk.htm (10-K) — 102KB
• aart2022-1exhibit3112025.htm (EX-31.1) — 9KB
• aart2022-1exhibit3312025.htm (EX-33.1) — 70KB
• aart2022-1exhibit3322025.htm (EX-33.2) — 53KB
• aart2022-1exhibit3412025.htm (EX-34.1) — 9KB
• aart2022-1exhibit3422025.htm (EX-34.2) — 7KB
• aart2022-1exhibit3512025.htm (EX-35.1) — 13KB
• 0001922474-26-000017.txt ( ) — 264KB

Management's Discussion and Analysis of Financial Condition and Results of Operations*

Management's Discussion and Analysis of Financial Condition and Results of Operations* Item 7A.

Quantitative and Qualitative Disclosures About Market Risk*

Quantitative and Qualitative Disclosures About Market Risk* Item 8.

Financial Statements and Supplementary Data*

Financial Statements and Supplementary Data* Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure* Item 9A.

Controls and Procedures*

Controls and Procedures* Item 9B. Other Information Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections Part III Item 10. Directors, Executive Officers and Corporate Governance* Item 11.

Executive Compensation*

Executive Compensation* Item 12.

Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters*

Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters* Item 13. Certain Relationships and Related Transactions and Director Independence* Item 14. Principal Accounting Fees and Services* Part IV Item 15. Exhibit and Financial Statement Schedules Item 16. Form 10-K Summary * Item is omitted in accordance with General Instruction J to Form 10-K. 3 Part I

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). There are no significant obligors with respect to the pool assets held by Ally Auto Receivables Trust 2022-1 (the "Issuing Entity"). Item 1114(b)(2) of Regulation AB. Credit Enhancement and Other Support, Except for Certain Derivatives Instruments (Financial Information). 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. There are no current legal proceedings pending, or to the best knowledge of management of such entity, threatened, against the Issuing Entity, the sponsor, the servicer or the depositor that, if determined adversely to such party, would be expected to have a material adverse effect on the performance of the notes. The owner trustee has represented to the Issuing Entity that it is not a party to any current legal proceedings, nor is its management aware of any legal proceedings threatened against it that, if determined adversely to such party, would be expected to have a material adverse effect on the performance of the notes. The indenture trustee has provided the following information for inclusion in this report on Form 10-K U.S. Bank National Association ("U.S. Bank") and other large financial institutions have been sued in their capacity as trustee or successor trustee for certain residential mortgage backed securities (RMBS) trusts. The complaints, primarily filed by investors or investor groups against U.S. Bank and similar institutions, allege the trustees caused losses to investors as a result of alleged failures by the sponsors, mortgage loan sellers and servicers to comply with the governing agreements for these RMBS trusts. Plaintiffs generally assert causes of action based upon the trustees' purported failures to enforce repurchase obligations of mortgage loan sellers for alleged breaches of representations and warranties, notify securityholders of purported events of default allegedly caused by breaches of servicing standards by mortgage loan servicers and abide by a heightened standard of care following alleged events of default. U.S. Bank denies liability and believes that it has performed its obligations under the RMBS trusts in good faith, that its actions were not the cause of losses to investors, that it has meritorious defenses, and it has contested and intends to continue contesting the pl

Other Information

Item 9B. Other Information. None.

Disclosure Regarding Foreign Jurisdictions that Prevent Inspections

Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections. Not applicable. Part III 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. The information has been provided previously in a Prospectus, dated May 10, 2022, filed by the Issuing Entity, pursuant to Rule 424(b)(5) of the Securities Act of 1933 on May 12, 2022.

of Regulation AB. Compliance with Applicable Servicing Criteria

Item 1122 of Regulation AB. Compliance with Applicable Servicing Criteria. Each of Ally Bank and U.S. Bank Trust Company, National Association (each, a "Servicing Participant") has been identified by the registrant as a party participating in the servicing function with respect to the pool assets held by the Issuing Entity during the reporting period. Each of the Servicing Participants has completed a report on an assessment of compliance with the servicing criteria applicable to such Servicing Participant (each, a "Report on Assessment") during the Issuing Entity's year ended December 31, 2025, which Reports on Assessment are attached as exhibits to this Form 10-K. In addition, each of the Servicing Participants has provided an attestation report (each, an "Attestation Report") by a registered independent public accounting firm regarding its related Report on Assessment. Each Attestation Report is attached as an exhibit to this Form 10-K. None of the Reports on Assessment or the related Attestation Reports has identified any material instances of noncompliance with the servicing criteria described in the related Report on Assessment as being applicable to each such Servicing Participant.

of Regulation AB. Servicer Compliance Statement

Item 1123 of Regulation AB. Servicer Compliance Statement. Ally Bank has been identified as the servicer during the reporting period with respect to the pool assets held by the Issuing Entity. Ally Bank has provided a statement of compliance with the applicable servicing activities (the "Compliance Statement"), signed by an authorized officer, and such Compliance Statement is attached as an exhibit to this Form 10-K. 5 Part IV

Exhibit and Financial Statement Schedules

Item 15. Exhibit and Financial Statement Schedules. (a) List the following documents filed as a part of the report (1) Financial Statements — Not Applicable. (2) Financial Statement Schedules — Not Applicable. (3) Exhibits Second Amended and Restated Limited Liability Company Agreement of Ally Auto Assets LLC, dated as of November 7, 2018. Indenture between Ally Auto Receivables Trust 2022-1 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of May 18, 2022. Trust Agreement between Ally Auto Assets LLC, as Depositor and BNY Mellon Trust of Delaware, as Owner Trustee and Paying Agent, dated as of May 18, 2022. Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of May 18, 2022. Rule 13a-14(d)15d-14(d) Certification (Section 302 Certification). Report on Assessment of Compliance with SEC Regulation AB Servicing Criteria concerning activities of Ally Bank for the year ended December 31, 202 5 . Report on Assessment of Compliance with SEC Regulation AB Servicing Criteria concerning activities of U.S. Bank Trust Company, National Association for the year ended December 31, 202 5 . Registered Public Accounting Firm Attestation Report on Assessment of Compliance with applicable Servicing Criteria of Ally Bank dated March 6 , 202 6 for the year ended December 31, 202 5 . Registered Public Accounting Firm Attestation Report on Assessment of Compliance with applicable Servicing Criteria of U.S. Bank Trust Company, National Association dated February 2 6 , 202 6 for the year ended December 31, 202 5 . Servicer Compliance Statement of Ally Bank for the year ended December 31, 202 5 . Trust Sale Agreement between Ally Auto Assets LLC, as Depositor, and Ally Auto Receivables Trust 2022-1, as Issuing Entity, dated as of May 18, 2022. Custodian Agreement between Ally Bank, as Custodian, and Ally Auto Assets LLC, as Depositor, dated as of May 18, 2022. Administration Agreement among Ally Aut

Form 10-K Summary

Item 16. Form 10-K Summary. None. 6 Signature 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 thereunto duly authorized. Ally Auto Assets LLC, as Depositor s Elliot Kahan Elliot Kahan President (Senior Officer in charge of securitization of the depositor) Date March 27, 2026 7 Index of Exhibits Exhibit Description Method of Filing 3.1 Second Amended and Restated Limited Liability Company Agreement of Ally Auto Assets LLC, dated as of November 7, 2018. ** 4.1 Indenture between Ally Auto Receivables Trust 2022-1 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of May 18, 2022. * 4.2 Trust Agreement between Ally Auto Assets LLC, as Depositor and BNY Mellon Trust of Delaware, as Owner Trustee and Paying Agent, dated as of May 18, 2022. * 4.3 Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of May 18, 2022. * 31.1 Certification of Executive Officer Pursuant to Rule 13a-14(d)15d-14(d). Filed herewith. 33.1 Report on Assessment of Compliance with SEC Regulation AB Servicing Criteria concerning activities of Ally Bank for the year ended December 31, 2025. Filed herewith. 33.2 Report on Assessment of Compliance with SEC Regulation AB Servicing Criteria concerning activities of U.S. Bank Trust Company, National Association for the year ended December 31, 2025. Filed herewith. 34.1 Registered Public Accounting Firm Attestation Report on Assessment of Compliance with applicable Servicing Criteria of Ally Bank dated March 6, 2026 for the year ended December 31, 2025. Filed herewith. 34.2 Registered Public Accounting Firm Attestation Report on Assessment of Compliance with applicable Servicing Criteria of U.S. Bank Trust Company, National Association, dated February 26, 2026 for the year ended December 31, 2025. Filed herewith. 35.1 Servicer Compliance

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