Ally Auto Trust 2022-2 Reports Clean Servicing, Trustee Faces RMBS Headwinds

TL;DR

**Ally Auto Receivables Trust 2022-2 is operationally sound, but keep an eye on U.S. Bank's broader legal woes as a trustee, which could signal systemic risks for securitized products.**

AI Summary

The Ally Auto Receivables Trust 2022-2 10-K filing for the fiscal year ended December 31, 2025, indicates a stable operational period with no significant obligors for its pool assets and no external credit enhancement or derivative instruments altering cashflows. Ally Bank, as the servicer, and U.S. Bank Trust Company, National Association, as a servicing participant, both reported full compliance with SEC Regulation AB servicing criteria, with their assessments attested by registered independent public accounting firms on March 6, 2026, and February 26, 2026, respectively. There were no material instances of noncompliance identified. The filing also notes no current legal proceedings against the Issuing Entity, sponsor, servicer, or depositor that would materially adversely affect the notes' performance. However, U.S. Bank National Association, as indenture trustee, disclosed ongoing litigation related to residential mortgage-backed securities (RMBS) trusts and student loan-backed securities (DSTs), specifically the NCMSLT Action, which remains stayed as of November 7, 2018, and consolidated for pretrial purposes on January 21, 2020. These legal challenges against U.S. Bank are not directly against the Ally Auto Receivables Trust 2022-2 but highlight potential systemic risks for trustees in securitization markets.

Why It Matters

This filing provides critical transparency for investors in Ally Auto Receivables Trust 2022-2, confirming robust servicing compliance by Ally Bank and U.S. Bank Trust Company, National Association, which underpins the stability of the auto loan-backed securities. The absence of significant obligors or external credit enhancements means the trust's performance is directly tied to the underlying auto loan pool. While the trust itself is not directly implicated, the ongoing RMBS and student loan litigation against U.S. Bank National Association, the indenture trustee, could signal broader operational or reputational risks for financial institutions involved in securitization, potentially impacting investor confidence across the structured finance market. This competitive context is crucial for assessing the long-term health of similar trusts.

Risk Assessment

Risk Level: medium — The risk level is medium due to the disclosed legal proceedings against U.S. Bank National Association, the indenture trustee, in its capacity as trustee for other securitization trusts (RMBS and student loans). While these lawsuits, including the NCMSLT Action filed March 9, 2018, are not directly against Ally Auto Receivables Trust 2022-2, they represent a potential systemic risk to the trustee's operational capacity or reputation, which could indirectly affect the trust's administration or investor confidence in the broader securitization market.

Analyst Insight

Investors should maintain their position in Ally Auto Receivables Trust 2022-2 given the strong compliance reports from Ally Bank and U.S. Bank Trust Company, National Association. However, closely monitor developments in the U.S. Bank National Association's RMBS and student loan litigation, as adverse outcomes could signal broader risks for trustees in securitized products, potentially impacting future trust performance or market sentiment.

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

• 2025 — Fiscal Year End (The period covered by this 10-K filing.)
• 2026-03-27 — Filing Date (Date the 10-K was filed with the SEC.)
• 2022-10-12 — Original Indenture Date (Date of the Indenture between Ally Auto Receivables Trust 2022-2 and U.S. Bank Trust Company, National Association.)
• 2018-03-09 — NCMSLT Action Filing Date (Date the lawsuit against U.S. Bank National Association regarding student loan trusts was filed.)
• 2018-11-07 — NCMSLT Action Stay Date (Date the Delaware Court of Chancery ruled to stay the NCMSLT Action.)
• 2020-01-21 — NCMSLT Action Consolidation Date (Date the NCMSLT Action was consolidated for pretrial purposes with other lawsuits.)

Key Players & Entities

• Ally Auto Receivables Trust 2022-2 (company) — Issuing Entity
• Ally Bank (company) — Sponsor, Servicer, and Administrator
• U.S. Bank Trust Company, National Association (company) — Indenture Trustee and Servicing Participant
• U.S. Bank National Association (company) — Securities Intermediary and Indenture Trustee facing litigation
• Ally Auto Assets LLC (company) — Depositor
• 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
• Delaware Court of Chancery (regulator) — Court handling NCMSLT Action
• The National Collegiate Student Loan Master Trust I, et al. v. U.S. Bank National Association, et al. (company) — Legal proceeding against U.S. Bank National Association

FAQ

Risk Factors

• U.S. Bank National Association Litigation [medium — legal]: U.S. Bank National Association, acting as indenture trustee, is involved in ongoing litigation related to RMBS and DSTs, specifically the NCMSLT Action. This action was filed on March 9, 2018, stayed on November 7, 2018, and consolidated for pretrial purposes on January 21, 2020. While not directly against Ally Auto Receivables Trust 2022-2, it represents a systemic risk for trustees in the securitization market.

Industry Context

The auto finance industry, particularly securitization, relies heavily on the consistent performance of underlying auto loan pools. Trends include evolving consumer credit behavior, interest rate sensitivity, and increasing regulatory scrutiny on servicing and disclosure practices. The market for auto ABS remains a significant funding source for originators like Ally Bank.

Regulatory Implications

The filing underscores the importance of compliance with SEC Regulation AB servicing criteria, as evidenced by the required attestations from Ally Bank and U.S. Bank Trust Company, National Association. Any failure in these areas could lead to regulatory action and investor distrust.

What Investors Should Do

1. Monitor U.S. Bank National Association's litigation status.
2. Review the attestations of compliance with Regulation AB servicing criteria.
3. Acknowledge the lack of external credit enhancement.

Key Dates

• 2022-10-12: Original Indenture Date — Marks the establishment of the trust and the formal agreement between Ally Auto Receivables Trust 2022-2 and U.S. Bank Trust Company, National Association as Indenture Trustee.
• 2025-12-31: Fiscal Year End — The period covered by the 10-K filing, indicating the operational period for which compliance and financial information are reported.
• 2026-02-26: U.S. Bank Servicing Criteria Attestation — Independent auditors attested to U.S. Bank Trust Company, National Association's compliance with SEC Regulation AB servicing criteria for the year ended December 31, 2025.
• 2026-03-06: Ally Bank Servicing Criteria Attestation — Independent auditors attested to Ally Bank's compliance with SEC Regulation AB servicing criteria for the year ended December 31, 2025.
• 2018-03-09: NCMSLT Action Filing Date — The date a significant lawsuit concerning student loan trusts was filed against U.S. Bank National Association, a potential risk for the indenture trustee.
• 2018-11-07: NCMSLT Action Stay Date — The date the Delaware Court of Chancery ruled to stay the NCMSLT Action, pausing legal proceedings but not resolving the underlying issues.

Glossary

Issuing Entity

The legal entity that issues the securities (in this case, Ally Auto Receivables Trust 2022-2). (Refers to the specific trust whose financial condition and operations are detailed in the filing.)

Indenture Trustee

A financial institution appointed to act on behalf of the bondholders, ensuring the issuer complies with the terms of the indenture agreement. (U.S. Bank Trust Company, National Association serves this role for Ally Auto Receivables Trust 2022-2, and its own litigation is a disclosed risk.)

Servicer

The entity responsible for managing the underlying assets (auto loans in this case), including collecting payments and handling delinquencies. (Ally Bank is the servicer, and its compliance with servicing criteria is a key aspect of the trust's operational stability.)

Regulation AB

SEC rules governing the registration, reporting, and disclosure requirements for asset-backed securities. (Compliance with Regulation AB servicing criteria by Ally Bank and U.S. Bank Trust Company, National Association is a critical focus of this filing.)

Significant Obligors

The largest obligors (borrowers) whose individual balances represent a significant portion of the total pool of assets. (The absence of significant obligors indicates a diversified pool of auto loans, reducing concentration risk.)

Credit Enhancement

Mechanisms designed to reduce the credit risk of a securitization, protecting investors from losses. (The filing explicitly states there is no external credit enhancement, meaning investors rely solely on the performance of the underlying auto loans.)

Year-Over-Year Comparison

This filing pertains to Ally Auto Receivables Trust 2022-2, established in October 2022. As this is the initial 10-K filing for this specific trust, a direct comparison of key metrics like revenue growth or margin changes to a prior year's filing is not applicable. The focus is on establishing the operational framework, compliance with servicing criteria for the year ended December 31, 2025, and identifying any material risks, such as the ongoing litigation involving the indenture trustee.

Filing Documents

• aart2022-212_31x2510xk.htm (10-K) — 102KB
• aart2022-2exhibit3112025.htm (EX-31.1) — 9KB
• aart2022-2exhibit3312025.htm (EX-33.1) — 70KB
• aart2022-2exhibit3322025.htm (EX-33.2) — 53KB
• aart2022-2exhibit3412025.htm (EX-34.1) — 9KB
• aart2022-2exhibit3422025.htm (EX-34.2) — 7KB
• aart2022-2exhibit3512025.htm (EX-35.1) — 13KB
• 0001946472-26-000018.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 2022-2 (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 October 4, 2022, filed by the Issuing Entity, pursuant to Rule 424(b)(5) of the Securities Act of 1933 on October 6, 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 2022-2 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of October 12, 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 October 12, 2022. Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of October 12, 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 2022-2, as Issuing Entity, dated as of October 12, 2022. Custodian Agreement between Ally Bank, as Custodian, and Ally Auto Assets LLC, as Depositor, dated as of October 12, 2022. Administration Agre

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 2022-2 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of October 12, 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 October 12, 2022. * 4.3 Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of October 12, 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 Service

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