Ally Auto Trust 2022-3 Reports Clean Servicing Compliance
| Field | Detail |
|---|---|
| Company | Ally Auto Receivables Trust 2022-3 |
| Form Type | 10-K |
| Filed Date | Mar 27, 2026 |
| Risk Level | low |
| Pages | 10 |
| Reading Time | 12 min |
| Sentiment | neutral |
Sentiment: neutral
Topics: Auto ABS, Securitization, 10-K Filing, Servicing Compliance, Asset-Backed Securities, Ally Bank, U.S. Bank
TL;DR
**Ally Auto Receivables Trust 2022-3 is a stable auto ABS play, with solid servicing compliance, but keep an eye on U.S. Bank's broader litigation.**
AI Summary
Ally Auto Receivables Trust 2022-3, an issuing entity for asset-backed securities, filed its 10-K for the fiscal year ended December 31, 2025, confirming no significant obligors or external credit enhancements for its pool assets or notes. The trust reported no current legal proceedings that would materially adversely affect the performance of its notes. Ally Bank, as servicer, and U.S. Bank Trust Company, National Association, as a servicing participant, both submitted 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. U.S. Bank National Association, as indenture trustee, disclosed ongoing litigation related to residential mortgage-backed securities (RMBS) and student loan trusts, specifically the NCMSLT Action, but denies liability and believes it has performed its obligations in good faith. The trust's structure involves Ally Auto Assets LLC as depositor and Ally Bank as sponsor, with various agreements dated December 14, 2022, governing its operations.
Why It Matters
This 10-K filing provides transparency into the operational health of Ally Auto Receivables Trust 2022-3, a key player in the auto asset-backed securities market. For investors, the absence of significant obligors or external credit enhancements means the performance of the notes is directly tied to the underlying auto loan pool. The clean servicing compliance reports from Ally Bank and U.S. Bank Trust Company, National Association, for the year ended December 31, 2025, offer reassurance regarding the management of these assets, which is crucial in a competitive auto lending environment. However, the disclosed RMBS and student loan litigation involving U.S. Bank National Association, while not directly impacting this trust, highlights potential systemic risks for financial institutions acting as trustees, which could indirectly affect market sentiment for similar securitized products.
Risk Assessment
Risk Level: low — The risk level is low because the filing explicitly states there are no significant obligors, no external credit enhancement, and no material instances of noncompliance with servicing criteria for the year ended December 31, 2025. Furthermore, there are no current legal proceedings against the Issuing Entity, sponsor, servicer, or depositor that would materially adversely affect the notes' performance.
Analyst Insight
Investors should consider this filing as a positive indicator for the stability of Ally Auto Receivables Trust 2022-3's notes, given the clean servicing reports and lack of direct material legal issues. However, they should monitor the broader litigation involving U.S. Bank National Association, as it could signal wider industry challenges for trustees, potentially affecting investor confidence in securitized products generally.
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 the 10-K filing, showing compliance with servicing criteria.)
- 0 — Significant Obligors (Indicates no single obligor or group of affiliated obligors represents a material concentration risk to the pool assets.)
- 0 — External Credit Enhancement (Signifies that the notes' performance is solely dependent on the underlying pool assets, without third-party guarantees.)
- 0 — Material Noncompliance Instances (Number of material instances of noncompliance with SEC Regulation AB servicing criteria identified for Ally Bank and U.S. Bank Trust Company, National Association for 2025.)
- 2022-3 — Trust Series (Identifies the specific series of Ally Auto Receivables Trust.)
Key Players & Entities
- Ally Auto Receivables Trust 2022-3 (company) — Issuing Entity
- Ally Auto Assets LLC (company) — Depositor
- Ally Bank (company) — Sponsor and Servicer
- U.S. Bank Trust Company, National Association (company) — Indenture Trustee and Servicing Participant
- U.S. Bank National Association (company) — Indenture Trustee and Securities Intermediary
- 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
- December 14, 2022 (date) — Date of key agreements
FAQ
What is Ally Auto Receivables Trust 2022-3?
Ally Auto Receivables Trust 2022-3 is an issuing entity that holds a pool of auto receivables and issues asset-backed securities (notes and certificates) to investors, as detailed in its 10-K filing for the fiscal year ended December 31, 2025.
Who are the key parties involved with Ally Auto Receivables Trust 2022-3?
The key parties include Ally Auto Assets LLC as the depositor, Ally Bank as the sponsor and servicer, U.S. Bank Trust Company, National Association as the indenture trustee and a servicing participant, and BNY Mellon Trust of Delaware as the owner trustee, all outlined in the 10-K filed on March 27, 2026.
Did Ally Auto Receivables Trust 2022-3 report any material servicing issues in 2025?
No, the 10-K states that both Ally Bank and U.S. Bank Trust Company, National Association, as servicing participants, submitted reports on assessment of compliance with SEC Regulation AB servicing criteria for the year ended December 31, 2025, and neither identified any material instances of noncompliance.
Are there any significant obligors in the pool assets of Ally Auto Receivables Trust 2022-3?
The 10-K filing explicitly states that there are no significant obligors with respect to the pool assets held by Ally Auto Receivables Trust 2022-3, meaning no single borrower or group poses a concentrated risk.
What is the impact of U.S. Bank's litigation disclosures on Ally Auto Receivables Trust 2022-3?
While U.S. Bank National Association, as indenture trustee, disclosed ongoing litigation related to RMBS and student loan trusts (like the NCMSLT Action), the filing clarifies that these are not expected to have a material adverse effect on the performance of the notes issued by Ally Auto Receivables Trust 2022-3.
Does Ally Auto Receivables Trust 2022-3 use external credit enhancement?
No, the 10-K filing for Ally Auto Receivables Trust 2022-3 confirms that no entity or group of affiliated entities provides any external credit enhancement or other support for the payment of pool assets or notes.
When was the 10-K for Ally Auto Receivables Trust 2022-3 filed?
The 10-K for Ally Auto Receivables Trust 2022-3 was filed on March 27, 2026, covering the fiscal year ended December 31, 2025.
What is the role of Ally Bank as the servicer for Ally Auto Receivables Trust 2022-3?
As the servicer, Ally Bank is responsible for the day-to-day management and collection of the auto receivables in the trust's pool, and it provided a statement of compliance with applicable servicing activities for the year ended December 31, 2025, as an exhibit to the 10-K.
Are there any legal proceedings directly threatening Ally Auto Receivables Trust 2022-3?
The 10-K states that there are no current legal proceedings pending, or to the best knowledge of management, threatened against the Issuing Entity, sponsor, servicer, or depositor that would be expected to have a material adverse effect on the performance of the notes.
How can investors access more information about Ally Auto Receivables Trust 2022-3's structure?
Investors can find more information about the trust's structure, including agreements like the Indenture and Trust Agreement dated December 14, 2022, by referring to the exhibits incorporated by reference in the 10-K filing, specifically to the Issuing Entity's Current Report on Form 8-K filed on December 14, 2022.
Risk Factors
- U.S. Bank National Association Litigation [medium — legal]: U.S. Bank National Association, the indenture trustee, is involved in ongoing litigation related to RMBS and student loan trusts, specifically the NCMSLT Action. While the bank denies liability and asserts good faith performance, any adverse outcome could potentially impact its operational capacity or reputation, indirectly affecting its role in managing trust assets.
- Regulation AB Servicing Compliance [low — regulatory]: Ally Bank and U.S. Bank Trust Company, National Association, as servicing participants, submitted reports on their compliance with SEC Regulation AB servicing criteria for the year ended December 31, 2025. No material instances of noncompliance were identified, indicating a strong adherence to regulatory standards for the trust's operations.
Industry Context
The auto finance industry, particularly within the securitization market, is characterized by a high volume of receivables. Competition among lenders like Ally Bank is intense, driving the need for efficient servicing and robust risk management. The market relies heavily on investor confidence in the quality of underlying auto loan pools and the integrity of the securitization structure.
Regulatory Implications
The filing underscores the importance of compliance with SEC Regulation AB, particularly concerning servicing criteria. The absence of material noncompliance instances reported by Ally Bank and U.S. Bank Trust Company, National Association, is a positive indicator for investors. However, ongoing litigation involving the indenture trustee, U.S. Bank National Association, presents a potential, albeit currently low, regulatory or operational risk.
What Investors Should Do
- Review Servicing Reports
- Monitor U.S. Bank Litigation
- Assess Pool Diversification
Key Dates
- 2022-12-14: Governing Agreements Executed — Establishes the foundational legal and operational framework for the Ally Auto Receivables Trust 2022-3, including the Indenture, Trust Agreement, Pooling Agreement, and Servicing Agreement.
- 2025-12-31: Fiscal Year End for Servicing Compliance Assessment — Marks the end of the period for which Ally Bank and U.S. Bank Trust Company, National Association, assessed their compliance with SEC Regulation AB servicing criteria.
- 2026-02-26: U.S. Bank Trust Company Attestation Report Date — The date of the registered public accounting firm's attestation report on the compliance of U.S. Bank Trust Company, National Association, with applicable servicing criteria for the year ended December 31, 2025.
- 2026-03-06: Ally Bank Attestation Report Date — The date of the registered public accounting firm's attestation report on the compliance of Ally Bank with applicable servicing criteria for the year ended December 31, 2025.
Glossary
- Issuing Entity
- The legal entity created to hold the assets (auto loan receivables) and issue securities (notes and certificates) backed by those assets. (Refers to Ally Auto Receivables Trust 2022-3, the central entity for this securitization.)
- Significant Obligors
- In the context of asset-backed securities, these are obligors whose failure to pay would have a material impact on the pool of assets. Regulation AB requires disclosure if such obligors exist. (The filing explicitly states there are no significant obligors, indicating a diversified pool of auto loans.)
- External Credit Enhancement
- Third-party guarantees or support mechanisms designed to protect investors from losses on the asset-backed securities if the underlying assets underperform. (The absence of external credit enhancement means the performance of the notes is solely dependent on the quality of the underlying auto loan receivables.)
- SEC Regulation AB
- A regulation by the U.S. Securities and Exchange Commission that governs the disclosure and reporting requirements for asset-backed securities offerings. (Key servicing criteria under this regulation were assessed by Ally Bank and U.S. Bank Trust Company, National Association, with no material noncompliance found.)
- 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 the Ally Auto Receivables Trust 2022-3.)
- Servicer
- The entity responsible for managing the underlying assets, including collecting payments from borrowers, handling delinquencies, and remitting payments to the issuing entity. (Ally Bank acts as the servicer for the auto loan receivables in this trust.)
Year-Over-Year Comparison
This analysis is based on the 10-K for the fiscal year ended December 31, 2025. As this is the initial deep structural analysis provided, a direct comparison to a prior filing cannot be made. However, the confirmation of no significant obligors, no external credit enhancement, and no material instances of noncompliance with servicing criteria are key structural points that would be compared against previous periods if available.
Filing Stats: 3,052 words · 12 min read · ~10 pages · Grade level 10.8 · Accepted 2026-03-27 09:06:25
Filing Documents
- aart2022-312_31x2510xk.htm (10-K) — 102KB
- aart2022-3exhibit3112025.htm (EX-31.1) — 9KB
- aart2022-3exhibit3312025.htm (EX-33.1) — 70KB
- aart2022-3exhibit3322025.htm (EX-33.2) — 53KB
- aart2022-3exhibit3412025.htm (EX-34.1) — 9KB
- aart2022-3exhibit3422025.htm (EX-34.2) — 7KB
- aart2022-3exhibit3512025.htm (EX-35.1) — 13KB
- 0001954336-26-000020.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 2022-3 (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 December 6, 2022, filed by the Issuing Entity, pursuant to Rule 424(b)(5) of the Securities Act of 1933 on December 8, 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 2022-3 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of December 14, 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 December 14, 2022. Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of December 14, 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 2022-3, as Issuing Entity, dated as of December 14, 2022. Custodian Agreement between Ally Bank, as Custodian, and Ally Auto Assets LLC, as Depositor, dated as of December 14, 2022. Administration
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 2022-3 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of December 14, 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 December 14, 2022. * 4.3 Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of December 14, 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 Serv