Ally Auto Trust 2024-1 Reports Clean Servicing Compliance

TL;DR

**Ally Auto Receivables Trust 2024-1 shows solid servicing compliance, but keep an eye on U.S. Bank's broader legal woes as a trustee.**

AI Summary

The Ally Auto Receivables Trust 2024-1 10-K filing for the fiscal year ended December 31, 2025, indicates no significant obligors or external credit enhancement for its pool assets, notes, or certificates. Ally Bank and U.S. Bank Trust Company, National Association, as Servicing Participants, each filed a Report 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, as the servicer, also provided a Servicer Compliance Statement for the same period. The filing notes ongoing legal proceedings against U.S. Bank National Association in its capacity as trustee for certain residential mortgage-backed securities (RMBS) trusts and student loan-backed trusts, specifically the NCMSLT Action, though U.S. Bank denies liability and is vigorously contesting these claims. The Trust itself is not a party to any material legal proceedings.

Why It Matters

This 10-K provides transparency into the operational health of the Ally Auto Receivables Trust 2024-1, a key securitization vehicle for Ally Bank's auto loan portfolio. For investors in the Trust's notes, the absence of material noncompliance in servicing criteria from Ally Bank and U.S. Bank Trust Company, National Association, offers reassurance regarding the management of underlying auto receivables. However, the ongoing legal challenges faced by U.S. Bank National Association, while not directly impacting this specific Trust's performance, highlight broader systemic risks within the trustee industry that could indirectly affect investor confidence in similar securitized products. This competitive context underscores the importance of robust compliance and legal diligence for all parties involved in asset-backed securities.

Risk Assessment

Risk Level: medium — The risk level is medium due to the ongoing legal proceedings against U.S. Bank National Association, the indenture trustee, as detailed in Item 1117. While these lawsuits, such as the NCMSLT Action, do not directly involve Ally Auto Receivables Trust 2024-1, they expose the trustee to significant litigation risk that could impact its operational capacity or reputation, potentially creating indirect risks for the Trust's noteholders.

Analyst Insight

Investors should monitor the progress of the legal proceedings against U.S. Bank National Association, particularly the NCMSLT Action, as the outcome could influence the broader securitization market and trustee services. While the Trust's servicing compliance appears strong, investors should assess the potential for indirect impacts on the indenture trustee's ability to fulfill its obligations.

Key Numbers

• 2025-12-31 — Fiscal Year End (Reporting period for the 10-K filing)
• 2026-03-27 — Filing Date (Date the 10-K was filed with the SEC)
• 333-262894-05 — Issuing Entity Commission File Number (Unique identifier for Ally Auto Receivables Trust 2024-1)
• 0002010413 — Issuing Entity CIK Number (Central Index Key for Ally Auto Receivables Trust 2024-1)
• 2018-03-09 — NCMSLT Action Filing Date (Date the lawsuit against U.S. Bank National Association was filed)

Key Players & Entities

• Ally Auto Receivables Trust 2024-1 (company) — Issuing Entity
• Ally Auto Assets LLC (company) — Depositor
• Ally Bank (company) — Sponsor, Seller, Servicer, Administrator, Custodian
• U.S. Bank National Association (company) — Indenture Trustee, Securities Intermediary, defendant in RMBS and student loan lawsuits
• U.S. Bank Trust Company, National Association (company) — Indenture Trustee, Servicing Participant
• 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
• The National Collegiate Student Loan Master Trust I, et al. v. U.S. Bank National Association, et al. (legal_case) — NCMSLT Action
• Delaware Court of Chancery (regulator) — Court hearing the NCMSLT Action

FAQ

Risk Factors

• Ongoing Legal Proceedings Against Trustee [medium — legal]: U.S. Bank National Association, in its capacity as trustee for certain RMBS and student loan-backed trusts, is involved in ongoing legal proceedings, specifically the NCMSLT Action filed on March 9, 2018. While U.S. Bank denies liability and is contesting these claims, the existence of such litigation against a key party involved in the trust's operations could introduce operational or reputational risks.

Industry Context

The auto finance industry is characterized by intense competition among lenders, with a strong reliance on securitization to fund loan portfolios. Trends include evolving consumer preferences towards electric vehicles and increasing regulatory scrutiny on lending practices and data privacy. The market is sensitive to interest rate fluctuations, which impact both borrowing costs and the residual value of vehicles.

Regulatory Implications

The filing highlights compliance with SEC Regulation AB, which mandates detailed disclosures for asset-backed securities. Ongoing legal actions against a trustee, even if not directly involving the trust, can create reputational risk and necessitate close monitoring of legal developments. Compliance with servicing criteria by Ally Bank and U.S. Bank Trust Company, National Association, is crucial for investor confidence.

What Investors Should Do

1. Monitor U.S. Bank National Association's legal proceedings.
2. Assess the credit quality of the underlying auto loan pool.
3. Review the Servicer Compliance Statements.

Key Dates

• 2025-12-31: Fiscal Year End — Marks the end of the reporting period for the 10-K filing, providing the latest financial and operational data.
• 2026-03-27: Filing Date — Indicates when the 10-K was officially submitted to the SEC, providing investors with timely information.
• 2024-03-13: Indenture and Trust Agreements Dated — Establishes the core legal framework and trustee relationships for the Ally Auto Receivables Trust 2024-1, effective from this date.
• 2018-03-09: NCMSLT Action Filing Date — The commencement date of the significant legal action against U.S. Bank National Association, a party involved in the trust's operations.

Glossary

Regulation AB

SEC regulation that governs the disclosure requirements for asset-backed securities, including information about the underlying assets, servicers, and credit enhancements. (This filing is structured around the disclosure requirements of Regulation AB, ensuring transparency for investors in asset-backed securities.)

Servicing Criteria

A set of criteria established by the SEC under Regulation AB against which the performance and compliance of the servicer of an asset-backed security must be assessed. (Reports on the assessment of compliance with these criteria by Ally Bank and U.S. Bank Trust Company, National Association, indicate the operational integrity of the trust's servicing functions.)

Significant Obligors

In the context of asset-backed securities, these are obligors whose failure to meet their obligations could have a material impact on the performance of the asset pool. (The absence of significant obligors for Ally Auto Receivables Trust 2024-1 suggests a diversified pool of underlying auto loans, reducing concentration risk.)

Credit Enhancement

Mechanisms designed to reduce the credit risk of an asset-backed security, protecting investors from losses due to defaults in the underlying assets. (The lack of external credit enhancement means that the creditworthiness of the notes and certificates relies solely on the performance of the underlying auto loan pool.)

Indenture Trustee

A trustee appointed under an indenture to represent the interests of bondholders and ensure the issuer complies with the terms of the indenture agreement. (U.S. Bank Trust Company, National Association, serves as the Indenture Trustee, a critical role in overseeing the trust's operations and protecting noteholders.)

Year-Over-Year Comparison

This filing pertains to Ally Auto Receivables Trust 2024-1, established in March 2024. As such, a direct year-over-year comparison of financial metrics like revenue growth or margin changes is not applicable for the fiscal year ended December 31, 2025, as this represents the initial reporting period for this specific trust. The key focus is on the establishment of the trust, its governing agreements, and initial compliance assessments.

Filing Documents

• aart2024-112_31x2510xk.htm (10-K) — 102KB
• aart2024-1exhibit3112025.htm (EX-31.1) — 9KB
• aart2024-1exhibit3312025.htm (EX-33.1) — 70KB
• aart2024-1exhibit3322025.htm (EX-33.2) — 53KB
• aart2024-1exhibit3412025.htm (EX-34.1) — 9KB
• aart2024-1exhibit3422025.htm (EX-34.2) — 7KB
• aart2024-1exhibit3512025.htm (EX-35.1) — 13KB
• 0002010413-26-000018.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 2024-1 (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 March 5, 2024, filed by the Issuing Entity, pursuant to Rule 424(b)(5) of the Securities Act of 1933 on March 7, 2024.

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 2024-1 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of March 13, 2024. Trust Agreement between Ally Auto Assets LLC, as Depositor and BNY Mellon Trust of Delaware, as Owner Trustee and Paying Agent, dated as of March 13, 2024. Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of March 13, 2024. 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 2024-1, as Issuing Entity, dated as of March 13, 2024. Custodian Agreement between Ally Bank, as Custodian, and Ally Auto Assets LLC, as Depositor, dated as of March 13, 2024. Administration Agreement amon

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 2024-1 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of March 13, 2024. * 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 March 13, 2024. * 4.3 Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of March 13, 2024. * 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 Comp

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