Ally Auto Trust 2024-2: Clean Bill of Health, Trustee Faces RMBS Headwinds

TL;DR

**Ally Auto Receivables Trust 2024-2 looks solid, but keep an eye on U.S. Bank's ongoing RMBS and student loan legal battles – potential ripple effects for all trustees.**

AI Summary

Ally Auto Receivables Trust 2024-2, an issuing entity, 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 against itself, its sponsor Ally Bank, or its depositor Ally Auto Assets LLC that would materially adversely affect note performance. However, U.S. Bank National Association, serving as indenture trustee, disclosed ongoing litigation related to its role as trustee for residential mortgage-backed securities (RMBS) trusts and student loan-backed securities (DSTs), including the NCMSLT Action filed on March 9, 2018. 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.

Why It Matters

This filing provides transparency into the operational health of Ally Auto Receivables Trust 2024-2, a key securitization vehicle for Ally Bank's auto loans. For investors in the trust's notes, the absence of significant obligors or external credit enhancements means performance is directly tied to the underlying auto loan pool. The disclosed litigation against U.S. Bank National Association, while not directly impacting this specific trust, highlights broader systemic risks within the securitization market and could affect the trustee's capacity or reputation, potentially influencing future trust structures or investor confidence in the competitive auto ABS market.

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. While these lawsuits (e.g., the NCMSLT Action filed March 9, 2018) are not directly against Ally Auto Receivables Trust 2024-2, they involve U.S. Bank's capacity as a trustee in other securitization structures, which could indirectly impact the trustee's operational focus or financial stability, potentially affecting its ability to fulfill its duties for this trust.

Analyst Insight

Investors should monitor the progress of the legal proceedings against U.S. Bank National Association, the indenture trustee, as adverse outcomes could impact the broader securitization market and trustee services. While Ally Auto Receivables Trust 2024-2 itself appears compliant, understanding the health of its key service providers is crucial for long-term confidence.

Key Players & Entities

• Ally Auto Receivables Trust 2024-2 (company) — Issuing Entity
• Ally Auto Assets LLC (company) — Depositor
• Ally Bank (company) — Sponsor and Servicer
• 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
• March 27, 2026 (date) — Filing date of the 10-K
• December 31, 2025 (date) — Fiscal year end
• September 27, 2024 (date) — Date of various agreements establishing the trust

FAQ

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 its role in RMBS and DST trusts. This includes the NCMSLT Action filed on March 9, 2018. While not directly against Ally Auto Receivables Trust 2024-2, the trustee's involvement in significant litigation could potentially impact its operational capacity or introduce unforeseen risks.

Industry Context

The auto finance industry is characterized by intense competition and evolving consumer preferences. Securitization remains a critical funding mechanism for auto lenders like Ally Bank, allowing them to originate more loans. However, the industry is sensitive to economic downturns, interest rate fluctuations, and regulatory changes that can impact loan performance and the cost of capital.

Regulatory Implications

The filing highlights the importance of compliance with SEC Regulation AB, particularly concerning servicing criteria. Any identified noncompliance could lead to increased regulatory scrutiny, potential penalties, and damage to investor confidence. The litigation involving the indenture trustee also presents a potential indirect regulatory risk.

What Investors Should Do

1. Monitor U.S. Bank National Association litigation
2. Review Servicer Compliance Reports
3. Assess absence of credit enhancements and significant obligors

Key Dates

• 2024-09-27: Establishment of Ally Auto Receivables Trust 2024-2 — This is the closing date for the trust, indicating the securitization transaction has been finalized and the notes and certificates have been issued.
• 2018-03-09: NCMSLT Action filed — This is a significant legal action involving the indenture trustee, U.S. Bank National Association, highlighting potential risks associated with the trustee's broader litigation history.
• 2025-12-31: Fiscal Year End — This date marks the end of the reporting period for the Servicer Compliance Statements and Reports on Assessment of Compliance with SEC Regulation AB Servicing Criteria.
• 2026-02-26: U.S. Bank Trust Company, National Association Attestation Report Issued — This report confirms compliance with servicing criteria for the year ended December 31, 2025, providing assurance on the servicing operations.
• 2026-03-06: Ally Bank Attestation Report Issued — This report confirms compliance with servicing criteria for the year ended December 31, 2025, providing assurance on Ally Bank's servicing operations.

Glossary

Issuing Entity

The special purpose entity created to issue asset-backed securities and hold the underlying assets. (Ally Auto Receivables Trust 2024-2 is the Issuing Entity in this transaction.)

Regulation AB

SEC rules governing the disclosure requirements for asset-backed securities offerings. (The filing includes assessments of compliance with Regulation AB Servicing Criteria, which are crucial for investor confidence.)

Indenture Trustee

A financial institution appointed to act on behalf of the bondholders, ensuring the terms of the indenture are met. (U.S. Bank National Association serves as the Indenture Trustee, and its litigation history is a point of note.)

Depositor

The entity that transfers the securitized assets to the issuing entity. (Ally Auto Assets LLC is the Depositor in this transaction.)

Servicer

The entity responsible for managing the underlying assets, including collecting payments and handling defaults. (Ally Bank acts as the Servicer, and its compliance with servicing criteria is assessed.)

Significant Obligors

The largest obligors whose financial condition could materially impact the pool of assets. (The absence of significant obligors simplifies the risk profile of the asset pool.)

External Credit Enhancement

Third-party guarantees or support mechanisms designed to protect investors from losses on the asset-backed securities. (The absence of external credit enhancement means the notes rely solely on the performance of the underlying auto loan pool.)

Year-Over-Year Comparison

This filing pertains to the Ally Auto Receivables Trust 2024-2, which was established on September 27, 2024. As such, there is no direct prior year filing for this specific trust to compare against. However, the reports on assessment of compliance with SEC Regulation AB Servicing Criteria for Ally Bank and U.S. Bank Trust Company, National Association cover the year ended December 31, 2025, indicating a focus on operational integrity for the period.

Filing Documents

• aart2024-212_31x2510xk.htm (10-K) — 102KB
• aart2024-2exhibit3112025.htm (EX-31.1) — 9KB
• aart2024-2exhibit3312025.htm (EX-33.1) — 70KB
• aart2024-2exhibit3322025.htm (EX-33.2) — 53KB
• aart2024-2exhibit3412025.htm (EX-34.1) — 9KB
• aart2024-2exhibit3422025.htm (EX-34.2) — 7KB
• aart2024-2exhibit3512025.htm (EX-35.1) — 13KB
• 0002035124-26-000019.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 2024-2 (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 September 24, 2024, filed by the Issuing Entity, pursuant to Rule 424(b)(5) of the Securities Act of 1933 on September 26, 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 2024-2 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of September 27, 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 September 27, 2024. Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of September 27, 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 2024-2, as Issuing Entity, dated as of September 27, 2024. Custodian Agreement between Ally Bank, as Custodian, and Ally Auto Assets LLC, as Depositor, dated as of September 27, 2024. Administr

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 2024-2 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of September 27, 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 September 27, 2024. * 4.3 Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of September 27, 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 S

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