Ally Auto Trust 2025-1 Reports Clean Servicing Compliance

TL;DR

**Ally Auto Receivables Trust 2025-1 is a low-risk, transparent auto ABS play, with solid servicing compliance despite unrelated trustee litigation.**

AI Summary

Ally Auto Receivables Trust 2025-1, an issuing entity, filed its 10-K for the fiscal year ended December 31, 2025, confirming no significant obligors or external credit enhancement for its pool assets or notes. Ally Bank and U.S. Bank Trust Company, National Association, as Servicing Participants, each reported 100% compliance with applicable servicing criteria, with no material instances of noncompliance identified in their respective Reports on Assessment and Attestation Reports for the year ended December 31, 2025. The trust also confirmed no current or threatened legal proceedings that would materially adversely affect the performance of the notes, although U.S. Bank National Association, as indenture trustee, disclosed ongoing litigation related to its role in residential mortgage-backed securities (RMBS) and student loan trusts, specifically the NCMSLT Action filed on March 9, 2018. The trust's operations are governed by agreements established on October 16, 2025, including an Indenture and a Trust Agreement.

Why It Matters

This filing provides critical transparency for investors in Ally Auto Receivables Trust 2025-1, confirming the robust compliance of its servicing entities, Ally Bank and U.S. Bank Trust Company, National Association, with SEC Regulation AB criteria for the year ended December 31, 2025. The absence of significant obligors or external credit enhancement means the performance of the notes relies solely on the underlying auto receivables, which is a key factor for risk assessment. While U.S. Bank National Association faces unrelated RMBS and student loan litigation, the filing explicitly states these do not materially impact the Ally Auto Trust 2025-1 notes, offering reassurance to bondholders and maintaining competitive stability for Ally Bank in the auto securitization market.

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 legal proceedings threatening the performance of the notes issued by Ally Auto Receivables Trust 2025-1. Both Ally Bank and U.S. Bank Trust Company, National Association, demonstrated 100% compliance with servicing criteria for the year ended December 31, 2025, as evidenced by their Attestation Reports.

Analyst Insight

Investors should view Ally Auto Receivables Trust 2025-1 as a stable investment in the auto asset-backed securities market, given the confirmed servicing compliance and lack of direct legal threats. This filing reinforces confidence in the operational integrity of the trust, making it a potentially attractive option for fixed-income portfolios seeking exposure to auto receivables with strong oversight.

Financial Highlights

debt To Equity

Not Disclosed

revenue

Not Disclosed

operating Margin

Not Disclosed

total Assets

Not Disclosed

total Debt

Not Disclosed

net Income

Not Disclosed

eps

Not Disclosed

gross Margin

Not Disclosed

cash Position

Not Disclosed

revenue Growth

Not Disclosed

Key Numbers

• 2025-1 — Trust Series (Identifies the specific securitization trust)
• December 31, 2025 — Fiscal Year End (Reporting period for the 10-K filing)
• October 16, 2025 — Key Agreement Date (Date of establishment for core trust agreements like Indenture and Trust Agreement)
• March 27, 2026 — Filing Date (Date the 10-K was officially filed)
• 333-286053-01 — Issuing Entity Commission File Number (Unique identifier for the trust with the SEC)
• 0002087070 — Issuing Entity CIK Number (Central Index Key for the trust)
• March 9, 2018 — NCMSLT Action Filing Date (Date of lawsuit against U.S. Bank National Association)

Key Players & Entities

• Ally Auto Receivables Trust 2025-1 (company) — Issuing Entity
• Ally Auto Assets LLC (company) — Depositor
• Ally Bank (company) — Sponsor, Seller, Servicer, Administrator, Custodian
• U.S. Bank Trust Company, National Association (company) — Indenture Trustee, Servicing Participant
• U.S. Bank National Association (company) — Indenture Trustee, 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
• SEC (regulator) — Regulatory body for filing
• Delaware Court of Chancery (regulator) — Court overseeing NCMSLT Action

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, specifically the NCMSLT Action filed on March 9, 2018. While this litigation is related to its role in other trusts (RMBS and student loan trusts), its potential impact on the trustee's capacity or financial stability, though not explicitly detailed for this trust, represents a potential operational risk.

Industry Context

The auto finance industry is characterized by significant competition among lenders, with a strong reliance on technology for loan origination and servicing. Securitization, as utilized by Ally Auto Receivables Trust 2025-1, is a common practice for providing liquidity and funding for auto loans. Trends include evolving consumer preferences towards electric vehicles and increasing regulatory scrutiny on lending practices.

Regulatory Implications

The trust's operations are subject to SEC regulations, particularly Regulation AB, which mandates specific disclosures regarding the underlying assets, credit enhancement, and servicer compliance. The confirmation of 100% compliance with servicing criteria by Ally Bank and U.S. Bank Trust Company, National Association, suggests adherence to these regulatory standards for the reporting period.

What Investors Should Do

1. Monitor U.S. Bank National Association's litigation.
2. Review Servicing Reports Annually.
3. Assess Pool Asset Quality.

Key Dates

• 2025-10-16: Establishment of Key Trust Agreements — Marks the effective date for the Indenture, Trust Agreement, Pooling Agreement, and Servicing Agreement, which govern the operations and structure of the Ally Auto Receivables Trust 2025-1.
• 2025-12-31: Fiscal Year End — The reporting period for which the 10-K provides financial and operational information.
• 2026-02-26: U.S. Bank Trust Company Attestation Report — The date of the registered public accounting firm's attestation report on U.S. Bank Trust Company's compliance with servicing criteria for the year ended December 31, 2025.
• 2026-03-06: Ally Bank Attestation Report — The date of the registered public accounting firm's attestation report on 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 market with the trust's year-end disclosures.
• 2018-03-09: NCMSLT Action Filing Date — The date a significant lawsuit was filed against U.S. Bank National Association, the indenture trustee, which is disclosed as ongoing litigation.

Glossary

Issuing Entity

The special purpose entity created to issue securities backed by a pool of assets. In this case, Ally Auto Receivables Trust 2025-1. (This is the core entity whose financial activities and disclosures are detailed in the 10-K.)

Regulation AB

SEC rules governing the registration, reporting, and disclosure requirements for asset-backed securities. (The filing references specific items within Regulation AB (e.g., Item 1112(b), 1114(b)(2), 1115(b)) related to significant obligors, credit enhancement, and derivatives, which are key structural components of the trust.)

Servicing Criteria

A set of criteria established by the SEC for assessing the compliance of servicers with their obligations under asset-backed securities transactions. (Both Ally Bank and U.S. Bank Trust Company, National Association, as servicing participants, reported 100% compliance with these criteria, indicating operational stability in their roles.)

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 trust, and its disclosed litigation is a relevant risk factor.)

Significant Obligors

In the context of securitization, these are the obligors whose receivables constitute a significant portion of the asset pool. Disclosure is required under Regulation AB. (The trust confirmed there are no significant obligors, simplifying the risk profile by eliminating concentration risk from a few large counterparties.)

External Credit Enhancement

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

Year-Over-Year Comparison

As this appears to be the initial 10-K filing for Ally Auto Receivables Trust 2025-1, a direct comparison of key metrics to a previous year's filing is not possible. However, the establishment of core agreements on October 16, 2025, and the reporting period ending December 31, 2025, indicate the trust is in its foundational operational phase. The confirmation of 100% compliance with servicing criteria by both Ally Bank and U.S. Bank Trust Company, National Association, sets a baseline for operational performance.

Filing Documents

• aart2025-112_31x2510xk.htm (10-K) — 117KB
• aart2025-1exhibit3112025.htm (EX-31.1) — 9KB
• aart2025-1exhibit3312025.htm (EX-33.1) — 70KB
• aart2025-1exhibit3322025.htm (EX-33.2) — 53KB
• aart2025-1exhibit3412025.htm (EX-34.1) — 9KB
• aart2025-1exhibit3422025.htm (EX-34.2) — 7KB
• aart2025-1exhibit3512025.htm (EX-35.1) — 13KB
• 0002087070-26-000018.txt ( ) — 279KB

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 2025-1 (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 October 7, 2025, filed by the Issuing Entity, pursuant to Rule 424(b)(5) of the Securities Act of 1933 on October 16, 2025.

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 202 5 - 1 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of October 16 , 202 5 . 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 16 , 202 5 . Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of October 1 6 , 202 5 . 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 202 5 - 1 , as Issuing Entity, dated as of Oc tober 16, 2025 . Custodian Agreement between Ally Bank, as Custodian, and Ally Auto Assets LLC, as Depositor, dated as of October 16 , 202 5 .

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 2025-1 and U.S. Bank Trust Company, National Association, as Indenture Trustee, dated as of October 16, 2025. * 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 16, 2025. * 4.3 Pooling Agreement between Ally Bank, as Seller, and Ally Auto Assets LLC, dated as of October 16 2025. * 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

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