Exeter Auto Trust 2021-3 Reports Stable Servicing, No Major Risks

TL;DR

**Exeter Auto Trust 2021-3 is a low-drama, compliant securitization, making it a safe, if unexciting, bet for bond investors.**

AI Summary

Exeter Automobile Receivables Trust 2021-3, a securitization entity, filed its 10-K for the fiscal year ended December 31, 2025, indicating no significant changes in its core business of holding automobile receivables. The Trust reported no single obligor represents 10% or more of its asset pool, maintaining a diversified risk profile. There was no external credit enhancement or derivative instruments provided by any entity or group of affiliated entities for the pool assets or the Notes and Certificates. Exeter Finance LLC, the sponsor and servicer, confirmed no material instances of noncompliance with servicing criteria for the 2025 reporting period, as attested by Ernst & Young LLP. Similarly, Citibank, N.A., as a servicing participant, also reported no material noncompliance, verified by KPMG LLP. The filing highlights ongoing litigation and regulatory risks for Exeter Finance LLC, including potential class action complaints and investigations by agencies like the CFPB and SEC, though none are currently deemed to materially adversely affect Note holders. The Trust's structure as a pass-through entity means it does not report traditional revenue or net income figures.

Why It Matters

This 10-K provides crucial transparency for investors in the Exeter Automobile Receivables Trust 2021-3, confirming the continued compliance of key servicers, Exeter Finance LLC and Citibank, N.A., with Regulation AB criteria for the 2025 reporting period. This stability in servicing operations is vital for the consistent performance of the asset-backed securities, reassuring investors about the management of the underlying auto loan portfolio. While Exeter Finance LLC faces ongoing litigation and regulatory scrutiny, the filing explicitly states these are not expected to materially impact the Trust's Note holders, which is a positive signal for bondholders. In a competitive subprime auto lending market, operational integrity and compliance are key differentiators, influencing investor confidence and the cost of future securitizations.

Risk Assessment

Risk Level: low — The risk level is low because the filing explicitly states that no single obligor represents 10% or more of the asset pool, diversifying credit risk. Furthermore, both Exeter Finance LLC and Citibank, N.A. reported no material instances of noncompliance with servicing criteria for the 2025 Reporting Period, as confirmed by independent public accounting firms Ernst & Young LLP and KPMG LLP, respectively, indicating strong operational controls.

Analyst Insight

Investors should maintain their positions in Exeter Automobile Receivables Trust 2021-3 notes, given the confirmed servicing compliance and diversified asset pool. Monitor Exeter Finance LLC's broader litigation and regulatory landscape, but the current filing suggests no direct material adverse impact on the Trust's securities.

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.)
• 10% — Maximum Single Obligor Concentration (No single obligor represents 10% or more of the asset pool, indicating diversification.)
• 0 — Material Noncompliance Instances (Neither Exeter Finance LLC nor Citibank, N.A. identified any material noncompliance with servicing criteria for 2025.)
• 2026-03-27 — Filing Date (Date the 10-K was filed with the SEC.)
• 2021-3 — Trust Series (Identifies the specific securitization trust.)

Key Players & Entities

• Exeter Automobile Receivables Trust 2021-3 (company) — issuing entity
• Exeter Finance LLC (company) — sponsor and servicer
• Citibank, N.A. (company) — servicing participant and indenture trustee
• EFCAR, LLC (company) — depositor and registrant
• Jason Kulas (person) — Chief Executive Officer of EFCAR, LLC
• Ernst & Young LLP (company) — independent registered public accounting firm for Exeter Finance LLC
• KPMG LLP (company) — independent registered public accounting firm for Citibank, N.A.
• Wilmington Trust Company (company) — owner trustee
• Federal Reserve (regulator) — government agency overseeing Exeter Finance LLC
• Consumer Financial Protection Bureau (regulator) — government agency overseeing Exeter Finance LLC

FAQ

Risk Factors

• Litigation and Regulatory Risks for Exeter Finance LLC [medium — legal]: The filing highlights ongoing litigation and regulatory risks for Exeter Finance LLC, including potential class action complaints and investigations by agencies like the CFPB and SEC. While these are not currently deemed to materially adversely affect Note holders, they represent a significant area of scrutiny for the sponsor and servicer.

Industry Context

The automobile finance industry, particularly within the securitization market, is characterized by the pooling and tranching of auto loan receivables. This market is sensitive to economic conditions, interest rate fluctuations, and consumer credit quality. Competition among originators and servicers like Exeter Finance LLC is driven by factors such as loan origination volume, servicing efficiency, and the ability to access capital markets for funding.

Regulatory Implications

The ongoing litigation and investigations involving Exeter Finance LLC by agencies such as the CFPB and SEC present potential regulatory risks. While currently not deemed material to noteholders, any adverse findings could lead to increased compliance costs, fines, or reputational damage, indirectly impacting the trust's operations and sponsor's stability.

What Investors Should Do

1. Monitor litigation and regulatory developments concerning Exeter Finance LLC.
2. Review the diversification of the asset pool.
3. Assess the absence of external credit enhancement and derivatives.

Key Dates

• 2021-07-31: Indenture, Trust Agreements, Sale and Servicing Agreement, and Purchase Agreements established — Marks the foundational agreements for the Exeter Automobile Receivables Trust 2021-3, outlining the structure and operational framework of the securitization.
• 2021-08-25: Form 8-K filed with incorporated agreements — Publicly disclosed key transaction documents, providing transparency to investors regarding the trust's structure and terms.
• 2021-08-30: Form SF-3 filed with Certificate of Formation and LLC Agreement of EFCAR — Provided details on the formation and governance of EFCAR, a key entity in the securitization structure.
• 2025-12-31: Fiscal Year End — The period covered by the 10-K filing, reflecting the state of the trust's assets and operations at the end of the fiscal year.
• 2026-03-27: 10-K Filing Date — The date the annual report was submitted to the SEC, providing investors with the latest financial and operational information.

Glossary

Securitization Entity

A legal entity created to pool assets, such as automobile receivables, and issue securities backed by those assets. (Exeter Automobile Receivables Trust 2021-3 is a securitization entity whose primary function is holding automobile receivables.)

Pass-through Entity

An entity that does not pay income tax itself; instead, its income or losses are passed through to its owners or beneficiaries. (The Trust is structured as a pass-through entity, meaning it does not report traditional revenue or net income figures.)

Obligor

A person or entity that owes a debt or obligation. (The filing states no single obligor represents 10% or more of the asset pool, indicating diversification of credit risk.)

Sponsor

The entity that initiates and organizes a securitization transaction, typically by originating or purchasing the assets to be securitized. (Exeter Finance LLC is the sponsor of the Trust.)

Servicer

The entity responsible for managing the pooled assets, including collecting payments, handling delinquencies, and remitting payments to investors. (Exeter Finance LLC acts as the servicer for the Trust's automobile receivables.)

Servicing Criteria

A set of standards and procedures that a servicer must adhere to in managing securitized assets, often subject to third-party attestation. (Exeter Finance LLC and Citibank, N.A. confirmed no material noncompliance with these criteria for the reporting period.)

External Credit Enhancement

Third-party guarantees or support mechanisms designed to protect investors from losses in a securitization. (The Trust's filing indicates no external credit enhancement was provided for the pool assets or the Notes and Certificates.)

Derivative Instruments

Financial contracts whose value is derived from an underlying asset, index, or rate, often used for hedging or speculation. (The Trust does not utilize derivative instruments, simplifying its risk profile.)

Year-Over-Year Comparison

As this is the first 10-K filing for the Exeter Automobile Receivables Trust 2021-3, a direct comparison to a prior year's filing is not applicable. The filing establishes the baseline operational and risk profile for the trust, highlighting its structure as a pass-through entity with no single obligor concentration above 10% and no external credit enhancement or derivatives. Key risks identified pertain to the sponsor, Exeter Finance LLC, and its ongoing litigation and regulatory scrutiny.

Filing Documents

• a10k.htm (10-K) — 66KB
• exhibit31-1.htm (EX-31.1) — 8KB
• exhibit33-1.htm (EX-33.1) — 167KB
• exhibit33-2.htm (EX-33.2) — 15KB
• exhibit34-1.htm (EX-34.1) — 11KB
• exhibit34-2.htm (EX-34.2) — 8KB
• exhibit35-1.htm (EX-35.1) — 3KB
• logo_kpmg.jpg (GRAPHIC) — 7KB
• picture1.jpg (GRAPHIC) — 4KB
• 0000929638-26-001211.txt ( ) — 295KB

(b) of Regulation AB. Significant Obligors of Pool Assets

Item 1112(b) of Regulation AB. Significant Obligors of Pool Assets. No single obligor represents 10% or more of the asset pool owned by Exeter Automobile Receivables Trust 2021-3 (the "Trust").

(b)(2) of Regulation AB. Credit Enhancement and Other Support, Except for Certain Derivatives Instruments

Item 1114(b)(2) of Regulation AB. Credit Enhancement and Other Support, Except for Certain Derivatives Instruments. No entity or group of affiliated entities provides any external credit enhancement or other support with respect to either payment on the pool assets owned by the Trust or payments on the notes (the "Notes") or the certificates (the "Certificates") issued by the Trust.

(b) of Regulation AB. Certain Derivatives Instruments

Item 1115(b) of Regulation AB. Certain Derivatives Instruments. No entity or group of affiliated entities provides any external derivative instruments to either payment on the pool assets owned by the Trust or payments on the Notes or the Certificates.

of Regulation AB. Legal Proceedings

Item 1117 of Regulation AB. Legal Proceedings. As a consumer finance company, Exeter Finance LLC ("Exeter") is subject to various consumer claims and litigation seeking damages and statutory penalties, based upon, among other things, usury, disclosure inaccuracies, wrongful repossession, violations of bankruptcy stay provisions, certificate of title disputes, fraud, breach of contract, improper collection practices, credit bureau reporting and discriminatory treatment of credit applicants. Some litigation against Exeter could take the form of class action complaints by consumers. As the assignee or purchaser of automobile loan contracts originated indirectly by dealers or originated directly by the direct lenders, in each case for sale or assignment to Exeter, Exeter also may be named as a co-defendant in lawsuits filed by consumers principally against such dealers or such direct lenders. The damages and penalties claimed by consumers in these types of matters can be substantial. The relief requested by plaintiffs varies but can include requests for compensatory, statutory and punitive damages. Exeter is also party to, or is periodically otherwise involved in, reviews, investigations, examinations and proceedings (both formal and informal), and information-gathering requests, by government and self-regulatory agencies, including the Federal Reserve, the Consumer Financial Protection Bureau, the United States Department of Justice, the U.S. Securities and Exchange Commission, the Federal Trade Commission and various state regulatory and enforcement agencies. The penalties and remedies sought by government and self-regulatory agencies in these types of matters can be substantial. Exeter believes that it has taken prudent steps to address and mitigate the litigation and regulatory risks associated with its business activities. As of the date hereof, Exeter is not subject to litigation or reviews, investigations, examinations or proceedings by government or self-regula

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.

Other Information

Item 9B. Other Information. Nothing to report.

Disclosure Regarding Foreign Jurisdictions that Prevent Inspections

Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections. Not applicable. PART III The following Items have been omitted in accordance with General Instruction J to Form 10-K: 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 Accountant Fees and Services. The following substitute information is 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.

of Regulation AB. Compliance with Applicable Servicing Criteria

Item 1122 of Regulation AB. Compliance with Applicable Servicing Criteria. Each of Exeter and Citibank, N.A. ("Citibank") (each, a "Servicing Participant") has been identified by the registrant as a party participating in the servicing function during the year ended December 31, 2025 (the "2025 Reporting Period") with respect to the pool assets owned by the Trust. 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") as of December 31, 2025, and for the 2025 Reporting Period. In addition, each of the Servicing Participants has provided an attestation report (each, an "Attestation Report") by a registered public accounting firm regarding its Report on Assessment. Each Report on Assessment and Attestation Report is attached as an exhibit to this Form 10-K. Neither the Report on Assessment nor the Attestation Report for Exeter has identified any material instance of noncompliance with the servicing criteria described in such Report on Assessment as being applicable to Exeter. Neither the Report on Assessment nor the Attestation Report for Citibank has identified any material instance of noncompliance with the servicing criteria described in such Report on Assessment as being applicable to Citibank.

of Regulation AB. Servicer Compliance Statement

Item 1123 of Regulation AB. Servicer Compliance Statement. Exeter has been identified by the registrant as a servicer during the 2025 Reporting Period with respect to the pool assets owned by the Trust. Exeter has provided a statement of compliance for the 2025 Reporting Period, signed by an authorized officer, and such compliance statement is attached as an exhibit to this Form 10-K. PART IV

Exhibit and Financial Statement Schedules

Item 15. Exhibit and Financial Statement Schedules. (a) The following documents are filed as part of this report: (1) Not applicable. (2) Not applicable. (3) See Item 15(b) below. (b) Exhibits Required by Item 601 of Regulation S-K. Exhibit Number Description 3.1 Certificate of Formation of EFCAR, LLC ("EFCAR") (included in Exhibit 3.1 to Registration Statement on Form SF-3 (333-213381), as filed by the registrant with the Commission on August 30, 2016, which is incorporated herein by reference). 3.2 Limited Liability Company Agreement of EFCAR (included in Exhibit 3.2 to Registration Statement on Form SF-3 (333-213381), as filed by the registrant with the Commission on August 30, 2016, which is incorporated herein by reference). 4.2 Indenture, dated as of July 31, 2021, among the Trust, Exeter Holdings Trust 2021-3 and Citibank, N.A., as indenture trustee (the "Indenture Trustee") (included in Exhibit 4.2 to the Trust's Form 8-K, as filed with the Commission on August 25, 2021, which is incorporated herein by reference). 4.3 Amended & Restated Trust Agreement for the Trust, dated as of July 31, 2021, between EFCAR and Wilmington Trust Company, as owner trustee (included in Exhibit 4.3 to the Trust's Form 8-K, as filed with the Commission on August 25, 2021, which is incorporated herein by reference). 4.4 Amended & Restated Trust Agreement for Exeter Holdings Trust 2021-3, dated as of July 31, 2021, between the Trust and Wilmington Trust Company, as owner trustee (included in Exhibit 4.4 to the Trust's Form 8-K, as filed with the Commission on August 25, 2021, which is incorporated herein by reference). 4.5 Sale and Servicing Agreement, dated as of July 31, 2021, among Exeter Holdings Trust 2021-3, EFCAR, Exeter, as servicer, the Trust, and Citibank, N.A., as Indenture Trustee and backup servicer (included in Exhibit 4.5 to the Trust's Form 8-K, as filed with the Commission on August 25, 2021, which is incorporated herein by r

SIGNATURES

SIGNATURES 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. EFCAR, LLC (Depositor) Date: March 27, 2026 By: /s/ Jason Kulas Jason Kulas Chief Executive Officer (Senior officer in charge of securitization of the depositor) SUPPLEMENTAL INFORMATION TO BE FURNISHED WITH REPORTS FILED PURSUANT TO SECTION 15(d) OF THE ACT BY REGISTRANTS WHICH HAVE NOT REGISTERED SECURITIES PURSUANT TO SECTION 12 OF THE ACT No annual report to security holders, proxy statement, form of proxy or other proxy soliciting material has been sent to security holders or is anticipated to be furnished to security holders subsequent to the filing of this annual report on Form 10-K.

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