Mercedes-Benz Auto Trust Flags Servicing Lapses in 2025 10-K

TL;DR

Mercedes-Benz Auto Receivables Trust 2022-1's 10-K reveals minor servicing compliance issues by Mercedes-Benz Financial Services, but the trust itself remains stable with no direct legal threats.

AI Summary

The Mercedes-Benz Auto Receivables Trust 2022-1 filed its 10-K for the fiscal year ended December 31, 2025, indicating no material changes in its financial condition or operations, as many standard items were omitted per General Instruction J(1) to Form 10-K. The trust, an issuing entity for asset-backed notes, reported no unresolved staff comments, legal proceedings against the trust itself, or significant obligors. However, Mercedes-Benz Financial Services USA LLC, as Servicer, identified two material instances of noncompliance with servicing criteria under Item 1122(d)(4)(vii). One instance involved not sending a post-repossession notice within the required timeframe for a defaulted receivable not part of the Notes' assets, and another involved failing to send a pre-repossession notice for a receivable released from bankruptcy that *was* part of the Notes' assets. The Servicer plans to modify workflow processes, reporting, and provide additional training to address these compliance issues. U.S. Bank Trust Company, National Association, as Indenture Trustee, reported no material noncompliance, though it disclosed ongoing litigation related to its role as trustee for other residential mortgage-backed securities (RMBS) and student loan trusts, specifically the NCMSLT Action filed March 9, 2018.

Why It Matters

For investors in Mercedes-Benz Auto Receivables Trust 2022-1, the identified servicing noncompliance, particularly the failure to send a pre-repossession notice for a receivable backing the Notes, introduces a minor operational risk that could impact recovery rates on defaulted assets. While the Servicer, Mercedes-Benz Financial Services USA LLC, has committed to workflow modifications and training, these issues highlight potential vulnerabilities in asset management. In the competitive auto asset-backed securities market, consistent and compliant servicing is crucial for maintaining investor confidence and the perceived quality of the underlying collateral. The ongoing legal challenges faced by U.S. Bank Trust Company, National Association, as Indenture Trustee, in other capacities, while not directly impacting this trust, underscore broader systemic risks within the financial trustee landscape.

Risk Assessment

Risk Level: low — The risk level is low because the identified servicing noncompliance instances are limited to two specific receivables, one of which was not even part of the Notes' assets. The Servicer has acknowledged these issues and committed to corrective actions, indicating a proactive approach to compliance. There are no material legal proceedings directly against the Issuing Entity, Mercedes-Benz Auto Receivables Trust 2022-1, as stated in Item 1117 of Regulation AB.

Analyst Insight

Investors should monitor future compliance reports from Mercedes-Benz Financial Services USA LLC to ensure the promised workflow modifications and training effectively resolve the identified servicing issues. While the current impact is minimal, consistent non-compliance could erode the value of the underlying auto receivables. No immediate action is required beyond continued due diligence.

Financial Highlights

debt To Equity

0.0

revenue

$0

operating Margin

N/A

total Assets

$0

total Debt

$0

net Income

$0

eps

$0

gross Margin

N/A

cash Position

$0

revenue Growth

N/A

Key Numbers

• 2 — Material instances of noncompliance (Identified by the Servicer under Item 1122(d)(4)(vii))
• 1 — Receivable part of Notes' assets with noncompliance (Servicer failed to send pre-repossession notice after bankruptcy release)
• 2025-12-31 — Fiscal year end date (Reporting period for the 10-K filing)
• 2022-11-01 — Original Indenture date (Date of the Indenture between Issuing Entity and Indenture Trustee)
• 2018-03-09 — Date of NCMSLT Action filing (Lawsuit against U.S. Bank National Association as trustee for student loan trusts)

Key Players & Entities

• Mercedes-Benz Auto Receivables Trust 2022-1 (company) — Issuing Entity
• Mercedes-Benz Financial Services USA LLC (company) — Servicer and Sponsor
• U.S. Bank Trust Company, National Association (company) — Indenture Trustee
• Wilmington Trust, National Association (company) — Owner Trustee
• Mercedes-Benz Retail Receivables LLC (company) — Depositor
• Christian Rottenkolber (person) — Vice President and Chief Financial Officer of Servicer
• SEC (regulator) — Securities and Exchange Commission
• Grant Thornton LLP (company) — Independent public accounting firm for Servicer
• Ernst & Young LLP (company) — Independent public accounting firm for Indenture Trustee
• Clayton Fixed Income Services LLC (company) — Asset Representations Reviewer

FAQ

Risk Factors

• Servicer Noncompliance with Servicing Criteria [medium — operational]: The Servicer, Mercedes-Benz Financial Services USA LLC, identified two instances of noncompliance with servicing criteria under Item 1122(d)(4)(vii). One involved a failure to send a post-repossession notice within the required timeframe for a defaulted receivable not part of the Notes' assets. The second instance involved a failure to send a pre-repossession notice for a receivable released from bankruptcy that was part of the Notes' assets.
• Indenture Trustee Litigation [low — legal]: U.S. Bank Trust Company, National Association, as Indenture Trustee, disclosed ongoing litigation related to its role as trustee for other trusts, specifically the NCMSLT Action filed on March 9, 2018. While this litigation is not directly against the Mercedes-Benz Auto Receivables Trust 2022-1, it involves the Indenture Trustee's broader fiduciary responsibilities.

Industry Context

The auto finance industry is characterized by securitization as a primary funding mechanism. Trusts like Mercedes-Benz Auto Receivables Trust 2022-1 issue asset-backed securities to investors, backed by pools of auto loans. This market is sensitive to interest rate changes, economic conditions affecting consumer creditworthiness, and regulatory oversight of both originators and servicers.

Regulatory Implications

The disclosure of two instances of noncompliance with servicing criteria by the Servicer highlights the importance of robust operational controls and adherence to regulatory standards. While the Servicer is taking corrective actions, any recurrence or more significant breaches could lead to increased scrutiny from regulators and potential impacts on the trust's performance.

What Investors Should Do

1. Monitor Servicer's remediation efforts
2. Assess impact of Indenture Trustee's litigation

Key Dates

• 2025-12-31: Fiscal Year End — Marks the end of the reporting period for the 10-K filing.
• 2022-11-01: Original Indenture Date — Establishes the foundational agreement between the Issuing Entity and the Indenture Trustee for the securitization.
• 2018-03-09: NCMSLT Action Filing Date — Indicates the commencement of a significant lawsuit against the Indenture Trustee, U.S. Bank Trust Company, National Association, in its capacity as trustee for other trusts.

Glossary

Asset-Backed Notes

Securities that are collateralized by a pool of assets, such as auto loans, credit card receivables, or mortgages. (These are the primary financial instruments issued by the Trust, representing claims on the underlying auto receivables.)

Servicer

The entity responsible for managing the underlying receivables, including collecting payments, handling delinquencies, and performing other administrative tasks. (Mercedes-Benz Financial Services USA LLC acts as the Servicer, and its compliance with servicing criteria is a key focus of the filing.)

Indenture Trustee

A financial institution appointed to act on behalf of the noteholders, ensuring the terms of the indenture are met and protecting the interests of investors. (U.S. Bank Trust Company, National Association, serves this role, and its disclosures regarding litigation are relevant to investor confidence.)

Item 1122(d)(4)(vii)

A specific section of SEC regulations requiring servicers to report on their compliance with certain servicing criteria. (This is the regulatory basis for the Servicer's disclosure of noncompliance instances.)

Receivable

A right to receive payment or other property that arises from a loan or other extension of credit. (The Trust is backed by a pool of auto receivables, which are the core assets generating cash flows for the noteholders.)

Year-Over-Year Comparison

As many standard items were omitted per General Instruction J(1) to Form 10-K, a direct comparison of key financial metrics to a previous filing is not feasible. The filing indicates no material changes in financial condition or operations, suggesting stability. However, the identification of two instances of noncompliance by the Servicer represents a new development in operational risk compared to a hypothetical prior filing without such disclosures.

Filing Documents

• mbart20221_10k_32026.htm (10-K) — 87KB
• e311_mbart20221.htm (EX-31) — 8KB
• e331_mbenserv23.htm (EX-33) — 65KB
• e332_ubtcintr.htm (EX-33) — 98KB
• e341_mbenserv23.htm (EX-34) — 14KB
• e342_ubtcintr.htm (EX-34) — 9KB
• e351_mbenserv23mbart20221.htm (EX-35) — 4KB
• 0001853620-26-000088.txt ( ) — 287KB

Unresolved Staff Comments

Item 1B. Unresolved Staff Comments. Nothing to report. The following Items have been omitted in accordance with General Instruction J(1) to Form 10-K:

Risk Factors

Item 1A. Risk Factors.

Cybersecurity

Item 1C. Cybersecurity.

Legal Proceedings

Item 3. Legal Proceedings.

Mine Safety Disclosures

Item 4. Mine Safety Disclosures. PART II

Other Information

Item 9B. Other Information. Nothing to report. 1 The following Items have been omitted in accordance with General Instruction J(1) to Form 10-K:

Market for Registrant’s Common Equity, Related

Item 5. Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities .

Management’s Discussion and Analysis of Financial

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations .

Quantitative and Qualitative Disclosures About Market

Item 7A. Quantitative and Qualitative Disclosures About Market Risk .

Financial Statements and Supplementary Data

Item 8. Financial Statements and Supplementary Data .

Changes in and Disagreements with Accountants on

Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure .

Controls and Procedures

Item 9A. Controls and Procedures .

Disclosure Regarding Foreign Jurisdictions that Prevent

Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections PART III The following Items have been omitted in accordance with General Instruction J(1) to Form 10-K:

Directors, Executive Officers and Corporate Governance

Item 10. Directors, Executive Officers and Corporate Governance.

Executive Compensation

Item 11. Executive Compensation.

Security Ownership of Certain Beneficial Owners and

Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters .

Certain Relationships and Related Transactions, and

Item 13. Certain Relationships and Related Transactions, and Director Independence .

Principal Accountant Fees and Services

Item 14. Principal Accountant Fees and Services . PURSUANT TO GENERAL INSTRUCTION J(2) THE FOLLOWING SUBSTITUTE INFORMATION IS BEING PROVIDED IN THIS REPORT ON FORM 10-K:

(b) of Regulation AB. Significant Obligors

Item 1112(b) of Regulation AB. Significant Obligors of Pool Assets – Financial Information. Nothing to report.

(b)(2) of Regulation AB. Credit Enhancement

Item 1114(b)(2) of Regulation AB. Credit Enhancement and Other Support, Except for Certain Derivatives Instruments – Financial Information. Nothing to report.

(b) of Regulation AB. Certain Derivatives

Item 1115(b) of Regulation AB. Certain Derivatives Instruments – Financial Information. Nothing to report.

of Regulation AB. Legal Proceedings

Item 1117 of Regulation AB. Legal Proceedings. There are no legal proceedings pending, or any proceedings known to be contemplated by governmental authorities, against the Sponsor, the Depositor, U.S. Bank Trust Company, National Association (the “Indenture Trustee”), Wilmington Trust, National Association (the “Owner Trustee”), the Issuing Entity, or any property thereof, that are material to holders of the Asset Backed Notes issued by the Issuing Entity (the “Notes”), except to the extent set forth below with respect to the Indenture Trustee. 2 The Indenture Trustee has provided the information contained in the following five paragraphs for purposes of compliance with Regulation AB: 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 plaintiffs’ claims vigor

of Regulation AB. Affiliations and Certain

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. 3

of Regulation AB. Compliance with Applicable

Item 1122 of Regulation AB. Compliance with Applicable Servicing Criteria. Each of the Sponsor, in its capacity as Servicer, and the Indenture Trustee (together with the Sponsor in its capacity as Servicer, each, a “Servicing Participant”) has been identified by the registrant as a party participating in the servicing function during the reporting period with respect to the pool assets held by the Issuing Entity. Each Servicing Participant 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 reporting period, which Reports on Assessment are attached as Exhibits 33.1 and 33.2 to this report on Form 10-K. In addition, each Servicing Participant has provided an attestation report (each, an “Attestation Report”) by a registered independent public accounting firm on its Report on Assessment. The Attestation Reports are attached as Exhibits 34.1 and 34.2 to this report on Form 10-K. The Report on Assessment prepared by the Indenture Trustee and the Attestation Report provided by the Indenture Trustee did not identify any material instance of noncompliance with the servicing criteria applicable to the Indenture Trustee. The Report on Assessment prepared by the Servicer and the Attestation Report provided by the Servicer identified the following material instances of noncompliance with the servicing criteria applicable to the Servicer: In regard to one defaulted receivable, the Servicer did not send a post-repossession notice within the timeframe required by the applicable state resulting in a reportable finding under Item 1122(d)(4)(vii). The receivable in question was not part of the assets backing the Notes. In regard to one receivable that was involved in a bankruptcy proceeding, the Servicer did not send a pre-repossession notice after it was released from bankruptcy resulting in a reportabl

of Regulation AB. Servicing

Item 1123 of Regulation AB. Servicing Compliance Statement. The Servicer has completed a statement of compliance with its obligations under the applicable servicing agreement (a “Compliance Statement”) signed by an authorized officer of the Servicer. The Compliance Statement is attached as Exhibit 35.1 to this report on Form 10-K. PART IV Item 15. Exhibits 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 4 Exhibit Number Description 1.1 Underwriting Agreement, dated November 15, 2022, among Mercedes-Benz Retail Receivables LLC, Mercedes-Benz Financial Services USA LLC and SMBC Nikko Securities America, Inc., Credit Agricole Securities (USA) Inc. and Mizuho Securities USA LLC , as representatives of the several underwriters named therein (included in Exhibit 1.1 to the Form 8-K/A of the Issuing Entity, as filed with the SEC on November 18, 2022, which is incorporated herein by reference). 3.1 Certificate of Formation of Mercedes-Benz Retail Receivables LLC (included in Exhibit 3.1 to the Registration Statement on Form SF-3 of Mercedes-Benz Retail Receivables LLC, No. 333-266303, as filed with the SEC on July 22, 2022, which is incorporated herein by reference). 3.2 Limited Liability Company Agreement of Mercedes-Benz Retail Receivables LLC (included in Exhibit 3.2 to the Form 8-K/A of the Issuing Entity, as filed with the SEC on November 18, 2022, which is incorporated herein by reference). 4.1 Indenture, dated as of November 1, 2022, between the Issuing Entity and U.S. Bank Trust Company, National Association, as indenture trustee (included in Exhibit 4.1 to the Form 8-K of the Issuing Entity, as filed with the SEC on November 22, 2022, which is incorporated herein by reference). 4.2 Amended and Restated Trust Agreement, dated as of November 1, 2022,

Form 10–K Summary

Item 16. Form 10–K Summary Not included. 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 any security holders or is presently anticipated to be furnished to security holders subsequent to the filing of this annual report on Form 10-K. 6

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. Mercedes-Benz Auto Receivables Trust 2022-1 (Issuing Entity) By: Mercedes-Benz Financial Services USA LLC (Servicer) By: /s/ Rottenkolber Name: Christian Rottenkolber Title: Vice President and Chief Financial Officer (senior officer in charge of the servicing function for the Servicer) Dated: March 25, 2026 7 EXHIBIT INDEX Exhibit Number Description 1.1

Underwriting

Underwriting Agreement, dated November 15, 2022, among Mercedes-Benz Retail Receivables LLC, Mercedes-Benz Financial Services USA LLC and SMBC Nikko Securities America, Inc., Credit Agricole Securities (USA) Inc. and Mizuho Securities USA LLC, as representatives of the several underwriters named therein (included in Exhibit 1.1 to the Form 8-K/A of the Issuing Entity, as filed with the SEC on November 18, 2022, which is incorporated herein by reference). 3.1 Certificate of Formation of Mercedes-Benz Retail Receivables LLC (included in Exhibit 3.1 to the Registration Statement on Form SF-3 of Mercedes-Benz Retail Receivables LLC, No. 333-266303, as filed with the SEC on July 22, 2022, which is incorporated herein by reference). 3.2 Limited Liability Company Agreement of Mercedes-Benz Retail Receivables LLC (included in Exhibit 3.2 to the Form 8-K/A of the Issuing Entity, as filed with the SEC on November 18, 2022, which is incorporated herein by reference). 4.1 Indenture, dated as of November 1, 2022, between the Issuing Entity and U.S. Bank Trust Company, National Association, as indenture trustee (included in Exhibit 4.1 to the Form 8-K of the Issuing Entity, as filed with the SEC on November 22, 2022, which is incorporated herein by reference). 4.2 Amended and Restated Trust Agreement, dated as of November 1, 2022, between Mercedes-Benz Retail Receivables LLC, as Depositor, and Wilmington Trust, National Association, as owner trustee (included in Exhibit 4.2 to the Form 8-K of the Issuing Entity, as filed with the SEC on November 22, 2022, which is incorporated herein by reference). 10.1 Sale and Servicing Agreement, dated as of November 1, 2022, among the Issuing Entity, Mercedes-Benz Retail Receivables LLC, and Mercedes-Benz Financial Services USA LLC, as seller and as servicer (included in Exhibit 10.1 to the Form 8-K of the Issuing Entity, as filed with the SEC on November 22, 2022, which is incorporated herein by reference). 10.2 Recei

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