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Rule 15Ga-1 under the Exchange Act (17 CFR 240.15Ga-1) for the reporting period
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Rule 15Ga-2 under the Exchange Act (17 CFR 240.15Ga-2)
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Exhibit No.
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Description
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Exhibit 99.1
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Report of Independent Accountants on Applying Agreed-Upon Procedures, dated May 6, 2024.
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EFCAR, LLC
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(Depositor)
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By:
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/s/ Ben Miller
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Name:
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Ben Miller
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Title:
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Chief Executive Officer
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Ernst & Young LLP
One Manhattan West
New York, NY 10001
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Tel: +1 212 773 3000
Fax: +1 212 773 6350
ey.com
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EFCAR, LLC (the “Depositor”)
Exeter Finance LLC (the “Sponsor”)
2101 W. John Carpenter Freeway
Irving, Texas 75063
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6 May 2024
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Re: |
Exeter Automobile Receivables Trust 2024-3 (the “Issuing Entity”)
Automobile Receivables Backed Notes (the “Notes”) Sample Automobile Loan Contract Agreed-Upon Procedures |
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Page 2 of 4
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a. |
An electronic data file labeled “EART 2024-3 Stat Pool - EY.xlsx” and the corresponding record layout and decode information, as applicable (the “Preliminary Data File”), that the Sponsor, on behalf of the Depositor, indicated contains
information relating to certain sub‑prime automobile loan contracts secured by new and used automobiles, light duty trucks, minivans and sport utility vehicles (the “Preliminary Automobile Loan Contracts”) as of 7 April 2024
(the “Preliminary Cutoff Date”) that are expected to be representative of the Automobile Loan Contracts,
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b. |
Imaged copies of the following documents (collectively, the “Source Documents”):
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i. |
Certain printed screen shots from the Sponsor’s customer acquisition and life cycle management system (the “CALMS System Screen Shots”) and
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ii. |
Certain printed screen shots from the Sponsor’s global search imaging system (the “GS System Screen Shots”),
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c. |
An electronic data file labeled “EART 2024-3 Stat Bureau Validation.xlsx” and the corresponding record layout and decode information, as applicable (the “FICO Schedule,” together with the Source Documents, the “Sources”), that the
Sponsor, on behalf of the Depositor, indicated contains FICO score information as of the Preliminary Cutoff Date, relating to each Sample Automobile Loan Contract,
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d. |
The list of relevant characteristics (the “Sample Characteristics”) on the Preliminary Data File, which is shown on Exhibit 1 to Attachment A, and
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e. |
Instructions, assumptions and methodologies, which are described in Attachment A.
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Page 3 of 4
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a. |
Satisfying any criteria for due diligence published by a nationally recognized statistical rating organization (a “rating agency”) or
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b. |
Making any findings with respect to:
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i. |
Whether the origination of the Automobile Loan Contracts conformed to, or deviated from, stated underwriting or credit extension guidelines, standards, criteria, or other requirements,
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ii. |
The value of the collateral securing the Automobile Loan Contracts,
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iii. |
Whether the originator(s) of the Automobile Loan Contracts complied with federal, state or local laws or regulations or
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iv. |
Any other factor or characteristic of the Automobile Loan Contracts that would be material to the likelihood that the issuer of the Notes will pay interest and principal in accordance with applicable terms and conditions.
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Page 4 of 4
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Attachment A
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1. |
As instructed by the Sponsor, on behalf of the Depositor, we randomly selected a sample of 150 Preliminary Automobile Loan Contracts from the Preliminary Data File (the “Sample Automobile Loan Contracts”). For the purpose of this
procedure, the Sponsor, on behalf of the Depositor, did not inform us as to the basis for how they determined the number of Sample Automobile Loan Contracts or the methodology they instructed us to use to select the Sample Automobile Loan
Contracts from the Preliminary Data File.
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2. |
For each Sample Automobile Loan Contract, we compared the Sample Characteristics listed on Exhibit 1 to Attachment A, as shown on the Preliminary Data File, to the corresponding information located in, or to the corresponding
information we recalculated using information located in, the Sources, subject to the instructions, assumptions and methodologies provided by the Sponsor, on behalf of the Depositor, described in the notes to Exhibit 1 to Attachment A.
The Source(s) that we were instructed by the Sponsor, on behalf of the Depositor, to use for each Sample Characteristic are shown on Exhibit 1 to Attachment A. All such compared information was found to be in agreement.
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Sample Characteristic
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Preliminary
Data File Field Name
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Source(s)
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Note(s)
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Application number
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ApplicationNumber
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CALMS System Screen Shots
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i.
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Vehicle identification number (VIN)
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VIN
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CALMS System Screen Shots
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Origination date
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NoteDate
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CALMS System Screen Shots or GS System Screen Shots
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ii.
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Monthly P&I payment
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MonthlyPaymentAmount
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CALMS System Screen Shots or GS System Screen Shots
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iii., iv.
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Original amount financed
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OriginalLoanBalanceAmount
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CALMS System Screen Shots or GS System Screen Shots
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iii., v.
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Original term to maturity
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ContractTermInMonths
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CALMS System Screen Shots
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Annual percentage rate (APR)
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CurrentInterestRate
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CALMS System Screen Shots or GS System Screen Shots
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vi.
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Model type (new/used)
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VehicleNewUsedCode
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CALMS System Screen Shots
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Vehicle model year
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VehicleModelYear
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CALMS System Screen Shots
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Vehicle make
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VehicleMakeName
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CALMS System Screen Shots
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vii.
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Vehicle model (excluding trim or engine type)
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VehicleModelName
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CALMS System Screen Shots
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vii.
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Borrower state (current)
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BorrowerPrimaryStateCode
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CALMS System Screen Shots
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Sample Characteristic
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Preliminary
Data File Field Name
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Source(s)
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Note(s)
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FICO score
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FICO Score
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FICO Schedule
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Custom score
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CustomScore
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CALMS System Screen Shots
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i. |
For identification purposes only.
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ii. |
For the purpose of comparing the origination date Sample Characteristic for each Sample Automobile Loan Contract (except for Sample Automobile Loan Contract Numbers 2 and 115) the Sponsor, on behalf of the Depositor, instructed us to
use the CALMS System Screen Shots as the Source.
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iii. |
For the purpose of comparing the indicated Sample Characteristics for each Sample Automobile Loan Contract, the Sponsor, on behalf of the Depositor, instructed us to ignore differences of +/- $1.00 or less (and in accordance with any
other applicable note(s)).
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iv. |
For the purpose of comparing the monthly P&I payment Sample Characteristic for each Sample Automobile Loan Contract (except for Sample Automobile Loan Contract Numbers 2, 88 and 115), the Sponsor, on behalf of the Depositor,
instructed us to use the CALMS System Screen Shots as the Source (and in accordance with any other applicable note(s)).
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v. |
For the purpose of comparing the original amount financed Sample Characteristic for each Sample Automobile Loan Contract (except for Sample Automobile Loan Contract Number 2), the Sponsor, on behalf of the Depositor, instructed us to
use the CALMS System Screen Shots as the Source (and in accordance with any other applicable note(s)).
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vi. |
For the purpose of comparing the annual percentage rate (APR) Sample Characteristic for each Sample Automobile Loan Contract, the Sponsor, on behalf of the Depositor, instructed us to ignore differences of +/- 0.10% or less.
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vii. |
For the purpose of comparing the indicated Sample Characteristics for each Sample Automobile Loan Contract, the Sponsor, on behalf of the Depositor, instructed us to ignore differences that appear to be due to abbreviation, truncation
or spelling errors.
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