UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM ABS-15G
ASSET-BACKED SECURITIZER
REPORT PURSUANT TO SECTION 15G OF
THE SECURITIES EXCHANGE ACT OF 1934
Check the appropriate box to indicate the filing obligation to which this form is intended to satisfy:
☐ | Rule 15Ga-1 under the Exchange Act (17 CFR 240.15Ga-1) for the reporting period __ to __ |
Date of Report (Date of earliest event reported)______________________
Commission File Number of securitizer: ____________________
Central Index Key Number of securitizer: ___________________
Name and telephone number, including area code, of the person
to contact in connection with this filing
Indicate by check mark whether the securitizer has no activity to report for the initial period pursuant to Rule 15Ga-1(c)(1) ☐
Indicate by check mark whether the securitizer has no activity to report for the quarterly period pursuant to Rule 15Ga-1(c)(2)(i) ☐
Indicate by check mark whether the securitizer has no activity to report for the annual period pursuant to Rule 15Ga-1(c)(2)(ii) ☐
☒ | Rule 15Ga-2 under the Exchange Act (17 CFR 240.15Ga-2) |
Central Index Key Number of sponsor: 0001664943
College Ave Student Loans 2024-B, LLC*
(Exact name of issuing entity as specified in its charter)
Central Index Key Number of issuing entity (if applicable): Not applicable
Central Index Key Number of underwriter (if applicable): Not applicable
James W. Keller, Chief Financial Officer (302) 497-0701
Name and telephone number, including area code, of the person
to contact in connection with this filing
* | College Avenue Student Loans, LLC, as sponsor/securitizer, is filing this Form ABS-15G in respect of issuances of asset-backed securities by the above referenced issuing entity. |
INFORMATION TO BE INCLUDED IN THE REPORT
PART II: FINDINGS AND CONCLUSIONS OF THIRD-PARTY DUE DILIGENCE REPORTS
Item 2.01 Findings and Conclusions of a Third-Party Due Diligence Report Obtained by the Issuer
Attached as Exhibit 99.1 hereto is an agreed-upon procedures report, dated May 3, 2024 obtained by the Securitizer, with respect to certain agreed-upon procedures performed by Deloitte & Touche LLP.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the reporting entity has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
Date: May 10, 2024 | College Avenue Student Loans, LLC | |||||
(Securitizer) | ||||||
By: | /s/ James W. Keller | |||||
Name: | James W. Keller | |||||
Title: | Chief Financial Officer |
EXHIBIT INDEX
Exhibit No. |
Description | |
Exhibit 99.1 | Independent Accountants Report on Applying Agreed-Upon Procedures, dated May 3, 2024, of Deloitte & Touche LLP. |
Deloitte & Touche LLP | ||
Suite 301 | ||
Harborside Plaza 10 | ||
Jersey City, NJ 07311 | ||
USA | ||
Tel: +1 212 937 8200 www.deloitte.com |
College Avenue Student Loans, LLC
233 N. King Street
Wilmington, Delaware 19801
Independent Accountants Report
on Applying Agreed-Upon Procedures
We have performed the procedures described below, related to certain information with respect to a portfolio of student loan contracts in connection with the proposed offering of College Ave Student Loans 2024-B, LLC Asset-Backed Notes. College Avenue Student Loans, LLC (the Company) is responsible for the information provided to us, including the information set forth in the Statistical Loan File (as defined herein).
The Company has agreed to the procedures and acknowledged that the procedures performed are appropriate to meet the intended purpose of evaluating the accuracy of certain information set forth in the Statistical Loan File. Additionally, BofA Securities, Inc. (together with the Company, the Specified Parties) has agreed to the procedures and acknowledged that the procedures performed are appropriate for their purposes. This report may not be suitable for any other purpose. The procedures performed may not address all of the items of interest to a user of the report and may not meet the needs of all users of the report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. Consequently, we make no representations regarding the appropriateness of the procedures described below either for the purpose for which this report has been requested or for any other purpose.
Agreed-Upon Procedures
On April 16, 2024, representatives of the Company provided us with a computer-generated student loan contract data file and related record layout containing data, as represented to us by the Company, as of the close of business on March 31, 2024, with respect to 27,604 student loan contracts (the Statistical Loan File).
At the instruction of the Company, we randomly selected 150 student loan contracts from the Statistical Loan File (the Sample Loans) and performed certain comparisons and recomputations for each of the Sample Loans relating to the student loan characteristics (the Characteristics) set forth on the Statistical Loan File and indicated below.
Characteristics
1. Loan number (informational purposes only) 2. School name 3. Loan ID 4. Loan type 5. Borrower state 6. Original principal balance 7. Current interest rate 8. Current principal balance 9. First disbursement date 10. Repayment begin date 11. Loan status |
12. Last day of enrollment* 13. Deferment/forbearance end date (if applicable) 14. Grace end date 15. Days past due 16. Number of scheduled remaining payments 17. School code 18. Initial repayment schedule type option 19. Maturity Date 20. Credit score 21. School type |
* | For Sample Loans with a loan status as set forth on the Servicing System (as defined herein) of enrolled only. |
Member of
Deloitte Touche Tohmatsu Limited
We compared Characteristics 2. and 3. to the corresponding information set forth on the Promissory Note, Loan Application or Final Disclosure (collectively, the Promissory Note).
We compared Characteristics 4. through 17. to the corresponding information set forth on or derived from the Companys servicing system (the Servicing System).
Using methodologies provided to us by representatives of the Company, we compared Characteristics 18. and 19. to the corresponding information set forth on the Servicing System.
We compared Characteristic 20. to a query from the Companys origination system (the Origination System) provided to us by the Company on April 29, 2024 (the Credit Score Query).
On April 24, 2024, at the instruction of the Company, we accessed the College Navigator Website (https://nces.ed.gov/collegenavigator/) and, using the school name (as set forth on the Promissory Note), we compared Characteristic 21. to the corresponding information set forth on the College Navigator Website.
For purposes of our procedures and at your instruction:
| with respect to our comparison of Characteristic 8., differences of $1.00 or less are deemed to be in agreement; and |
| with respect to our comparison of Characteristics 9., 10., 12., 13., 14. and 19., differences of 60 days or less were deemed to be in agreement. |
The student loan documents described above, including any information obtained from the Servicing System, Origination System or College Navigator Website, and any other related documents used in support of the Characteristics were provided to us by representatives of the Company and are collectively referred to hereinafter as the Loan Documents. We were not requested to perform, and we did not perform, any procedures with respect to the preparation or verification of any of the information set forth on the Loan Documents and we make no representations concerning the accuracy or completeness of any of the information contained therein. In certain instances, our procedures were performed using data imaged facsimiles or photocopies of the Loan Documents. In addition, we make no representations as to whether the Loan Documents are comprehensive or valid instruments or reflect the current prevailing terms with respect to the corresponding Sample Loans.
Agreed-Upon Procedures Findings
The results of the foregoing procedures indicated that the Characteristics set forth on the Statistical Loan File were found to be in agreement with the above-mentioned Loan Documents.
******
We make no representations as to the (i) actual characteristics or existence of the underlying documents or data comprising the student loan contracts underlying the Statistical Loan File or the conformity of their characteristics with those assumed for purposes of the procedures described herein, (ii) existence or ownership of the student loan contracts or (iii) reasonableness of any of the aforementioned assumptions, information or methodologies.
It should be understood that we make no representations as to questions of legal interpretation or as to the sufficiency for your purposes of the procedures enumerated in the preceding paragraphs. Also, such procedures would not necessarily reveal any material misstatement of the information referred to above. We have no responsibility to update this report for events and circumstances that occur subsequent to the date of this report.
We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the American Institute of Certified Public Accountants (AICPA). An agreed-upon procedures engagement involves the practitioner performing specific procedures that the engaging party has agreed to and acknowledged to be appropriate for the purpose of the engagement and reporting on findings based on the procedures performed. We were not engaged to conduct, and did not conduct, an (i) audit conducted in accordance with generally accepted auditing standards or (ii) examination or a review engagement conducted in accordance with attestation standards established by the AICPA, the objective of which would be the expression of an opinion or conclusion, respectively, on the Statistical Loan File. Accordingly, we do not express such an opinion or conclusion, or any other form of assurance, including reasonable assurance. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.
We are required to be independent of the Company and to meet our other ethical responsibilities, as applicable for agreed-upon procedures engagements set forth in the Preface: Applicable to All Members and Part 1 Members in Public Practice of the Code of Professional Conduct established by the AICPA. Independence requirements for agreed-upon procedure engagements are less restrictive than independence requirements for audit and other attestation services.
None of the engagement, procedures or report was intended to address, nor did they address, the (i) conformity of the origination of the assets to stated underwriting or credit extension guidelines, standards, criteria or other requirements, (ii) value of collateral securing such assets or (iii) compliance of the originator of the assets with federal, state, and local laws and regulations.
None of the engagement, procedures or report were intended to satisfy, nor did they satisfy, any criteria for due diligence published by a nationally recognized statistical rating organization.
This report is intended solely for the information and use of the Specified Parties identified above and is not intended to be and should not be used by anyone other than these Specified Parties.
Yours truly,
/s/ Deloitte & Touche LLP
May 3, 2024
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