Deloitte & Touche LLP
Suite 400 Harborside Plaza 10 Jersey City, NJ 07311 USA
Tel:  +1 212 937 8200 Fax: +1 212 937 8298
www.deloitte.com

Freedom Consumer Credit Fund, LLC
1875 South Grant Street, Suite 450
San Mateo, California 94402

Independent Accountants’ Report

on Applying Agreed-Upon Procedures

We have performed the procedures described below, which were agreed to by Freedom Consumer Credit Fund, LLC (the “Company”) and Credit Suisse Securities (USA) LLC (the “Other Specified Party” and, together with the Company, the “Specified Parties”) related to their evaluation of certain information with respect to a portfolio of unsecured consumer loans in conjunction with the proposed offering of FREED ABS Trust 2020-1, Series 2020-1 Asset-Backed Notes.

The Company is responsible for the information provided to us, including the information set forth in the Statistical Loan File (as defined herein).  The sufficiency of these procedures is solely the responsibility of the Specified Parties of this report.  Consequently, we make no representations regarding the sufficiency 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 December 6, 2019, representatives of the Company provided us with a computer-generated data file and related record layout containing data, as represented to us by the Company, as of the close of the business November 30, 2019, with respect to 22,095 unsecured consumer loans (the “Statistical Loan File”).

At the Company’s instruction, we randomly selected 250 unsecured consumer loans from the Statistical Loan File (the “Sample Loans”) and performed certain comparisons and recomputations for each of the Sample Loans relating to the unsecured consumer loan characteristics (the “Characteristics”) set forth on the Statistical Loan File and indicated below.

Characteristics

1.Loan number (for informational purpose only) 2.Scheduled payment amount 3.Maturity date 4.Original loan amount 5.Original loan term (months) 6.Interest rate 7.Annual percentage rate (APR) 8.Funded date 9.State of residence (at approval) 10.Annual borrower income (at approval) 11.Current principal balance 12.Number of days delinquent 13.Original FICO score 14.Debt to income ratio 15.Remaining term (months) 16.Final risk group 17.NACO  

Member of

Deloitte Touche Tohmatsu Limited

We compared Characteristics 2. through 7. to the corresponding information set forth on or derived from the related Loan Agreement or Truth-In-Lending Disclosure (collectively, the “Loan Agreement”) and Characteristics 8. through 17. to an electronic loan file, prepared, created and delivered by the Company on December 16, 2019, from the servicer system, as of the close of business November 30, 2019 (the “Servicing System File”).

For purposes of our comparisons and at your instruction:

• with respect to our comparison of Characteristic 3., for Sample Loans for which the number of days between the origination date and the first payment date (each as set forth on the Loan Agreement) was greater than 30 days, differences of 31 days or less are deemed to be “in agreement;”

• with respect to our comparison of Characteristics 5. and 15., differences of one month are deemed to be “in agreement;”

• with respect to our comparison of Characteristic 7., for Sample Loans indicated as “CP” on the Statistical Loan File, differences of 1.00% or less are deemed to be “in agreement”;

• with respect to our comparison of Characteristic 10., we rounded the annual borrower income (at approval) (as set forth on the Statistical Loan File) to the nearest dollar; and

• with respect to our comparison of Characteristic 14., differences of 0.01% or less are deemed to be “in agreement.”

In addition to the procedures described above, for each of the Sample Loans, we observed that the Loan Agreement indicated that the borrower “signed electronically.”

The loan documents described above (including any information obtained from the Servicing System File) 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, except as described in Appendix A.  Supplemental information is contained on Appendix B.

******

We make no representations as to the (i) actual characteristics or existence of the underlying documents or data comprising the unsecured consumer loans 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 unsecured consumer loans 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.

This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants.  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 conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants, the objective of which would be the expression of an opinion or conclusion, respectively, on the accompanying information.  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.

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,

Deloitte & Touche LLP

January 8, 2020

Appendix A to Independent Accountants’ Report on Applying Agreed-Upon Procedures issued by Deloitte & Touche LLP dated January 8, 2020.

In applying our agreed-upon procedures as outlined above, we observed the following:

Exception Description Number	Exception Description
1	Nine differences in maturity date.
2	Eleven differences in original loan term.

The information above reflects the procedures performed and is subject to the conditions set forth in the agreed-upon procedures report to which this appendix is attached.

Appendix B to Independent Accountants’ Report on Applying Agreed-Upon Procedures issued by Deloitte & Touche LLP dated January 8, 2020.

Supplemental Information Related to the Findings Set Forth on Appendix A

Exception Description Number	Sample Loan number	Characteristic	Characteristic set forth on the Statistical Loan File	Characteristic set forth on the Loan Documents
1	324353	Maturity date	5/8/2024	7/8/2024
1	350644	Maturity date	6/21/2024	8/21/2024
1	397880	Maturity date	9/20/2024	11/20/2024
1	409628	Maturity date	9/26/2024	11/26/2024
1	411288	Maturity date	10/1/2024	12/1/2024
1	414103	Maturity date	10/5/2024	12/5/2024
1	416157	Maturity date	10/11/2024	12/11/2024
1	424501	Maturity date	11/2/2024	1/2/2025
1	432326	Maturity date	11/21/2024	1/21/2025
2	324353	Original loan term	60 months	62 months
2	350644	Original loan term	60 months	62 months
2	397880	Original loan term	60 months	62 months
2	409628	Original loan term	60 months	62 months
2	411288	Original loan term	60 months	62 months
2	414103	Original loan term	60 months	62 months
2	416157	Original loan term	60 months	62 months
2	424501	Original loan term	60 months	62 months
2	432326	Original loan term	60 months	62 months
2	438353	Original loan term	60 months	62 months
2	438429	Original loan term	60 months	62 months

The information above reflects the procedures performed and is subject to the conditions set forth in the agreed-upon procedures report to which this appendix is attached.