EX-99.1 2 cps_ex9901.htm INDEPENDENT ACCOUNTANTS REPORT

Exhibit 99.1

 

 

KPMG LLP

Suite 700

20 Pacifica

Irvine, CA 92618-3391

 

Independent Accountants’ Agreed-Upon Procedures Report

 

Consumer Portfolio Services, Inc. (the “Company”)

Citigroup Global Markets Inc.

Capital One Securities, Inc.

(together, the “Specified Parties”)

 

Re: CPS Auto Receivables Trust 2025-B – Data File Procedures

 

We have performed the procedures described below on the specified attributes in an electronic data file entitled “bb.Pool_2025-B_033125.xlsx” provided by the Company on April 2, 2025, containing information on 20,209 automobile retail installment sale contracts (“Receivables”) as of March 31, 2025 (the “Data File”), which we were informed are intended to be included as collateral in the offering by CPS Auto Receivables Trust 2025-B. The Company is responsible for the specified attributes identified by the Company in the Data File.

 

The Specified Parties have agreed to and acknowledged that the procedures performed are appropriate to meet their intended purpose of assisting specified parties in evaluating the accuracy of the specified attributes in the Data File. This report may not be suitable for any other purpose. No other parties have agreed to or acknowledged the appropriateness of these procedures for the intended purpose or any other purpose.

 

The procedures performed may not address all the items of interest to a specified party of this report and may not meet the needs of all specified parties of this report and, as such, specified parties are responsible for determining whether the procedures performed are appropriate for their purposes. We make no representation regarding the appropriateness of the procedures either for the intended purpose or for any other purpose.

 

Unless otherwise stated, the following definitions have been adopted in presenting our procedures and findings:

 

·The term “compared” means compared to the information shown and found it to be in agreement, unless otherwise stated. Such compared information was deemed to be in agreement if differences were within the reporting threshold.
  
·The term “reporting threshold” means that dollar amounts and percentages were within $1.00 and 0.1%, respectively.
  
·The term “Instructions” means the instructions provided by the Company pertaining to a procedure, attribute, or methodology, as described in the procedures table below.
  
·The term "Vehicle Mapping" means email correspondence provided by the Company on April 5, 2025, containing the Vehicle Models and Vehicle Makes corresponding to different abbreviations of vehicle model and vehicle make appearing on the Installment Sale Contracts.
  
·The term “Acceptable Company Names” means email correspondence provided by the Company on April 5, 2025, which the Company informed us includes acceptable names for the Company that can appear in the Title Documents as the Lien Holder, Owner, Security Interest Holder, or Secured Party.

 

 

 

 1 

 

 

 

·The term “Title Document” means a scanned image of one of the title documents listed in email correspondence provided by the Company on April 5, 2025, which the Company informed us includes the acceptable forms of Title Document.
  
·The term “Insurance Document” means a scanned image of one of the insurance documents listed in email correspondence provided by the Company on April 5, 2025, which the Company informed us includes the acceptable forms of Insurance Document.
  
·The term “Receivable File” means the following documents for each Sample Receivable (defined below): Installment Sale Contract (not applicable for direct loans), Addendum to the Installment Sale Contract, Retail Installment Sale Contract Simple Interest Finance Charge letter, Federal Truth in Lending Disclosure Statement (within the Installment Sale Contract or, for a direct loan, a stand-alone document), SCRA Letter, Title Document, Insurance Document, Credit Application (not applicable for direct loans), and/or origination details screen in the Company’s servicing system. We accessed the Receivable File in the Company’s servicing system via virtual desktop. We make no representation regarding the validity, enforceability, or authenticity of the information in the Receivable File.
  
·The term “Provided Information” means the Instructions, Vehicle Mapping, Acceptable Company Names, and Receivable File.

 

The procedures we were instructed by the Company to perform and the associated findings are as follows:

 

A.We randomly selected a sample of 150 Receivables from the Data File (the “Sample Receivables”). A listing of the Sample Receivables is attached hereto as Exhibit A. For purposes of this procedure, the Company did not inform us of the basis they used to determine the number of Receivables we were instructed to randomly select from the Data File.
  
B.For each Sample Receivable, we compared the specified attributes in the Data File listed below to or using the corresponding information included in the Receivable File, utilizing the Instructions, as applicable. The Specified Parties indicated that the absence of any of the information in the Receivable File or the inability to agree the specified attributes from the Data File to the Receivable File, utilizing the Instructions, as applicable, constituted an exception. The Receivable File documents are listed in the order of priority.

 

  Attribute Receivable File / Instructions
     
  Obligor’s First Name and Last Name Installment Sale Contract, Federal Truth in Lending Disclosure Statement, Credit Application, SCRA Letter
     
  Contract Date Installment Sale Contract, Federal Truth in Lending Disclosure Statement
     
  Original Term Installment Sale Contract, Federal Truth in Lending Disclosure Statement
     
  Original Amount Financed Installment Sale Contract, Federal Truth in Lending Disclosure Statement
     
  Scheduled Monthly Payment Amount Installment Sale Contract, Federal Truth in Lending Disclosure Statement, Retail Installment Sale Contract Simple Interest Finance Charge letter
     
  Annual Percentage Rate (“APR”) Installment Sale Contract, Federal Truth in Lending Disclosure Statement, Retail Installment Sale Contract Simple Interest Finance Charge letter

 

 

 

 2 

 

 

 

  Vehicle Type (New or Used) Installment Sale Contract, Federal Truth in Lending Disclosure Statement, Gap Addendum. Consider an entry of “C” in the Data File to be a Used vehicle.
     
  Vehicle Make Installment Sale Contract, Federal Truth in Lending Disclosure Statement, Vehicle Mapping
     
  Vehicle Model Installment Sale Contract, Federal Truth in Lending Disclosure Statement, Vehicle Mapping, Insurance Document

 

We found such information to be in agreement without exception.

 

C.For each Sample Receivable, we observed the presence of the following in the Receivable File:

 

1.Title Document. We were instructed by the Company to observe that one of the Acceptable Company Names appeared on the Title Document as the Lien Holder, Owner, Security Interest Holder, or Secured Party.
   
2.Proof of Insurance. The Company instructed us to consider an Insurance Document to be acceptable proof of insurance. The Company further instructed us that no insurance document was required for Sample Receivables with the characteristics listed below because its underwriting policy does not require proof of insurance for these receivable types:

 

(i)“Stip Tier 1” (“ST01”)
   
(ii)“Stip Tier 2” (“ST02”) or “Stip Tier 3” (“ST03”) for which:

 

a.the loan application update screen in the Company's servicing system indicates that the signed contract was received prior to April 1, 2024, or
   
b.the credit report inquiry screen in the Company’s servicing system indicates the customer had an open mortgage loan and the Program in the Data File was “Pref.”

 

As such, the absence of an insurance document for Sample Receivables with these receivable types should not be considered an exception.

 

3.Signed Credit Application (not applicable to direct loans). We make no representation regarding the authenticity of the obligor’s signature(s).

 

We found such information to be present as required.

 

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, which involves us performing the specific procedures agreed to and acknowledged above and reporting on findings based on performing those procedures. We were not engaged to and did not conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on the specified attributes in the Data File. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported.

 

We are required to be independent of the Company and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement.

 

 

 

 3 

 

 

 

The procedures performed were applied based on the information included in the Data File and Provided Information, without verification or evaluation of such information by us; therefore, we express no opinion or any other form of assurance regarding (i) the reasonableness of the information provided to us by the Company, (ii) the physical existence of the Receivables, (iii) the reliability or accuracy of the Provided Information which was used in our procedures, or (iv) matters of legal interpretation.

 

The procedures performed were not intended to address, nor did they address: (i) the conformity of the origination of the Receivables to stated underwriting or credit extension guidelines, standards, criteria or other requirements, (ii) the value of collateral securing any such Receivables being securitized, (iii) the compliance of the originator of the Receivables with federal, state, and local laws and regulations, or (iv) any other factor or characteristic of the Receivables that would be material to the likelihood that the issuer of the asset-backed security will pay interest and principal in accordance with applicable terms and conditions. The procedures performed were not intended to satisfy any criteria for due diligence published by the nationally recognized statistical rating organizations (“NRSROs”).

 

The terms of our engagement are such that we have no responsibility to update this report because of events and circumstances that may subsequently occur.

 

This report is intended solely for the information and use of the Specified Parties. It is not intended to be and should not be used by any other person or entity, including investors or the NRSROs, who are not identified in the report as the Specified Parties but may have access to this report as required by law or regulation.

 

/s/ KPMG LLP

 

Irvine, California

April 8, 2025

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 4 

 

 

Exhibit A

 

The Sample Receivables

 

 

Sample Receivable #

Receivable Number1 Sample Receivable # Receivable Number1 Sample Receivable # Receivable Number1
1 2025B001 51 2025B051 101 2025B101
2 2025B002 52 2025B052 102 2025B102
3 2025B003 53 2025B053 103 2025B103
4 2025B004 54 2025B054 104 2025B104
5 2025B005 55 2025B055 105 2025B105
6 2025B006 56 2025B056 106 2025B106
7 2025B007 57 2025B057 107 2025B107
8 2025B008 58 2025B058 108 2025B108
9 2025B009 59 2025B059 109 2025B109
10 2025B010 60 2025B060 110 2025B110
11 2025B011 61 2025B061 111 2025B111
12 2025B012 62 2025B062 112 2025B112
13 2025B013 63 2025B063 113 2025B113
14 2025B014 64 2025B064 114 2025B114
15 2025B015 65 2025B065 115 2025B115
16 2025B016 66 2025B066 116 2025B116
17 2025B017 67 2025B067 117 2025B117
18 2025B018 68 2025B068 118 2025B118
19 2025B019 69 2025B069 119 2025B119
20 2025B020 70 2025B070 120 2025B120
21 2025B021 71 2025B071 121 2025B121
22 2025B022 72 2025B072 122 2025B122
23 2025B023 73 2025B073 123 2025B123
24 2025B024 74 2025B074 124 2025B124
25 2025B025 75 2025B075 125 2025B125
26 2025B026 76 2025B076 126 2025B126
27 2025B027 77 2025B077 127 2025B127
28 2025B028 78 2025B078 128 2025B128
29 2025B029 79 2025B079 129 2025B129
30 2025B030 80 2025B080 130 2025B130
31 2025B031 81 2025B081 131 2025B131
32 2025B032 82 2025B082 132 2025B132
33 2025B033 83 2025B083 133 2025B133
34 2025B034 84 2025B084 134 2025B134
35 2025B035 85 2025B085 135 2025B135
36 2025B036 86 2025B086 136 2025B136
37 2025B037 87 2025B087 137 2025B137
38 2025B038 88 2025B088 138 2025B138
39 2025B039 89 2025B089 139 2025B139
40 2025B040 90 2025B090 140 2025B140
41 2025B041 91 2025B091 141 2025B141
42 2025B042 92 2025B092 142 2025B142
43 2025B043 93 2025B093 143 2025B143
44 2025B044 94 2025B094 144 2025B144
45 2025B045 95 2025B095 145 2025B145
46 2025B046 96 2025B096 146 2025B146
47 2025B047 97 2025B097 147 2025B147
48 2025B048 98 2025B098 148 2025B148
49 2025B049 99 2025B099 149 2025B149
50 2025B050 100 2025B100 150 2025B150

 

[1] The Company has assigned a unique eight-digit account number to each Receivable in the Data File. The Receivable Numbers referred to in this Exhibit are not the Company’s account numbers.

 

 A-1