Form ABS-15G CREDIT ACCEPTANCE CORP For: Oct 05
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, DC 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) ☐
þ Rule 15Ga-2 under the Exchange Act (17 CFR 240.15Ga-2).
_______________________
Credit Acceptance Corporation
(Exact name of securitizer as specified in its charter)
_______________________
Central Index Key Number of depositor: _________
Central Index Key Number of issuing entity (if applicable): _________
Central Index Key Number of underwriter (if applicable): _________
Douglas Busk, Chief Treasury Officer, (248) 353-2700 (ext. 4432)
Name and telephone number, including area code,
of the person to contact in connection with this filing
_______________________
Item 2.01 Findings and Conclusions of a Third Party Due Diligence Report Obtained by the Issuer
Attached as Exhibit 99.1 hereto is a Report of Independent Certified Public Accountants, October 5, 2020, of Grant Thornton LLP, which report sets forth the findings and conclusions, as applicable, of Grant Thornton LLP with respect to certain agreed-upon procedures performed by Grant Thornton LLP.
EXHIBIT INDEX
Exhibit No. | Description | ||||
Report of Independent Certified Public Accountants, dated October 5, 2020 of Grant Thornton LLP. | |||||
SIGNATURE
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.
CREDIT ACCEPTANCE CORPORATION
as securitizer
By: | /s/ Douglas W. Busk | ||||
Name: | Douglas W. Busk | ||||
Title: | Chief Treasury Officer | ||||
Date: October 5, 2020
ITEM 4 AND ITEM 5
REPORT OF INDEPENDENT CERTIFIED PUBLIC ACCOUNTANTS
GRANT THORNTON LLP
27777 Franklin Road
Suite 800
Southfield, MI 48034-2366
D +1 248 262 1950
F +1 248 350 3581
Board of Directors and Management of
Credit Acceptance Corporation
25505 W. Twelve Mile Road
Southfield, MI 48034
Credit Suisse Securities (USA) LLC
Eleven Madison Ave.
New York, NY 10010
We have performed the procedures enumerated below, which were agreed to by the Board of Directors and Management of Credit Acceptance Corporation (the “Company”) and Credit Suisse Securities (USA) LLC (“Credit Suisse”) (collectively, the “Specified Parties”), in their evaluation of certain information with respect to attributes of the electronic file of information for the population of vehicle loans to be pooled for securitization related to the Class A, Class B, and Class C Asset-Backed Notes to be issued by the Credit Acceptance Auto Loan Trust 2020-3. The sufficiency of these procedures is solely the responsibility of the parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures enumerated below either for the purpose for which this report has been requested or for any other purpose.
The procedures we performed and our findings are as follows.
1.The Company provided an electronic file (the “Data File”) with information for certain vehicle loans, which the Company represented was as of the close of business on August 31, 2020.
2.Grant Thornton selected one hundred vehicle loans on a random basis from the Data File. The sample of loans is listed in Exhibit A. For each of the selected loans we compared the following information, designated by Credit Suisse to the related retail installment contract and in instances where consumers changed their address subsequent to the origination of their loan, we agreed the state of the consumer to other Company records.
a.Loan number
b.Original amount financed
c.First payment date (scheduled)
d.Original term to maturity
e.Monthly payment
f.Interest rate
g.State
h.Compared the Vehicle Identification Number (“VIN”) on the contract to the VIN on the title document (actual title, title application, VINtek, or acceptable proof of lien, as applicable)
GT.COM Grant Thornton LLP is the U.S. member firm of Grant Thornton International Ltd (GTIL). GTIL and each of its member firms are separate legal entities and are not a worldwide partnership.
We defined the term “compare” as meaning we compared to the information shown in the Data File and found it to be in agreement. Such information was deemed to be in agreement if differences were attributable to rounding. The term “rounding” was defined as meaning amounts and percentages that were within $1 and 0.1%, respectively. We noted no exceptions.
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 and did not conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on certain information with respect to attributes of the electronic file of information for the population of vehicle loans to be pooled for securitization related to the Class A, Class B, and Class C Asset-Backed Notes to be issued by the Credit Acceptance Auto Loan Trust 2020-3. 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 to you.
Our agreed-upon procedures engagement was not conducted for the purpose of the following:
•Addressing the conformity of the origination of the assets to stated underwriting or credit extension guidelines, standards, criteria, or other requirements
•Addressing the value of collateral securing any such assets being securitized
•Addressing the compliance of the originator of the assets with federal, state, and local laws and regulations
•Satisfying any criteria for due diligence published by a nationally recognized statistical rating organization
•Addressing any other factor or characteristic of the assets 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
•Forming any conclusion
•Any other terms or requirements of the transaction that do not appear in this report.
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 anyone other than these Specified Parties, including investors and rating agencies, who are not identified as Specified Parties but who may have access to this report as required by law or regulation.
/s/ GRANT THORNTON LLP
Southfield, Michigan
October 5, 2020
Exhibit A
| Sample | Loan Number | Sample | Loan Number | Sample | Loan Number | ||||||||||||
| 1 | XXXXX6477 | 35 | XXXXX3263 | 69 | XXXXX0280 | ||||||||||||
| 2 | XXXXX9556 | 36 | XXXXX3665 | 70 | XXXXX6568 | ||||||||||||
| 3 | XXXXX8591 | 37 | XXXXX5768 | 71 | XXXXX2363 | ||||||||||||
| 4 | XXXXX1178 | 38 | XXXXX5897 | 72 | XXXXX5465 | ||||||||||||
| 5 | XXXXX4022 | 39 | XXXXX4838 | 73 | XXXXX2309 | ||||||||||||
| 6 | XXXXX3756 | 40 | XXXXX9551 | 74 | XXXXX6856 | ||||||||||||
| 7 | XXXXX6428 | 41 | XXXXX3491 | 75 | XXXXX5329 | ||||||||||||
| 8 | XXXXX5256 | 42 | XXXXX7186 | 76 | XXXXX4227 | ||||||||||||
| 9 | XXXXX2768 | 43 | XXXXX8159 | 77 | XXXXX0555 | ||||||||||||
| 10 | XXXXX4683 | 44 | XXXXX5867 | 78 | XXXXX1815 | ||||||||||||
| 11 | XXXXX0207 | 45 | XXXXX9293 | 79 | XXXXX8704 | ||||||||||||
| 12 | XXXXX5047 | 46 | XXXXX8736 | 80 | XXXXX2297 | ||||||||||||
| 13 | XXXXX3302 | 47 | XXXXX3307 | 81 | XXXXX3814 | ||||||||||||
| 14 | XXXXX8373 | 48 | XXXXX7642 | 82 | XXXXX0517 | ||||||||||||
| 15 | XXXXX9631 | 49 | XXXXX3495 | 83 | XXXXX9845 | ||||||||||||
| 16 | XXXXX7124 | 50 | XXXXX8754 | 84 | XXXXX0391 | ||||||||||||
| 17 | XXXXX0923 | 51 | XXXXX4777 | 85 | XXXXX8435 | ||||||||||||
| 18 | XXXXX0500 | 52 | XXXXX2401 | 86 | XXXXX6509 | ||||||||||||
| 19 | XXXXX1572 | 53 | XXXXX8262 | 87 | XXXXX9442 | ||||||||||||
| 20 | XXXXX4868 | 54 | XXXXX9041 | 88 | XXXXX8531 | ||||||||||||
| 21 | XXXXX3968 | 55 | XXXXX2472 | 89 | XXXXX0361 | ||||||||||||
| 22 | XXXXX4767 | 56 | XXXXX2341 | 90 | XXXXX4442 | ||||||||||||
| 23 | XXXXX8804 | 57 | XXXXX2166 | 91 | XXXXX1094 | ||||||||||||
| 24 | XXXXX0953 | 58 | XXXXX4910 | 92 | XXXXX5990 | ||||||||||||
| 25 | XXXXX0389 | 59 | XXXXX9155 | 93 | XXXXX6709 | ||||||||||||
| 26 | XXXXX9896 | 60 | XXXXX5702 | 94 | XXXXX5537 | ||||||||||||
| 27 | XXXXX0831 | 61 | XXXXX2580 | 95 | XXXXX6766 | ||||||||||||
| 28 | XXXXX5612 | 62 | XXXXX6208 | 96 | XXXXX5966 | ||||||||||||
| 29 | XXXXX2429 | 63 | XXXXX5674 | 97 | XXXXX6752 | ||||||||||||
| 30 | XXXXX5713 | 64 | XXXXX0705 | 98 | XXXXX0172 | ||||||||||||
| 31 | XXXXX4850 | 65 | XXXXX3387 | 99 | XXXXX6788 | ||||||||||||
| 32 | XXXXX2745 | 66 | XXXXX9173 | 100 | XXXXX4689 | ||||||||||||
| 33 | XXXXX2581 | 67 | XXXXX8546 | ||||||||||||||
| 34 | XXXXX9193 | 68 | XXXXX9373 | ||||||||||||||