0000899140-22-000672.txt : 20220830 0000899140-22-000672.hdr.sgml : 20220830 20220830164555 ACCESSION NUMBER: 0000899140-22-000672 CONFORMED SUBMISSION TYPE: ABS-15G PUBLIC DOCUMENT COUNT: 3 CONFORMED PERIOD OF REPORT: 20220830 ITEM INFORMATION: Findings and Conclusions of the Third Party Due Diligence Provider Obtained by the Issuer FILED AS OF DATE: 20220830 DATE AS OF CHANGE: 20220830 ABS RULE: RULE-15GA2 REGISTERED ENTITY: N ABS ASSET CLASS: Credit card FILER: COMPANY DATA: COMPANY CONFORMED NAME: Continental Finance Credit Card ABS, LLC CENTRAL INDEX KEY: 0001833111 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: ABS-15G SEC ACT: Dodd Frank Act SEC FILE NUMBER: 025-05322 FILM NUMBER: 221215115 BUSINESS ADDRESS: STREET 1: 4550 NEW LINDEN HILL ROAD, SUITE 400 CITY: WILMINGTON STATE: DE ZIP: 19808 BUSINESS PHONE: 302 355 0023 MAIL ADDRESS: STREET 1: 4550 NEW LINDEN HILL ROAD, SUITE 400 CITY: WILMINGTON STATE: DE ZIP: 19808 DEPOSITOR: COMPANY DATA: COMPANY CONFORMED NAME: Continental Finance Credit Card ABS, LLC CENTRAL INDEX KEY: 0001833111 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: ABS-15G SEC ACT: Dodd Frank Act BUSINESS ADDRESS: STREET 1: 4550 NEW LINDEN HILL ROAD, SUITE 400 CITY: WILMINGTON STATE: DE ZIP: 19808 BUSINESS PHONE: 302 355 0023 MAIL ADDRESS: STREET 1: 4550 NEW LINDEN HILL ROAD, SUITE 400 CITY: WILMINGTON STATE: DE ZIP: 19808 ABS-15G 1 c56841727a.htm ABS-15G

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 150a-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) [  ]
__X_ Rule 15Ga-2 under the Exchange Act (17 CFR 240.15Ga-2)
Central Index Key Number of depositor:___0001833111________________
            CONTINENTAL FINANCE CREDIT CARD ABS MASTER TRUST                 
(Exact name of issuing entity as specified in its charter)

Central Index Key Number of issuing entity (if applicable): ____________
Central Index Key Number of underwriter (if applicable):   _____________
Lamiaa Elfar, General Counsel, (732) 957-9560
Name and telephone number, including area code, of the person to
contact in connection with this filing


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 to this Form ABS-15G is a Report of Independent Accountants on Applying Agreed-Upon Procedures, dated August 25, 2022, of Ernst & Young LLP, which sets forth the findings and conclusions, as applicable, of Ernst & Young LLP with respect to certain agreed-upon procedures performed by Ernst & Young 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: August 30, 2022
 
CONTINENTAL FINANCE CREDIT CARD ABS, LLC
     
 
By:
/s/ Stephen McSorley_____
   
Name: Stephen McSorley
   
Title: President
 


Exhibit Number
Description
   
Exhibit 99.1
Report of Independent Accountants on Applying Agreed-Upon Procedures, dated August 25, 2022, of Ernst & Young LLP.
EX-99.1 2 c56841727b.htm REPORT OF INDEPENDENT ACCOUNTANTS

Ernst & Young LLP
One Manhattan West
New York, NY 10036-6530

Tel: +1 212 773 3000
Fax: +1 212 773 6350
ey.com


Report of Independent Accountants on Applying Agreed-Upon Procedures


Continental Finance Company, LLC
Continental Finance Credit Card ABS Master Trust 4550 New Linden Hill Road, Suite 400
Wilmington, Delaware 19808
25 August 2022
 


Re:        Continental Finance Credit Card ABS Master Trust (the “Issuing Entity”)
Series 2022-A Asset-Backed Notes (the “Notes”)
Sample Receivable Agreed‑Upon Procedures

We have performed the procedures enumerated in Attachment A, which were agreed to and acknowledged as appropriate by Continental Finance Company, LLC (the “Servicer”), the Issuing Entity and Credit Suisse Securities (USA) LLC (“Credit Suisse,” together with the Servicer and Issuing Entity, the “Specified Parties”), for the intended purpose of assisting the Specified Parties in evaluating the accuracy of certain information with respect to a pool of revolving credit card accounts (the “Receivables”) relating to the Issuing Entity’s securitization transaction.  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.  The appropriateness of these procedures is solely the responsibility of the Specified Parties identified in this report.  No other party acknowledged the appropriateness of the procedures.  Consequently, we make no representation regarding the appropriateness of the procedures described in Attachment A, either for the purpose for which this report has been requested or for any other purpose.

The procedures performed and our associated findings are included in Attachment A.

For the purpose of the procedures described in this report, the Servicer, on behalf of the Issuing Entity, provided us with:

a.
An electronic data file labeled “Data_Tape_for_EY_2020_A_Jun22.txt” and the corresponding record layout and decode information, as applicable (the “Preliminary Data File”), that the Servicer, on behalf of the Issuing Entity, indicated contains information relating to a pool of revolving credit card accounts (the “Preliminary Receivables”) as of 30 June 2022 (the “Preliminary Cutoff Date”) that are expected to be representative of the Receivables,



Page 2 of 5


b.
Imaged copies of:

i.
Certain printed screen shots from the Servicer’s servicing system (the “Servicing System Screen Shots”),

ii.
The Transunion credit report (the “Transunion Credit Report”), as applicable,

iii.
The credit limit memorandum (the “Credit Limit Memo”), as applicable, and

iv.
Certain account statements, as applicable (the “Account Statements,” together with the Servicing System Screen Shots, Transunion Credit Report and Credit Limit Memo, the “Source Documents”), as applicable,
that the Servicer, on behalf of the Issuing Entity, indicated relate to each Sample Receivable (as defined in Attachment A),
c.
The list of relevant characteristics (the “Sample Characteristics”) on the Preliminary Data File, which is shown on Exhibit 1 to Attachment A, and
d.
Instructions, assumptions and methodologies, which are described in Attachment A.

For the purpose of the procedures described in this report, certain information contained on the Preliminary Data File is the “Subject Matter” as of the date of this report.

The procedures included in Attachment A were limited to comparing certain information that is further described in Attachment A.  The Issuing Entity is responsible for the Subject Matter, Preliminary Data File, Source Documents, Sample Characteristics and the determination of the instructions, assumptions and methodologies that are described herein.  We were not requested to perform, and we have not performed, any procedures other than those listed in Attachment A.  We have not verified, and we make no representation as to, the accuracy, completeness or reasonableness of the Source Documents or any other information provided to us, or that we were instructed to obtain, as applicable, by the Servicer, on behalf of the Issuing Entity, upon which we relied in forming our findings.  Accordingly, we make no representation and express no opinion or conclusion as to (a) the existence of the Preliminary Receivables or Receivables, (b) questions of legal or tax interpretation or (c) the appropriateness, accuracy, completeness or reasonableness of any instructions, assumptions and methodologies provided to us by the Servicer, on behalf of the Issuing Entity, that are described in this report.  We undertake no responsibility to update this report for events and circumstances occurring after the date hereof.

This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants (the “AICPA”).  An agreed-upon procedures engagement involves the practitioner performing specific procedures that the Specified Parties have 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, and did not, conduct an examination to express an opinion or a review to express a conclusion in accordance with attestation standards established by the AICPA on any of the items referred to herein.  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.



Page 3 of 5

The agreed-upon procedures described in this report were not performed for the purpose of:

a.
Satisfying any criteria for due diligence published by a nationally recognized statistical rating organization (a “rating agency”) or
b.
Making any findings with respect to:

i.
Whether the origination of the Receivables conformed to, or deviated from, stated underwriting or credit extension guidelines, standards, criteria, or other requirements,

ii.
The value of the collateral securing the Receivables,

iii.
Whether the originator(s) of the Receivables complied with federal, state or local laws or regulations or

iv.
Any other factor or characteristic of the Receivables 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.

We are required to be independent of the Issuing Entity 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.

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

/s/ Ernst & Young LLP

25 August 2022





Attachment A


Procedures performed and our associated findings

1.
As instructed by the Servicer, on behalf of the Issuing Entity, we randomly selected a sample of 200 Preliminary Receivables from the Preliminary Data File (the “Sample Receivables”).  For the purpose of this procedure, the Servicer, on behalf of the Issuing Entity, did not inform us as to the basis for how they determined the number of Sample Receivables or the methodology they instructed us to use to select the Sample Receivables from the Preliminary Data File.

For the purpose of the procedures described in this report, the 200 Sample Receivables are referred to as Sample Receivable Numbers 1 through 200.

2.
For each Sample Receivable, 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 the Source Document(s), subject to the instructions, assumptions and methodologies provided by the Servicer, on behalf of the Issuing Entity, described in the notes to Exhibit 1 to Attachment A.  The Source Document(s) that we were instructed by the Servicer, on behalf of the Issuing Entity, to use for each Sample Characteristic are shown on Exhibit 1 to Attachment A.  All such compared information was found to be in agreement.





Exhibit 1 to Attachment A
Page 1 of 2

Sample Characteristics and Source Documents

Sample
Characteristic 
Preliminary
Data File Field Name 
Source Document(s) 
Note(s)
       
Loan number
account
Servicing System Screen Shots
i.
       
State
State
Servicing System Screen Shots
 
       
Open date
Open_Date
Servicing System Screen Shots
 
       
APR
APR
Servicing System Screen Shots
iii.
       
Credit limit
Credit_Line
Servicing System Screen Shots or Credit Limit Memo
ii.
       
# days delinquent
Delinquency
Servicing System Screen Shots and/or Account Statements
ii., iv.
       
Credit score
Origination_Vantage3
Servicing System Screen Shots or Transunion Credit Report
ii., v.


Notes:

i.
For identification purposes only.

ii.
For the purpose of comparing the indicated Sample Characteristics for each Sample Receivable, the Servicer, on behalf of the Issuing Entity, instructed us to note agreement if the value on the Preliminary Data File agreed with the corresponding information in at least one of the Source Documents that are listed for such Sample Characteristic (and in accordance with any other applicable note(s)).  We performed no procedures to reconcile any differences that may exist relating to the information shown in the Source Documents that are listed for such Sample Characteristic.



Exhibit 1 to Attachment A
Page 2 of 2

Notes:  (continued)

iii.
For the purpose of comparing the APR Sample Characteristic for each Sample Receivable, the Servicer, on behalf of the Issuing Entity, instructed us to note agreement if the value on the Preliminary Data File agreed with:

a.
The corresponding APR value, as shown in the applicable Source Document(s), less 0.50%, if the “Closing Date,” as shown in the applicable Source Document(s), is in the month of July 2022, or

b.
The corresponding APR value, as shown in the applicable Source Document(s), less 0.75%, if the “Closing Date,” as shown in the applicable Source Document(s), is in the month of August 2022.
iv.
For the purpose of comparing the # days delinquent Sample Characteristic for each Sample Receivable, the Servicer, on behalf of the Issuing Entity, instructed us to note agreement if the # days delinquent value, as shown on the Preliminary Data File, agreed with the corresponding # days delinquent value, as shown in the applicable Source Document(s), in accordance with the decode table shown below (and in accordance with any other applicable note(s)):

Preliminary Data File Value
Source Document Value
   
0
0-29
1
30-59
2
60-89
3
90-119
4
120-149
5
150-179
6
180-209

v.
The Servicer, on behalf of the Issuing Entity, instructed us not to compare the credit score Sample Characteristic for any Sample Receivable with a credit score value of <blank>, as shown on the Preliminary Data File.

We performed no procedures to determine the accuracy, completeness or reasonableness of the instructions, assumptions and methodologies provided by the Servicer, on behalf of the Issuing Entity, described in the notes above.





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