EX-99.1 2 cpsfive_abs-ex9901.htm ACCOUNTANT'S REPORT

Exhibit 99.1

   
  KPMG LLP
Suite 700
20 Pacifica
Irvine, CA 92618-3391

 

Independent Accountants’ Report on Applying Agreed-Upon Procedures

 

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

Citigroup Global Markets Inc.

Credit Suisse Securities (USA) LLC

(together, the “Specified Parties”)

 

Re: CPS Auto Receivables Trust 2021-B – Data File Procedures

 

We have performed the procedures described below, which were agreed to by the Specified Parties, on the specified attributes identified by the Company in an electronic data file entitled “bb.Pool_2021-B_022821_Indicative,” provided by the Company on March 12, 2021, containing information related to 5,161 automobile retail installment sale contracts (“Receivables”) as of February 28, 2021 (the “Data File”), which we were informed are intended to be included as collateral in the offering by CPS Auto Receivables Trust 2021-B. The Company is responsible for the specified attributes identified by the Company in the Data File. The sufficiency of these procedures is solely the responsibility of the Specified Parties. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested 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 materiality threshold.

 

·The term “materiality threshold” means that dollar amounts and percentages were within $1.00 and 0.1%, respectively.

 

·The term “Title Document” means a scanned image of the Certificate of Title, Application for Title, Application for Certificate of Ownership, Dealer Guarantee of Title Delivery, CPS Guarantee of Title, Application for Registration, Application for Dealer Assignment, Lien Entry Form, or Electronic Title in the CPS Title Management System.

 

·The term “Insurance Document” means a scanned image of the Insurance Card, Agreement to Provide Insurance, Insurance Binder, Insurance Declaration Page, Proof of Insurance/Authorization to Release Insurance Information, Confirmation of Accidental Physical Damage Insurance, Insurance Verification Form, or Insurance Verification system screen shot.

 

·The term “Receivable File” means any file containing some or all of the following documents for each Sample Receivable (defined below): Installment Sale Contract (which includes any related Addendum to the Installment Sale Contract and/or Retail Installment Sale Contract Simple Interest Finance Charge letter) (not applicable for direct loans), Federal Truth in Lending Disclosure Statement (within Installment Sale Contract or as a stand-alone document for direct loans), Title Document, Insurance Document, and Credit Application (not applicable for direct loans). The Receivable File, provided to us by the Company, was represented to be a scanned image of the original Receivable File. We make no representation regarding the validity, enforceability, or authenticity of the information in the Receivable File.

 

We were instructed by the Company to perform the following agreed-upon procedures on the Receivables in the Data File.

 

A.The Company instructed us to select a random 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 as to the basis for how they determined the number of Receivables we were instructed to randomly select from the Data File.

 

 

 

   

 

 

 

 

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B.For each Sample Receivable, we compared the Attribute, listed below, to the corresponding information appearing in the Receivable File, listed below, utilizing instructions provided by the Company (as applicable). The Specified Parties indicated that the absence of any of the Receivable File information or the inability to agree the indicated information from the Data File to the Receivable File for each of the Attributes constituted an exception. Where more than one document was indicated for an Attribute, we used the highest priority document found in the Receivable File (i.e., in the order listed in the table below).

 

Attribute Receivable File / Company’s Instructions
Obligor’s First Name and Last Name Installment Sale Contract, Federal Truth in Lending Disclosure Statement, Credit Application
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
Annual Percentage Rate (“APR”) Installment Sale Contract, Federal Truth in Lending Disclosure Statement
Vehicle Type (New or Used) Installment Sale Contract, Federal Truth in Lending Disclosure Statement. For purposes of this attribute, the Company instructed to 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 Model Installment Sale Contract, Federal Truth in Lending Disclosure Statement

 

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 the Company’s name appeared on the Title Document as the Lien Holder, Owner, Security Interest Holder, or Secured Party. The Company informed us that “CPS, Inc.,” “CPS,” “CPS Incorporated,” “Consumer Portfolio Services,” “Consumer Portfolio Services In,” “Consumer Portfolio Services, Inc.,” “Consumer Portfolio Svcs,” “Consumer Portfolio Svcs., Inc.,” “Consumer Portfolio Serv,” “Consumer Portfolio Servic,” “Consumer Portfolio Srvs,” “Consumer Portfolio S,” and “C.P.S. Inc.” were acceptable names for the Company.

 

2.Proof of Insurance. The Company informed us that a copy of the Insurance Document was acceptable proof of insurance.

 

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

 

There were no conclusions that resulted from the procedures.

 

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 the specified attributes identified by the Company 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 to the Specified Parties.

 

 

 

   

 

 

 

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The procedures performed were applied based on the information included in the Data File, the Receivable Files, and instructions provided by the Company, without verification or evaluation of such information and instructions by us; therefore, we express no opinion or any other form of assurance regarding (i) the physical existence of the Receivables, (ii) the reasonableness of the information and instructions provided by the Company, (iii) the reliability or accuracy of the Receivable Files which were 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 a nationally recognized statistical rating organization (“NRSRO”).

 

The terms of our engagement are such that we have no obligation to update this report because of events and transactions 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 and NRSROs, 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/KPMG LLP

 

Irvine, CA
April 2, 2021

 

 

 

 

 

   

 

 

Exhibit A

 

The Sample Receivables
Sample
Receivable #
Receivable
Number1
Sample
Receivable #
Receivable
Number
1
Sample
Receivable #
Receivable
Number
1
1 2021B001 51 2021B051 101 2021B101
2 2021B002 52 2021B052 102 2021B102
3 2021B003 53 2021B053 103 2021B103
4 2021B004 54 2021B054 104 2021B104
5 2021B005 55 2021B055 105 2021B105
6 2021B006 56 2021B056 106 2021B106
7 2021B007 57 2021B057 107 2021B107
8 2021B008 58 2021B058 108 2021B108
9 2021B009 59 2021B059 109 2021B109
10 2021B010 60 2021B060 110 2021B110
11 2021B011 61 2021B061 111 2021B111
12 2021B012 62 2021B062 112 2021B112
13 2021B013 63 2021B063 113 2021B113
14 2021B014 64 2021B064 114 2021B114
15 2021B015 65 2021B065 115 2021B115
16 2021B016 66 2021B066 116 2021B116
17 2021B017 67 2021B067 117 2021B117
18 2021B018 68 2021B068 118 2021B118
19 2021B019 69 2021B069 119 2021B119
20 2021B020 70 2021B070 120 2021B120
21 2021B021 71 2021B071 121 2021B121
22 2021B022 72 2021B072 122 2021B122
23 2021B023 73 2021B073 123 2021B123
24 2021B024 74 2021B074 124 2021B124
25 2021B025 75 2021B075 125 2021B125
26 2021B026 76 2021B076 126 2021B126
27 2021B027 77 2021B077 127 2021B127
28 2021B028 78 2021B078 128 2021B128
29 2021B029 79 2021B079 129 2021B129
30 2021B030 80 2021B080 130 2021B130
31 2021B031 81 2021B081 131 2021B131
32 2021B032 82 2021B082 132 2021B132
33 2021B033 83 2021B083 133 2021B133
34 2021B034 84 2021B084 134 2021B134
35 2021B035 85 2021B085 135 2021B135
36 2021B036 86 2021B086 136 2021B136
37 2021B037 87 2021B087 137 2021B137
38 2021B038 88 2021B088 138 2021B138
39 2021B039 89 2021B089 139 2021B139
40 2021B040 90 2021B090 140 2021B140
41 2021B041 91 2021B091 141 2021B141
42 2021B042 92 2021B092 142 2021B142
43 2021B043 93 2021B093 143 2021B143
44 2021B044 94 2021B094 144 2021B144
45 2021B045 95 2021B095 145 2021B145
46 2021B046 96 2021B096 146 2021B146
47 2021B047 97 2021B097 147 2021B147
48 2021B048 98 2021B098 148 2021B148
49 2021B049 99 2021B099 149 2021B149
50 2021B050 100 2021B100 150 2021B150

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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.