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KPMG LLP

Suite 600

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-D – Data File Procedures

 

We have performed the procedures described below on the specified attributes in an electronic data file entitled “bb.Pool_2025-D_082925_Indicative.xlsx” provided by the Company on September 5, 2025, containing information on 12,916 automobile retail installment sale contracts (“Receivables”) as of August 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-D. 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 Model Mapping" means a list mapping specific vehicle model descriptions to general vehicle model descriptions, contained in email correspondence with the Company on September 13, 2025.
  
·The term “Title Document” means one of the title documents listed in email correspondence with the Company on September 13, 2025, which the Company informed are the acceptable forms of Title Document.

 

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·The term “Acceptable Company Names” means the names listed in email correspondence with the Company on September 13, 2025, which the Company informed us are acceptable names for the Company that can appear in the Title Documents as the Lien Holder, Owner, Security Interest Holder, or Secured Party.
  
·The term “Insurance Document” means one of the insurance documents listed in email correspondence with the Company on September 13, 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), including any addendum thereto, 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), Title Document, Insurance Document, Credit Application (not applicable for direct loans), and/or the following screens in the Company’s servicing system: Analysis 1 screen, Loan Application Update screen, and/or Credit Report Inquiry screen. We accessed the Receivable File documents 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 Model 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
     
  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

 

 

 

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  Attribute Receivable File / Instructions
     
  Annual Percentage Rate (“APR”) Installment Sale Contract, Federal Truth in Lending Disclosure Statement, Retail Installment Sale Contract Simple Interest Finance Charge letter
     
  Vehicle Type (New or Used) Installment Sale Contract, Federal Truth in Lending Disclosure Statement. 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 Mapping
     
  Vehicle Model Installment Sale Contract, Federal Truth in Lending Disclosure Statement, Vehicle Model Mapping, Insurance Document

 

We found such information to be in agreement except as listed in Exhibit B.

 

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 (Type “ST01” on the Analysis 1 screen in the Company’s servicing system)
   
(ii)Stip Tier 2 (Type “ST02” on the Analysis 1 screen in the Company’s servicing system) or Stip Tier 3 (Type “ST03” on the Analysis 1 screen in the Company’s servicing system) 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 automobile or 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.

 

 

 

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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.

 

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

October 3, 2025

 

 

 

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Exhibit A

 

The Sample Receivables

 

Sample

Receivable #

Receivable

Number1

Sample

Receivable #

Receivable

Number1

Sample

Receivable #

Receivable

Number1

1

2025D001

51

2025D051

101

2025D101

2 2025D002 52 2025D052 102 2025D102
3 2025D003 53 2025D053 103 2025D103
4 2025D004 54 2025D054 104 2025D104
5 2025D005 55 2025D055 105 2025D105
6 2025D006 56 2025D056 106 2025D106
7 2025D007 57 2025D057 107 2025D107
8 2025D008 58 2025D058 108 2025D108
9 2025D009 59 2025D059 109 2025D109
10 2025D010 60 2025D060 110 2025D110
11 2025D011 61 2025D061 111 2025D111
12 2025D012 62 2025D062 112 2025D112
13 2025D013 63 2025D063 113 2025D113
14 2025D014 64 2025D064 114 2025D114
15 2025D015 65 2025D065 115 2025D115
16 2025D016 66 2025D066 116 2025D116
17 2025D017 67 2025D067 117 2025D117
18 2025D018 68 2025D068 118 2025D118
19 2025D019 69 2025D069 119 2025D119
20 2025D020 70 2025D070 120 2025D120
21 2025D021 71 2025D071 121 2025D121
22 2025D022 72 2025D072 122 2025D122
23 2025D023 73 2025D073 123 2025D123
24 2025D024 74 2025D074 124 2025D124
25 2025D025 75 2025D075 125 2025D125
26 2025D026 76 2025D076 126 2025D126
27 2025D027 77 2025D077 127 2025D127
28 2025D028 78 2025D078 128 2025D128
29 2025D029 79 2025D079 129 2025D129
30 2025D030 80 2025D080 130 2025D130
31 2025D031 81 2025D081 131 2025D131
32 2025D032 82 2025D082 132 2025D132
33 2025D033 83 2025D083 133 2025D133
34 2025D034 84 2025D084 134 2025D134
35 2025D035 85 2025D085 135 2025D135
36 2025D036 86 2025D086 136 2025D136
37 2025D037 87 2025D087 137 2025D137
38 2025D038 88 2025D088 138 2025D138
39 2025D039 89 2025D089 139 2025D139
40 2025D040 90 2025D090 140 2025D140
41 2025D041 91 2025D091 141 2025D141
42 2025D042 92 2025D092 142 2025D142
43 2025D043 93 2025D093 143 2025D143
44 2025D044 94 2025D094 144 2025D144
45 2025D045 95 2025D095 145 2025D145
46 2025D046 96 2025D096 146 2025D146
47 2025D047 97 2025D097 147 2025D147
48 2025D048 98 2025D098 148 2025D148
49 2025D049 99 2025D099 149 2025D149
50 2025D050 100 2025D100 150 2025D150

 

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 

 

 

Exhibit B

 

 

 

Exception List

 

 

Sample Receivable  Receivable Number  Attribute  Per Data File  Per Receivable File
                     
 90    2025D090  Contract Date   7/8/2025    7/10/2025 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 B-1