SEC Comment Letter 0000000000-25-006496 to CNH CAPITAL RECEIVABLES LLC (CIK 0001115252)
CNH CAPITAL RECEIVABLES LLC (CIK 0001115252)
Date: June 20, 2025 · CIK: 0001115252 · Accession: 0000000000-25-006496
AI Filing Summary & Sentiment
File numbers found in text: 333-286570
Letter
June 20, 2025 Douglas MacLeod Chairman and President CNH Capital Receivables LLC 5729 Washington Avenue Racine, Wisconsin 53406 Re:CNH Capital Receivables LLC Amendment No. 1 to Registration Statement on Form SF-3 Filed April 16, 2025 File No. 333-286570 Dear Douglas MacLeod: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our May 13, 2025 letter. Amendment No. 1 to Registration Statement on Form SF-3 Risk Factors Federal financial regulatory reform could have a significant effect on the servicer, the sponsor, the depositor or the trust, page 24 We note your revisions in response to prior comment 5 to include a description of risks presented by certain regulatory provisions, including a discussion of "ongoing rulemaking" by federal regulatory agencies to implement provisions of the Dodd- Frank Act and your statement that the "full impact of the Dodd-Frank Act...will not be known until such rulemaking has been completed and implemented." We also note, however, that, as of the adoption of Securities Act Rule 192 addressing conflicts of interest in certain securitizations, the applicable Dodd-Frank Act rules have all been adopted and implemented. Please revise your disclosure to reflect the current status of 1.
June 20, 2025 Page 2 these rules and describe the specific risks presented by them. Alternatively, please delete. Please contact Hodan Siad at 202-679-7829 or Kayla Roberts at 202-551-3490 with any questions. Sincerely, Division of Corporation Finance Office of Structured Finance
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June 20, 2025
Douglas MacLeod
Chairman and President
CNH Capital Receivables LLC
5729 Washington Avenue
Racine, Wisconsin 53406
Re:CNH Capital Receivables LLC
Amendment No. 1 to Registration Statement on Form SF-3
Filed April 16, 2025
File No. 333-286570
Dear Douglas MacLeod:
We have reviewed your amended registration statement and have the following
comment.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our May 13, 2025 letter.
Amendment No. 1 to Registration Statement on Form SF-3
Risk Factors
Federal financial regulatory reform could have a significant effect on the servicer, the
sponsor, the depositor or the trust, page 24
We note your revisions in response to prior comment 5 to include a description of
risks presented by certain regulatory provisions, including a discussion of "ongoing
rulemaking" by federal regulatory agencies to implement provisions of the Dodd-
Frank Act and your statement that the "full impact of the Dodd-Frank Act...will not be
known until such rulemaking has been completed and implemented." We also note,
however, that, as of the adoption of Securities Act Rule 192 addressing conflicts of
interest in certain securitizations, the applicable Dodd-Frank Act rules have all been
adopted and implemented. Please revise your disclosure to reflect the current status of 1.
June 20, 2025
Page 2
these rules and describe the specific risks presented by them. Alternatively, please
delete.
Please contact Hodan Siad at 202-679-7829 or Kayla Roberts at 202-551-3490 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Structured Finance