SecProbe.io

April 3, 2025
Mike McKeever
President and Chief Executive Office
Carvana Receivables Depositor LLC
300 E. Rio Salado Parkway, Bldg. 1
Tempe, AZ 85281
Re:Carvana Receivables Depositor LLC
Registration Statement on Form SF-3
Filed March 5, 2025
File No. 333-285582
Dear Mike McKeever:
            We have reviewed your registration statement and have the following comments.
            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.
Registration Statement on Form SF-3
General
1.Please confirm that the depositor or any issuing entity previously established, directly
or indirectly, by the depositor or any affiliate of the depositor has been current and
timely with Exchange Act reporting during the last twelve months with respect to
asset-backed securities involving the same asset class. Please refer to General
Instruction I.A.2. of Form SF-3.
Prospectus Summary
Pre-Funding Account, page 5
Please revise your prospectus summary to include a discussion of the selection criteria
or other requirements for any assets that may be added to the pool, consistent with the
disclosure located under the heading "The Receivables-[Criteria Applicable to the
Selection of Additional Receivables During the Funding Period] on page 58. Refer to 2.

April 3, 2025
Page 2
Item 1103(a)(5)(vi) of Regulation AB.
Risk Factors
[The characteristics of the Receivables in the Final Pool may differ from the characteristics of
the Receivables in the Initial Pool, page 26
3.We note your statement that "[t]here can be no assurance that the characteristics of the
Final Pool will not materially differ from the characteristics of the Initial Pool..." This
statement appears to be inconsistent with the statements on page 57 that the
Receivables purchased during the Funding Period "must meet substantially similar
criteria" and the statement on page 101 that the "underwriting criteria for additional
Receivables will be substantially the same in all material respects as those for the
initial Receivables." Please revise to reconcile these statements.
Adverse events with respect to Carvana, the Servicer, any of their respective affiliates or
other transaction parties could affect..., page 29
4.We note your disclosure sets forth an example that "many companies have seen an
increase in the number and range of cyber-attacks, which, if successful, could give
rise to the loss of significant amounts of sensitive information and the disablement of
the information technology systems used to service obligors on the Receivables and
other customers." Please revise to explain the relevancy of these attacks or provide
further detail.
Servicing Procedures, page 47
5.We note the Servicer recently modified its written servicing policy and procedures in
July 2024. Please expand the disclosure to describe the nature of such modifications
and confirm that the Form of Servicing Agreement filed as Exhibit 99.1, and any other
applicable transaction document, accurately reflects the modifications. Refer to Item
1108(b)(3) of Regulation AB.
Description of the Notes, page 75
6.We note your disclosure that the description of the notes “does not purport to be
complete and is subject, and qualified in its entirety by reference, to the Indenture.”
As you are responsible for the accuracy and completeness of the information in the
filing, this type of disclaimer is not appropriate. While disclosure may direct investors
to read the entirety of the applicable documents for a more complete discussion, the
description of the material terms of such documents must be complete. Please revise
accordingly here and elsewhere in the prospectus as necessary.
The Transaction Documents, page 90
We note your statement that the disclosure “do not purport to summarize all material
provisions of the Transaction Documents and are qualified in their entirety by
reference to the actual Transaction Documents.” As you are responsible for the
accuracy and completeness of the information in the filing, this type of disclaimer is
not appropriate. While disclosure may direct investors to read the entirety of the
applicable documents for a more complete discussion, the description of the material
terms of such documents must be complete. Please revise accordingly here and 7.

April 3, 2025
Page 3
elsewhere in the prospectus as necessary.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Shalini Shah at 202-551-5942 or Kayla Roberts at 202-551-3490 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Structured Finance