SEC Comment Letter 0000000000-23-006075 to Bridgecrest Auto Funding LLC (CIK 0001974820)
Bridgecrest Auto Funding LLC (CIK 0001974820)
Date: June 7, 2023 · CIK: 0001974820 · Accession: 0000000000-23-006075
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File numbers found in text: 333-271899
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United States securities and exchange commission logo
June 7, 2023
Daniel Gaudreau
President and Treasurer
Bridgecrest Auto Funding LLC
1720 W. Rio Salado Parkway
Tempe, AZ 85281
Re:Bridgecrest Auto Funding LLC
Registration Statement on Form SF-3
Filed May 12, 2023
File No. 333-271899
Dear Daniel Gaudreau:
We have reviewed your registration statement and have the following comments. In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form SF-3
General
1.Please review defined terms throughout your registration statement to ensure they are
defined as intended. For example, we note “funding period” has not been formally defined
and does not appear in the index of defined terms beginning on page I-1 of your form of
prospectus.
Cover Page
2.Please clarify on the cover page of your registration statement that the depositor is also
acting as depositor to the grantor trusts described in the registration statement.
FirstName LastNameDaniel Gaudreau
Comapany NameBridgecrest Auto Funding LLC
June 7, 2023 Page 2
FirstName LastName
Daniel Gaudreau
Bridgecrest Auto Funding LLC
June 7, 2023
Page 2
Form of Prospectus
Summary of Terms
Statistical Information, page 8
3.We note that the exceptions listed here for the receivables in the receivables pool as of the
statistical cut-off date do not match the exceptions listed in the risk factor on page 24 of
your form of prospectus. Specifically, exception (iii) on page 24 does not appear in the
summary. Please revise accordingly and elsewhere in the prospectus, as necessary.
Subsequent Receivables, page 9
4.Please confirm the funding period will not extend for more than one year from the date of
issuance of the securities. Refer to Item 1101(c)(3)(ii) of Regulation AB.
Origination, page 48
5.We note your bracketed placeholder to disclose information under Item 1110(a) of
Regulation AB about any originator or group of originators that originated, or is expected
to originate, 10% or more of the pool assets. For clarity, please also include a bracketed
placeholder to disclose information under Item 1110(b) of Regulation AB about
any originator or group of originators that originated, or is expected to originate, 20% or
more of the pool assets.
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 Jason Weidberg at 202-551-6892 or Arthur Sandel at 202-551-3262 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Structured Finance