Subprime auto financing is getting much more complex, from underwriting to securitizations.

Likely connected with fallout from last week’s Tricolor Holdings’ Chapter 7 bankruptcy, Credit Acceptance filed a Form 8-K with the Securities and Exchange Commission on Monday morning, addressing what it called, “select inquiries” it had received through Friday.

First, Credit Acceptance responded to how its loan performance has been going so far this quarter.

“For the two-month period ended August 31, 2025, consumer loan performance was generally consistent with the trends we have reported in recent quarters. We continue to monitor consumer loan performance closely and will provide a full update in our third quarter earnings release and Form 10-Q,” Credit Acceptance said in the SEC filing.

Next, Credit Acceptance said it was asked what percentage of its loan portfolio and new originations involve consumers who do not have a Social Security Number (SSN) or an Individual Taxpayer Identification Number (ITIN).

“Our underwriting policies require borrowers to provide either a Social Security Number (SSN) or an Individual Taxpayer Identification Number (ITIN), with the sole exception being a small pilot program launched in 2025 to evaluate collections performance among borrowers who do not possess SSNs or ITINs,” Credit Acceptance said. “Participation in this program is currently limited to five designated market areas, and all borrowers are required to provide a valid government-issued photo identification to ensure identity verification.

“The volume of originations under this pilot remains de minimis relative to both our total originations during the pilot period and our overall loan portfolio. In the aggregate, collections performance within the pilot has been consistent with expectations. We currently have no plans to expand the pilot beyond its existing scope.”

The subprime auto finance company closed its form to the SEC with this statement.

“Credit Acceptance Corporation, in disclosing this information, is not acknowledging any obligation to have done so and is not undertaking any obligation to disclose this information in the future,” the company said.

More details certainly were disclosed in Tricolor’s bankruptcy filing, which was shared with Cherokee Media Group by James Waldron, who is president of Texas-based 1st Adjusters.

Waldron’s repossession agency is one of the nearly 27,000 creditors specified among Tricolor’s liabilities that are approaching $10 billion. Those creditors not only are repo agents like Waldron, but there are also commercial banks, transportation companies, body shops, and multiple other service providers as well as former employees and consumer customers.

And Cherokee Media Group confirmed what Reuters reported on Wednesday that the law firm that helped Tricolor make its bankruptcy filing in Dallas would no longer represent the company.

As recently as June, Tricolor made a move involving securitizations. And because of its bankruptcy filing, those securitizations are in turmoil.

On Friday, S&P Global Ratings placed its ratings on six classes from Tricolor Auto Securitization Trust 2025-2’s (TAST 2025-2’s) automobile receivables-backed notes on CreditWatch with negative implications (see list).

Today’s CreditWatch placements reflect Tricolor Auto Acceptance LLC’s voluntary petition under Chapter 7 of title 11 of the U.S. Bankruptcy Code. Tricolor Auto Acceptance LLC is the sponsor, seller, servicer, and administrator of the TAST 2025-2 transaction.

In a news release, S&P Global Ratings explained the filing of the bankruptcy petition by Tricolor constitutes an insolvency event, and in its capacity as servicer, a servicer termination event. S&P Global Ratings said Wilmington Trust N.A. (WTNA), as indenture trustee, has provided a servicer termination notice to the depositor, the servicer, and the backup servicer, terminating the servicer rights and obligations pursuant to the sale and servicing agreement.

Vervent, the backup servicer to the transaction, has been appointed the successor servicer, unless the noteholders vote otherwise, according to S&P Global Ratings.

“We will continue to monitor the transaction’s performance. As relevant information becomes available, such as the successor servicer performance, the performance of the receivables as reflected in the monthly investor report, and developments relating to Tricolor’s bankruptcy, we will look to resolve the CreditWatch placement,” S&P Global Ratings said in the news release.