Morningstar DBRS Assigns Provisional Credit Ratings to ACHV ABS Trust 2024-3AL

DBRS, Inc. (Morningstar DBRS) assigned provisional credit ratings to the following classes of notes to be issued by ACHV ABS Trust 2024-3AL (ACHV 2024-3AL or the Issuer):

-- $65,654,000 Class A Notes at (P) AAA (sf)
-- $37,588,000 Class B Notes at (P) AA (low) (sf)
-- $23,555,000 Class C Notes at (P) A (low) (sf)

CREDIT RATING RATIONALE/DESCRIPTION

The provisional credit ratings on the Class A, Class B, and Class C Notes (together, the Notes) are based on Morningstar DBRS' review of the following considerations:

(1) The transaction's form and sufficiency of available credit enhancement.
-- Subordination, overcollateralization, amounts held in the reserve fund, and available excess spread, which create credit enhancement levels that are commensurate with the credit ratings.
-- Transaction cash flows that are sufficient to repay investors under all AAA (sf), AA (low) (sf), and A (low) (sf) stress scenarios in accordance with the terms of the ACHV 2024-3AL transaction documents.

(2) The experience, sourcing, and servicing capabilities of Achieve Personal Loans (APL).

(3) The experience, underwriting, and origination capabilities of Cross River Bank (CRB) (the Partner Bank).

(4) The ability of Wilmington Trust National Association to perform duties as a Backup Servicer and the ability of Firstmark Services LLC to perform duties as a Backup Servicer Subcontractor.

(5) The annual percentage rate (APR) charged on the loans and the status of the Partner Bank as the true lender.
-- All loans included in ACHV 2024-3AL are originated by CRB, a New Jersey state-chartered Federal Deposit Insurance Corporation-insured bank.
-- Loans originated by CRB are all within the New Jersey state usury limit of 30.00%.
-- The weighted-average APR of the loans in the pool is 27.96%.
-- Loans may be in excess of individual state usury laws; however, the Partner Bank as the true lender is able to export rates that pre-empt state usury rate caps.
-- Loans originated to borrowers in Connecticut, Vermont, Colorado, and West Virginia are excluded from the pool.
-- Loans originated by the Partner Bank is sold directly to third-party investors under loan purchase agreements.
-- Under the Loan Sale Agreement, APL is obligated to repurchase any loan if there is a breach of a representation and warranty that materially and adversely affects the interests of the purchaser.

(6) The Morningstar DBRS cumulative net loss assumption of 21.65% based on the Statistical Cutoff Date pool composition.

(7) The legal structure and legal opinions that address the true sale of the unsecured loans, the nonconsolidation of the trust, that the trust has a valid perfected security interest in the assets, and consistency with the Morningstar DBRS "Legal Criteria for U.S. Structured Finance."

(8) The transaction assumptions consider Morningstar DBRS' baseline macroeconomic scenarios for rated sovereign economies, available in its commentary Baseline Macroeconomic Scenarios for Rated Sovereigns September 2024 Update, published on September 25, 2024. These baseline macroeconomic scenarios replace Morningstar DBRS' moderate and adverse COVID-19 pandemic scenarios, which were first published in April 2020.

Morningstar DBRS' credit rating on the securities referenced herein addresses the credit risk associated with the identified financial obligations in accordance with the relevant transaction documents. The associated financial obligations are the related Interest Distributable Amount and the related Note Balance.

Morningstar DBRS' credit rating does not address nonpayment risk associated with contractual payment obligations contemplated in the applicable transaction document(s) that are not financial obligations. The associated contractual payment obligation that is not a financial obligation is the related interest on unpaid Interest Distributable Amount for each of the rated notes.

Morningstar DBRS' long-term credit ratings provide opinions on risk of default. Morningstar DBRS considers risk of default to be the risk that an issuer will fail to satisfy the financial obligations in accordance with the terms under which a long-term obligation has been issued.

ENVIRONMENTAL, SOCIAL, AND GOVERNANCE CONSIDERATIONS
There were no Environmental/Social/Governance factors that had a significant or relevant effect on the credit analysis.

A description of how Morningstar DBRS considers ESG factors within the Morningstar DBRS analytical framework can be found in the Morningstar DBRS Criteria: Approach to Environmental, Social, and Governance Factors in Credit Ratings (August 13, 2024) at https://dbrs.morningstar.com/research/437781.

Notes:
All figures are in U.S. dollars unless otherwise noted.

The principal methodology applicable to the credit ratings is: Rating U.S. Structured Finance Transactions (Appendix I: U.S. Consumer Loan ABS Transactions) (August 6, 2024), https://dbrs.morningstar.com/research/437571.

Other methodologies referenced in this transaction are listed at the end of this press release.

The credit rating was initiated at the request of the rated entity.

The rated entity or its related entities did participate in the credit rating process for this credit rating action.

Morningstar DBRS had access to the accounts, management and other relevant internal documents of the rated entity or its related entities in connection with this credit rating action.

This is a solicited credit rating.

A provisional credit rating is not a final credit rating with respect to the above-mentioned securities and may change or be different than the final credit rating assigned or may be discontinued. The assignment of the final credit ratings on the above-mentioned securities are subject to receipt by Morningstar DBRS of all data and/or information and final documentation that Morningstar DBRS deems necessary to finalize the credit ratings.

Please see the related appendix for additional information regarding the sensitivity of assumptions used in the credit rating process.

DBRS, Inc.
140 Broadway, 43rd Floor
New York, NY 10005 USA
Tel. +1 212 806-3277

The credit rating methodologies used in the analysis of this transaction can be found at:
https://dbrs.morningstar.com/about/methodologies.

Rating U.S. Structured Finance Transactions (August 6, 2024),

https://dbrs.morningstar.com/research/437571

Operational Risk Assessment for U.S. ABS Originators and Servicers (August 6, 2024),
https://dbrs.morningstar.com/research/437545

Legal Criteria for U.S. Structured Finance (April 15, 2024),

https://dbrs.morningstar.com/research/431205

For more information on this credit or on this industry, visit dbrs.morningstar.com or contact us at info-DBRS@morningstar.com.