Independent Accountants’ Agreed-Upon Procedures Report

 

Freedom Debt Relief, LLC (the “Company”)

Jefferies LLC (the “Structuring Agent”)

(together, the “Specified Parties”)

Re: ACHD Trust 2026-DS1 – Data File Procedures

 

We have performed the procedures described below on the specified attributes in an electronic data file entitled “18.6-1 Securitization_date_tape_506.csv” provided by the Company on May 13, 2026, containing information on 390,621 debt settlement fee rights (the “Debt Settlement Receivables”) as of May 6, 2026 (the “Data File”). We were informed the Debt Settlement Receivables are intended to be included as collateral in the offering by ACHD Trust 2026-DS1. The Company is responsible for the specified attributes identified by the Company in the Data File.

 

The Specified Parties have agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting the Specified Parties in evaluating the accuracy of the specified attributes in the Data File. This report may not be suitable for any other purpose. No other parties have agreed to or acknowledged the appropriateness of these procedures for the intended purpose or any other purpose.

 

The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. We make no representation regarding the appropriateness of the procedures either for the intended purpose or for any other purpose.

 

Unless otherwise stated, the following definitions have been adopted in presenting our procedures and findings:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The procedures we were instructed by the Company to perform and the associated findings are as follows:

 

 

 

We found such information to be in agreement without exception.

We were engaged by the Company to perform this agreed-upon procedures engagement. We conducted our engagement in accordance with attestation standards established by the American Institute of Certified Public Accountants, which involves us performing the specific procedures agreed to and acknowledged above and reporting on findings based on performing those procedures. We were not engaged to, and did not, conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on the specified attributes in the Data File. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported.

We are required to be independent of the Company and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement.

 

The procedures performed were applied based on the information included in the Data File and Provided Information, without verification or evaluation of such information by us; therefore, we express no opinion or any other form of assurance regarding (i) the reasonableness of the information provided to us by the Company, (ii) the physical existence of the Debt Settlement Receivables, (iii) the reliability or accuracy of the Provided Information which was used in our procedures, or (iv) matters of legal interpretation.

 

The procedures performed were not intended to address, nor did they address: (i) the conformity of the origination of the Debt Settlement Receivables to stated underwriting or credit extension guidelines, standards, criteria or other requirements, (ii) the value of collateral securing any such Debt Settlement Receivables being securitized, (iii) the compliance of the originator of the Debt Settlement Receivables with federal, state, and local laws and regulations, or (iv) any other factor or characteristic of the Debt Settlement Receivables that would be material to the likelihood that the issuer of the asset-backed securities will pay interest and principal in accordance with applicable terms and conditions. The procedures performed were not intended to satisfy any criteria for due diligence published by the nationally recognized statistical rating organizations (“NRSROs”).

 

The terms of our engagement are such that we have no responsibility to update this report because of events and circumstances that may subsequently occur.

 

This report is intended solely for the information and use of the Specified Parties. It is not intended to be and should not be used by any other person or entity, including investors or the NRSROs, who are not identified in the report as the Specified Parties but may have access to this report as required by law or regulation.

	/s/ KPMG LLP
Irvine, California
June 1, 2026

Exhibit A

Attributes, Source Documents, and Instructions

 

	Attribute			Attribute Name in the Data File			Source Documents / Instructions
	Customer Creditor ID			Alt_Customer_ID			N/A- for identification purposes only.
	Customer Status			Customer_Status			CRM Data File, Servicing System Screenshot (i) If the Account Status in the CRM Data File for the corresponding Customer Creditor ID is “Active Negotiation”, “Negotiation Assist”, “Removed From Program”, or “NLLG Referred”, consider the Customer Status to be “Pre-Settlement”.   (ii) If the Account Status in the CRM Data File for the corresponding Customer Creditor ID is “Ongoing Structure”, “N&V”, “Resolved”, consider the Customer Status to be “Post-Settlement”. (iii) For all other cases, compare the Customer Status in the Data File to the Servicing System Screenshots.
	Enrollment Date			Enrollment_date			Debt Resolution Agreements, Origination System Screenshot
	Original Estimated Length of Enrollment			Original_Estimated_length _of_enrollment			Debt Resolution Agreements
	Current Estimated Length of Enrollment			current_estimated_length _of_enrollment			CRM Data File, Servicing System Screenshots Recompute as: (i) the number of days (using a  360-day year basis) between May 6, 2026, and the “Estimated Graduation Date” in the CRM Data File; (ii) Divide the result from step (i) by 30 and round to the nearest integer; and,

	Attribute			Attribute Name in the Data File			Source Documents / Instructions
							(iii) add the result from step (ii) to the “Months in Program” in the CRM Data File.
	Category of Debt			Category_of_Debt			CRM Data File, Servicing System Screenshots (i) If the Category of Debt in the Data File is “Unknown”, consider the information to be in agreement if the “Account Type” in the CRM Data File is “0” or “Secured Debt”.   (ii) If the Category of Debt in the Data File is “Utility Services”, consider the information to be in agreement if the “Account Type” in the CRM Data File is “Disc. Services.”   (iii) If the Category of Debt in the Data File is not in agreement, compare the Category of Debt in the Data File to the Servicing System Screenshots.
	Creditor Name			Creditor_Name			CRM Data File
	Original Balance			Original_Enrolled_Balance			CRM Data File
	Current Unpaid Balance			Current_Active_Enrolled _Balance			CRM Data File, Servicing System Screenshots
	Total Fee			Total_fee			Recompute by multiplying the Original Balance and Fee Percentage.
	FICO at Enrollment			FICO_at_enrollment			CRM Data File
	State			State			Debt Resolution Agreement, Servicing System Screenshots
	Borrower Income			Stated_Verified_Income			Debt Resolution Agreements
	Fee Percentage			Fee_percentage			Debt Resolution Agreements
	Frequency of Deposits			Frequency_of_scheduled _customer_escrow_ deposits			Debt Resolution Agreements

	Attribute			Attribute Name in the Data File			Source Documents / Instructions
							If the Frequency of Deposits in the Data File is “Split”, consider the information to be in agreement if the Frequency of Deposits in the Debt Resolution Agreement is “Bi-Monthly”.
	Number of Deposits Made to Date			Number_of_deposits_made _by_customer_to_date			CRM Data File
	Value of Deposits Made to Date			Value_of_deposits_made _by_customer_to_date			CRM Data File, Servicing System Screenshots
	First Cleared Deposit Date			First_cleared_deposit_date			CRM Data File
	Active Settlement Amount			Active_settlement_amount			CRM Data File, Servicing System Screenshots
	Active Settlement Balance			Active_settlement_enrolled _balance			CRM Data File If the Active Settlement Balance in the Data File is equal to “0”, consider the information to be in agreement if “Is Active Settlement” in the CRM Data File is equal to “0”.
	Total Future Fees			Total_Future_Fees			CRM Data File

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