Exhibit 33.1
Management’s Assessment of Compliance with Applicable Servicing Criteria
1.American Honda Finance Corporation (“AHFC”) is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of March 31, 2026, and for the year ended March 31, 2026 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report consist of all asset-backed securities transactions for which AHFC acted as servicer and administrator involving retail automobile receivables for new and used Honda and Acura vehicles (the “Platform”). The asset-backed securities transactions included in the Platform are set forth in Appendix B hereto;
2.AHFC has engaged vendors, which are not servicers as defined in Item 1101(j) of Regulation AB, to perform specific, limited or scripted activities (the “Vendors”), and AHFC elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors’ activities as set forth in Appendix A hereto. AHFC has policies and procedures in place designed to provide reasonable assurance that the vendor’s activities comply in all material respects with the applicable Item 1122 criteria;
3.Except as set forth in paragraph 4 below, AHFC used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess compliance with the applicable servicing criteria;
4.The criteria listed in the column titled “Inapplicable Servicing Criteria” in Appendix A hereto are inapplicable to AHFC based on the activities it performs, directly or through its Vendors, with respect to the Platform;
5.AHFC has complied, in all material respects, with the applicable servicing criteria as of March 31, 2026 and for the Reporting Period with respect to the Platform taken as a whole;
6.AHFC has not identified and is not aware of any material instance of noncompliance by the Vendors with the applicable servicing criteria as of March 31, 2026 and for the Reporting Period with respect to the Platform taken as a whole;
7.AHFC has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors with the applicable servicing criteria as of March 31, 2026 and for the Reporting Period with respect to the Platform taken as a whole; and
8.KPMG LLP, an independent registered public accounting firm, has issued an attestation report on AHFC’s assessment of compliance with the applicable servicing criteria as of March 31, 2026 and for the Reporting Period.
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June 22, 2026 |
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American Honda Finance Corporation |
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By: |
/s/ Paul C. Honda |
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Name: |
Paul C. Honda |
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Title: |
Vice President and Treasurer |
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(senior officer in charge of the servicing function) |
Signature page for Management’s Assessment of Compliance with Applicable Servicing Criteria
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1122(d)(4)(xi) |
Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements. |
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X |
1122(d)(4)(xii) |
Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the servicer’s funds and not charged to the obligor, unless the late payment was due to the obligor’s error or omission. |
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X |
1122(d)(4)(xiii) |
Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the servicer, or such other number of days specified in the transaction agreements. |
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X |
1122(d)(4)(xiv) |
Delinquencies, charge-offs and uncollectable accounts are recognized and recorded in accordance with the transaction agreements. |
X |
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1122(d)(4)(xv) |
Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements. |
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X |
1.Testwork is incorporated in testwork done via 1122(d)(3)(i).
2.1122(d)(2)(i) and 1122(d)(4)(iv) are performed directly by AHFC only as it relates to the recording and application of borrower payments, as well as the remittance of collections to the Indenture Trustee (as defined in the transaction agreements). As permitted by the transaction agreements, AHFC is allowed to remit collections to the Indenture Trustee’s collection account prior to the payment date.
The initial processing of cash receipts at the lockbox was performed by a vendor that did not provide an Item 1122(d) attestation report, and for which AHFC has elected to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such vendor’s activities, as permitted by the SEC’s Compliance and Disclosure Interpretation (“C&DI”) 200.06, Vendors Engaged By Servicers (“C&DI 200.06”) (formerly Interpretation 17.06 of the SEC’s Division of Corporation Finance Manual of Publicly Available Telephone Interpretations). Further, AHFC has policies and procedures in place designed to provide reasonable assurance that the vendor’s activities comply in all material respects with the applicable Item 1122 criteria.
3.AHFC’s responsibility relating to criterion 1122(d)(2)(ii) is limited to wire disbursements to the Indenture Trustee (as defined in the transaction agreements). The Indenture Trustees have provided separate Regulation AB 1122(d) management assessments and related attestation reports.
4.AHFC has full responsibility relating to criteria 1122(d)(3)(ii), 1122(d)(3)(iii), and 1122(d)(3)(iv) except for the portions of those criteria for which the Indenture Trustees have taken responsibility. The Indenture Trustees have provided separate Regulation AB 1122(d) management assessments and related attestation reports.
5.Pertaining to 1122(d)(4)(i) and 1122(d)(4)(ii), AHFC has outsourced maintenance and safeguarding of vehicle titles and other documents related to retail contracts to a third party that did not provide an Item 1122(d) attestation report and for which AHFC has elected to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to that portion of the servicing activities, as permitted by the SEC’s C&DI 200.06. AHFC is responsible for maintenance and safeguarding of all other collateral and related documents. Further, AHFC has adequate policies and procedures in place designed to provide reasonable assurance that such vendor’s activities comply in all material respects with the applicable Item 1122 criteria.
Appendix B
Honda Auto Receivables 2021-4, 2022-1, 2022-2, 2023-1, 2023-2, 2023-3, 2023-4, 2024-1, 2024-2, 2024-3, 2024-4, 2025-1, 2025-2, 2025-3, 2025-4, 2026-1 Owner Trusts.