SEC Filing Report: SCE Recovery Funding LLC – Form 10-K (FYE 2024)
Executive Summary
This report analyzes the 2024 Form 10-K filing for SCE Recovery Funding LLC, an asset-backed securities issuer. The filing indicates overall compliance with servicing criteria, as attested by both management and independent auditors. However, the report highlights a material instance of noncompliance by The Bank of New York Mellon Trust Company, N.A., the Indenture Trustee, regarding timely remittances to investors in a separate securitization. While this noncompliance does not directly impact SCE Recovery Funding LLC, it warrants monitoring as it reflects on the overall servicing quality within the asset-backed securities structure. The overall assessment is neutral, focusing on maintaining awareness of the servicing environment.
Company Overview
SCE Recovery Funding LLC is a special-purpose entity created to issue asset-backed securities. These securities are backed by recovery property, which represents the right to collect specific charges from Southern California Edison Company’s (SCE) customers, authorized by the California Public Utilities Commission (CPUC). SCE acts as the servicer for these assets. The company is a wholly-owned subsidiary of SCE, which is a wholly-owned subsidiary of Edison International.
Detailed Analysis
Filing Highlights
* **Filing Type:** 10-K (Annual Report)
* **Reporting Period:** Fiscal Year Ended December 31, 2024
* **Auditor:** PricewaterhouseCoopers LLP
* **Key Personnel:** Brendan Bond (Vice President and Treasurer of Southern California Edison Company, as servicer)
Financial Statement Analysis
* The financial statements themselves are omitted pursuant to General Instruction J of Form 10-K, which is permissible for issuers of asset-backed securities that meet certain conditions. This means the analysis focuses on compliance and servicing aspects rather than traditional financial performance metrics.
Management’s Discussion and Analysis (MD&A)
* The MD&A is omitted, again due to General Instruction J. The focus is on compliance with servicing criteria.
Risk Factors
* Risk Factors are omitted pursuant to General Instruction J of Form 10-K.
Compliance and Servicing
* **Servicer Compliance Statement (Exhibit 35.1):** Brendan Bond, as Vice President and Treasurer of Southern California Edison Company, certifies that SCE has fulfilled all of its obligations under the Recovery Property Servicing Agreements in all material respects throughout the reporting period.
* **Assessment of Compliance with Servicing Criteria (Exhibit 33.1):** SCE’s management asserts compliance with applicable servicing criteria as of and for the year ended December 31, 2024. PricewaterhouseCoopers LLP issued an attestation report (Exhibit 34.1) supporting this assertion.
* **Indenture Trustee Compliance (Exhibits 33.2 & 34.2):** The Bank of New York Mellon Trust Company, N.A., as Indenture Trustee, also provides an assessment of compliance. However, KPMG LLP’s attestation report (Exhibit 34.2) reveals a *material instance of noncompliance*: amounts due to investors in the Consumers 2023 Securitization Funding LLC transaction were not remitted in accordance with the timeframes set forth in the transaction agreements. The specific instance was a one-day delay in a September 2024 distribution. Remediation efforts are underway, including a daily report to management identifying outstanding deal onboarding items.
Key Exhibits
* **Exhibit 31.1:** Certification by Brendan Bond regarding the accuracy of the report and compliance with servicing agreements.
* **Exhibit 33.1:** Report on Assessment of Compliance with Servicing Criteria for Asset-Backed Securities for SCE Recovery Funding LLC.
* **Exhibit 33.2:** ASSESSMENT OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIA for The Bank of New York Mellon Trust Company, N.A.
* **Exhibit 34.1:** Report of Independent Registered Public Accounting Firm (PwC) on SCE’s compliance.
* **Exhibit 34.2:** Report of Independent Registered Public Accounting Firm (KPMG) on The Bank of New York Mellon Trust Company, N.A.’s compliance.
* **Exhibit 35.1:** Servicer Compliance Statement of Southern California Edison Company.
Red Flags
* The material instance of noncompliance by The Bank of New York Mellon Trust Company, N.A. is a red flag. While it doesn’t directly involve SCE Recovery Funding LLC’s servicing, it indicates a potential weakness in the broader servicing environment for asset-backed securities.
Conclusion and Actionable Insights
The 10-K filing for SCE Recovery Funding LLC indicates that SCE, as the servicer, is in compliance with the applicable servicing criteria. However, the identified noncompliance by the Indenture Trustee warrants attention.
**Recommendations:**
* **Monitor Remediation Efforts:** Track the progress of The Bank of New York Mellon Trust Company, N.A.’s remediation efforts to ensure the issue is resolved and doesn’t recur.
* **Assess Potential Impact:** Evaluate whether the Indenture Trustee’s noncompliance could indirectly affect SCE Recovery Funding LLC’s operations or reputation.
* **Review Servicing Agreements:** Periodically review the servicing agreements to ensure they adequately address potential servicing disruptions or failures by any party involved.
This analysis provides a snapshot of SCE Recovery Funding LLC’s compliance as of December 31, 2024, based on the information available in the Form 10-K filing. Continuous monitoring of the servicing environment and adherence to best practices are crucial for maintaining the integrity of the asset-backed securities.