KBRA assigns preliminary ratings to four classes of notes issued by ACHV ABS Trust 2024-1PL (“ACHV 2024-1PL”), a $200.63 million consumer loan asset-backed securities transaction. The preliminary ratings reflect initial credit enhancement levels of 59.10% for the Class A notes, 39.25% for the Class B notes, 28.15% for the Class C notes, and 13.65% for the Class D notes. Credit enhancement consists of overcollateralization, subordination (except for the Class D notes), a reserve account funded in subsequent periods after closing, and excess spread.

This transaction represents the 19th overall ABS securitization collateralized by unsecured consumer loans. The company completed 18 deals, five of which were under the Achieve brand, which was adopted in September 2022, after previously being named Freedom Financial. The proceeds from the sale of the notes will be used to pay transaction expenses and purchase the loans and related rights from FREED ABS Master Depositor Trust (the “Depositor”), which purchased the loans from the Loan Sellers. The Depositor will in turn sell the loans to the Issuer.

KBRA applied its Consumer Loan ABS Global Rating Methodology, as well as its Global Structured Finance Counterparty Methodology and ESG Global Rating Methodology as part of its analysis of the transaction’s underlying collateral pool, the proposed capital structure and FFAM’s historical static pool data. KBRA considered its operational review of Freedom, as well as periodic update calls with the Company. Operative agreements and legal opinions will be reviewed prior to closing.

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Methodologies

• ABS: Consumer Loan ABS Global Rating Methodology
• Structured Finance: Global Structured Finance Counterparty Methodology
• ESG Global Rating Methodology

Disclosures

Further information on key credit considerations, sensitivity analyses that consider what factors can affect these credit ratings and how they could lead to an upgrade or a downgrade, and ESG factors (where they are a key driver behind the change to the credit rating or rating outlook) can be found in the full rating report referenced above.

A description of all substantially material sources that were used to prepare the credit rating and information on the methodology(ies) (inclusive of any material models and sensitivity analyses of the relevant key rating assumptions, as applicable) used in determining the credit rating is available in the Information Disclosure Form(s) located here.

Information on the meaning of each rating category can be located here.

Further disclosures relating to this rating action are available in the Information Disclosure Form(s) referenced above. Additional information regarding KBRA policies, methodologies, rating scales and disclosures are available at www.kbra.com.

About KBRA

Kroll Bond Rating Agency, LLC (KBRA) is a full-service credit rating agency registered with the U.S. Securities and Exchange Commission as an NRSRO. Kroll Bond Rating Agency Europe Limited is registered as a CRA with the European Securities and Markets Authority. Kroll Bond Rating Agency UK Limited is registered as a CRA with the UK Financial Conduct Authority. In addition, KBRA is designated as a designated rating organization by the Ontario Securities Commission for issuers of asset-backed securities to file a short form prospectus or shelf prospectus. KBRA is also recognized by the National Association of Insurance Commissioners as a Credit Rating Provider.

Doc ID: 1003424

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