MANAGEMENT'S REPORT ON ASSESSMENT OF COMPLIANCE WITH  SEC REGULATION AB SERVICING CRITERIA  1. Bridgecrest Credit Company, LLC (the "Company" or "Bridgecrest"), a wholly-owned subsidiary of Bridgecrest Acceptance Corporation, is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB as of and for the year ended December 31, 2022, (the "Reporting Period"), as set forth in Appendix A hereto. The transactions covered by this report include asset-backed transactions and securities, involving the CARVANA-originated public auto loan receivables servicing platform (the "Platform"). This includes the asset-backed transactions and securities for which Bridgecrest acted as servicer as defined in Appendix B hereto. 2. Except as set forth in paragraph 3 below, Bridgecrest used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to provide an assertion on the Company's assessment of compliance with the applicable servicing criteria. 3. The criteria listed as "Inapplicable Servicing Criteria" in Appendix A hereto are inapplicable to Bridgecrest based on the activities it performed, directly or through its Vendors, with respect to the Platform for the Reporting Period. 4. With respect to servicing criteria 1122(d)(2)(i),1122(d)(3)(ii), 1122(d)(4)(iv), and 1122(d)(4)(viii) Bridgecrest has engaged various Vendors to perform some or all of the activities required by these servicing criteria. Management has determined that these Vendors are not considered a "servicer" as defined in Item 1101(j) of Regulation AB, and has elected to take responsibility for assessing compliance with the servicing criteria applicable to each Vendor as permitted by the SEC's Compliance & Disclosure Interpretation 200.06, Vendors Engaged by Servicers ("C&DI 200.06"), formerly Interpretation 17.06 of the SEC Division of Corporation Finance Manual of Publicly Available Telephone Interpretations. As permitted by C&DI 200.06, management asserts that it has policies and procedures in place designed to provide reasonable assurance that the Vendor's activities comply in all material respects with the servicing criteria applicable to each Vendor. Management is not aware of any material deficiencies in such policies and procedures or any material instances of non-compliance of the servicing criteria as relates to the Company by such Vendors. Management is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the Vendors and related servicing criteria. Page 1 of 8  Exhibit 35.1
 5. Bridgecrest has complied, in all material respects, with the applicable servicing criteria for the Reporting Period with respect to the Platform taken as a whole. 6. Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation report on Bridgecrest's assertion on compliance with the applicable servicing criteria for the Reporting Period. Bridgecrest Credit Company, LLC  March 15, 2023    /s/ Daniel Gaudreau  Daniel Gaudreau, Chief Financial Officer  Page 2 of 8
 Appendix A — Applicable Servicing Criteria  SERVICING CRITERIA APPLICABLE SERVICING  CRITERIA  INAPPLICABLE  SERVICING CRITERIA  Reference Criteria  Performed  Directly by  Bridgecrest  Performed by  Vendor(s) for  which  Bridgecrest is  the Responsible  Party  Performed by  subservicer(s)  or Vendor(s)  for which  i Bridgecrest s  NOT the  Responsible  Party  NOT performed  by Bridgecrest  or by  u s bservicer(s)  or Vendor(s)  retained by  Bridgecrest  General Servicing Considerations  1122(d)(1)(i)  Policies and procedures are instituted to monitor any  performance or other triggers and events of default in  accordance with the transaction agreements.  X  1122(d)(1 )(ii)  If any material servicing activities are outsourced to third  parties, policies and procedures are instituted to monitor  the third party's performance and compliance with such  servicing activities.  X  1122(d)(1)(iii)  Any requirements in the transaction agreements to  maintain a back-up servicer for the pool assets are  maintained.  X  1122(d)(1)(iv)  A fidelity bond and errors and omissions policy is in effect  on the party participating in the servicing function  throughout the reporting period in the amount of  coverage required by and otherwise in accordance with  the terms of the transaction agreements.  X  1122(d)(1)(v)  Aggregation of information, as applicable, is  mathematically accurate and the information conveyed  accurately reflects the information.  X  Cash Collection and Administration  1122(d)(2)(i)  Payments on pool assets are deposited into the  appropriate custodial bank accounts and related bank  clearing accounts no more than two business days of  receipt, or such other number of days specified in the  transaction agreements.  X X  1122(d)(2)(ii)  Disbursements made via wire transfer on behalf of an  obligor or to an investor are made only by authorized  personnel.  X  1122(d)(2)(iii)  Advances of funds or guarantees regarding collections,  cash flows or distributions, and any interest or other fees  charged for such advances, are made, reviewed and  approved as specified in the transaction agreements.  X  Page 3 of 8
 SERVICING CRITERIA APPLICABLE SERVICING  CRITERIA  INAPPLICABLE  SERVICING CRITERIA  I  Reference Criteria  Performed  Directly by  Bridgecrest  Performed by  Vendor(s) for  which  Bridgecrest is  the Responsible  Party  Performed by  subservicer(s)  or Vendor(s)  for which  Bridgecrest is  NOT the  Responsible  Party  NOT performed  by Bridgecrest  or by  subservicer(s)  or Vendor(s)  retained by  Bridgecrest  1122(d)(2)(iv)  The related accounts for the transaction, such as cash  reserve accounts or accounts established as a form of  over collateralization, are separately maintained (e.g.,  with respect to commingling of cash) as set forth in the  transaction agreements.  X  1122(d)(2)(v)  Each custodial account is maintained at a federally  insured depository institution as set forth in the  transaction agreements. For purposes of this criterion,  "federally insured depository institution" with respect to a  foreign financial institution means a foreign financial  institution that meets the requirements of §240.13k- 1(b)(1) of this chapter.  X  1122(d)(2)(vi) Unissued checks are safeguarded so as to prevent  unauthorized access. X  1122(d)(2)(vii)  Reconciliations are prepared on a monthly basis for all  asset- backed securities related bank accounts, including  custodial accounts and related bank clearing accounts.  These reconciliations: (A) Are mathematically accurate;  (B) Are prepared within 30 calendar days after the bank  statement cutoff date, or such other number of days  specified in the transaction agreements; (C) Are  reviewed and approved by someone other than the  person who prepared the reconciliation; and (D) Contain  explanations for reconciling items. These reconciling  items are resolved within 90 calendar days of their  original identification, or such other number of days  specified in the transaction agreements.  X  Investor Remittances and Reporting  1122(d)(3)(i)  Reports to investors, including those to be filed with the  Commission, are maintained in accordance with the  transaction agreements and applicable Commission  requirements. Specifically, such reports: (A) Are  prepared in accordance with timeframes and other terms  set forth in the transaction agreements; (B) Provide  information calculated in accordance with the terms  specified in the transaction agreements; (C) Are filed with  the Commission as required by its rules and regulations;  and (D) Agree with investors' or the trustee's records as  to the total unpaid principal balance and number of pool  assets serviced by the servicer.  XI  1 For criterion 1122(d)(3)(i)(C), Bridgecrest did not perform the activity described in this criterion for the Reporting Period as this component of  1122(d)(3)(i) is inapplicable to the functions performed by Bridgecrest. No assessment of compliance, therefore, is necessary.  Page 4 of 8
 SERVICING CRITERIA APPLICABLE SERVICING  CRITERIA  INAPPLICABLE  SERVICING CRITERIA  Reference Criteria  Performed  Directly by  Bridgecrest  Performed by  Vendor(s) for  which  Bridgecrest is  the Responsible  Party  Performed by  subservicer(s)  or Vendor(s)  for which  Bridgecrest s i  NOT the  Responsible  Party  NOT performed  by Bridgecrest  or by  subservicer(s)  or Vendor(s)  retained by  Bridgecrest  1122(d)(3)(ii)  Amounts due to investors are allocated and remitted in  accordance with timeframes, distribution priority and  other terms set forth in the transaction agreements.  X X  _ 1122(d)(3)010  Disbursements made to an investor are posted within two  business days to the servicer's investor records, or such  other number of days specified in the transaction  agreements.  X  1122(d)(3)(iv)  Amounts remitted to investors per the investor reports  agree with cancelled checks, or other form of payment,  or custodial bank statements.  X  Pool Asset Administration  1122(d)(4)(i)  Collateral or security on pool assets is maintained as  required by the transaction agreements or related pool  asset documents.  X  . 1122(d)(4)00 Pool assets and related documents are safeguarded as  required by the transaction agreements. X  1122(d)(4)(iii)  Any additions, removals or substitutions to the asset pool  are made, reviewed and approved in accordance with  any conditions or requirements in the transaction  agreements.  X  1122(d)(4)(iv)  Payments on pool assets, including any payoffs, made in  accordance with the related pool asset documents are  posted to the applicable servicer's obligor records  maintained no more than two business days after receipt,  or such other number of days specified in the transaction  agreements, and allocated to principal, interest or other  items (e.g., escrow) in accordance with the related pool  asset documents.  X X  1122(d)(4)(v)  The servicer's records regarding the pool assets agree  with the servicer's records with respect to an obligor's  unpaid principal balance.  X  Page 5 of 8
 SERVICING CRITERIA APPLICABLE SERVICING  CRITERIA  INAPPLICABLE  SERVICING CRITERIA  Reference Criteria  Performed  Directly by  Bridgecrest  Performed by  Vendor(s) for  which  Bridgecrest is  the Responsible  Party  Performed by  subservicer(s)  or Vendor(s)  for which  Bridgecrest is  NOT the  Responsible  Party  NOT performed  by Bridgecrest  or by subservicer(s)  or Vendor(s)  retained by  Bridgecrest  1122(d)(4)(vi)  Changes with respect to the terms or status of an  obligor's pool assets (e.g., loan modifications or re- aging's) are made reviewed and approved by authorized  personnel in accordance with the transaction agreements  and related pool asset documents.  X  1122(d)(4)(vii)  Loss mitigation or recovery actions (e.g. forbearance  plans, modifications and deeds in lieu of foreclosure,  foreclosure and repossessions, as applicable) are  initiated, conducted and concluded in accordance with  the timeframes or other requirements established by the  transaction agreements.  X  1122(d)(4)  (viii)  Records documenting collection efforts are maintained  during the period a pool asset is delinquent in  accordance with the transaction agreements. Such  records are maintained on at least a monthly basis, or  such other period specified in the transaction  agreements, and describe the entity's activities in  monitoring delinquent pool assets including, for example,  phone calls, letters and payment rescheduling plans in  cases where delinquency is deemed temporary (e.g.,  illness or unemployment).  X X  1122(d)(4)(ix)  Adjustments to interest rates or rates of return for pool  assets with variable rates are computed based on the  related pool asset documents.  X  1122(d)(4)(x)  Regarding any funds held in trust for an obligor (such as  escrow accounts) See following: (A) Such funds are  analyzed, in accordance with the obligor's pool asset  documents, on at least an annual basis, or such other  period specified in the transaction agreements; (B)  Interest on such funds is paid, or credited, to obligors in  accordance with applicable pool asset documents and  state laws; and (C) Such funds are returned to the obligor  within 30 calendar days of full repayment of the related  pool asset, or such other number of days specified in the  transaction agreements.  X  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.  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.  X  Page 6 of 8
 SERVICING CRITERIA APPLICABLE SERVICING  CRITERIA  INAPPLICABLE  SERVICING CRITERIA  Reference  Criteria Performed  Directly by  Bridgecrest  Performed by  Vendor(s) for  which  Bridgecrest is  the Responsible  Party  Performed by  subservicer(s)  or Vendor(s)  for which  Bridgecrest is  NOT the  Responsible  Party  NOT performed  by Bridgecrest  or by  subservicer(s)  or Vendor(s)  retained by  Bridgecrest  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.  X  1122(d)(4)(xiv)  Delinquencies, charge-offs and uncollectible accounts  are recognized and recorded in accordance with the  transaction agreements.  X  1122(d)(4)(xv)  Any external enhancement or other support, identified in  Item 1114(a) (1) through (3) or Item 1115 of this  Regulation AB, is maintained as set forth in the  transaction agreements.  X  Page 7 of 8
 Appendix B — The Platform  Asset Pool # Asset Pool Description Servicing Agreement  Effective Date  44201 Carvana 2020-P1 December 10, 2020  44211 Carvana 2021-P1 March 18, 2021  44212 Carvana 2021-P2 June 24, 2021  44213 Carvana 2021-P3 September 29, 2021  44214 Carvana 2021-P4 December 29, 2021  45211 Carvana 2021-N1 March 25, 2021  45212 Carvana 2021-N2 June 3, 2021  45213 Carvana 2021-N3 September 9, 2021  45214 Carvana 2021-N4 December 15, 2021  44221 Carvana 2022-P1 March 30, 2022  44222 Carvana 2022-P2 May 25, 2022  44223 Carvana 2022-P3 September 8, 2022  Page 8 of 8