Capital One Auto Receivables LLC Files Legal, Tax Opinions for Auto Notes

What Happened Capital One Auto Receivables, LLC filed a Form 8-K on September 11, 2026, to provide unqualified legal and tax opinions delivered by Mayer Brown LLP in connection with the public issuance of Class A-2-A, Class A-2-B, Class A-3 and Class A-4 auto loan asset-backed notes by Capital One Prime Auto Receivables Trust 2026-1. The notes were issued in the initial principal amounts specified in the Prospectus dated September 9, 2026. The opinions are attached as Exhibits 5.1 (legality) and 8.1 (tax).

Key Details

• Filing date: September 11, 2026; Prospectus date: September 9, 2026.
• Notes issued by: Capital One Prime Auto Receivables Trust 2026-1 (Classes A-2-A, A-2-B, A-3, A-4).
• Exhibits attached: Mayer Brown LLP legal opinion (Exhibit 5.1) and tax opinion (Exhibit 8.1).
• Purpose: Filing satisfies the registrant’s undertaking to file unqualified legality and tax opinions at each takedown under the Registration Statement.

Why It Matters This filing provides the formal legal and tax confirmations required for the public issuance of the specified asset-backed notes. For investors and market participants, the delivery of unqualified opinions by counsel is a standard closing condition that helps confirm the notes’ legal validity and tax treatment as described in the prospectus — an important procedural step in completing the securitization offering.