January 11, 2006
| Mayer, Brown, Rowe & Maw LLP 71 South Wacker Drive Chicago, Illinois 60606-4637
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Jon D. Van Gorp Direct Tel (312) 701-7091 Direct Fax (312) 706-8362 jvangorp@mayerbrownrowe.com | |
| VIA FAX (202-772-9202) | ||
Ms. Sara W. Dunton, Senior Attorney Office of Structured Finance, Transportation and Leisure Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 | ||
| Re: | Capital One Auto Receivables, LLC Registration Statement on Form S-3 File No. 333-128722, filed on 9/30/2005 |
Dear Ms. Dunton:
On behalf of Capital One Auto Finance, Inc. (“Capital One”), as sponsor and sole equity owner of Capital One Auto Receivables, LLC, this letter responds to your request to confirm, and Capital One does hereby confirm, that the references to “other property securing the receivable” in the registration statement refers to property that (1) isde minimis in nature when compared to the other specifically enumerated property which secures the receivable and (2) is not a type of property that is not permitted to be included pursuant to the terms of Regulation AB.
The primary property that secures each receivable is the financed vehicle. The “other property securing the receivable” catchall is used in the underlying securitization transaction documents, as well as the prospectus disclosure, to ensure that all incidental property securing the receivable is included as part of the assets of the issuing entity.
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Mayer, Brown, Rowe & Maw LLP operates in combination with our associated English limited liability partnership in the offices listed above.
Mayer, Brown, Rowe & Maw LLP
Ms. Sara W. Dunton
January 11, 2006
Page 2
Should you have any questions about this letter, please do not hesitate to contact Amy Moorhus Baumgardner of Capital One at (703) 720-2290 or me at (312) 701-7091.
| Respectfully submitted, |
| Jon D. Van Gorp |
cc: Amy Baumgardner, Esq. (Capital One Financial Corporation)