Exhibit 35.1
ALLY FINANCIAL INC.
500 Woodward Ave
Detroit, Michigan 48226
As of December 31, 2016
| Deutsche Bank Trust Company Americas | BNY Mellon Trust of Delaware |
| As Indenture Trustee | As Owner Trustee |
| 100 Plaza One - MS: JCY03-0699 | 100 White Clay Center, Suite 102, |
| Jersey City, New Jersey 07311-3901 | Newark, DE 19711 |
| Attn: Capital Auto Receivables Asset Trust 2016-3 | |
Copy To:
| The Bank of New York Mellon Trust Company, N.A. | Capital Auto Receivables LLC |
| 2 North LaSalle Street, Suite 1020 | 500 Woodward Ave. |
| Chicago, IL 60602 | Mail code: MI-01-20-TRES |
| Attention: Structured Finance Services CARAT 2016-3 | Detroit, MI 48226 |
| Attention: Ryan Farris | |
| Re: | Capital Auto Receivables Asset Trust 2016-3 |
| Annual Statement as to Compliance | |
Ladies and Gentlemen:
Reference is made to Section 4.01 of the Trust Sale and Servicing Agreement dated as of September 21, 2016 between the Issuer, Ally Financial Inc., as Servicer, Custodian, and Seller (“Servicer”), and Capital Auto Receivables LLC, as Depositor.
The undersigned does hereby certify that:
| a. | A review of the activities of the Servicer during the period of September 21, 2016 through December 31, 2016, and of its performance under the Trust Sale and Servicing Agreement and the Pooling and Servicing Agreement has been made under his supervision; and |
| b. | To the best of his knowledge, based on such review, the Servicer has fulfilled in all material respects all its obligations under the Trust Sale and Servicing Agreement and the Pooling and Servicing Agreement throughout such period. |
| Very truly yours, | ||
| /s/ David J. DeBrunner | ||
| David J. DeBrunner | ||
| Vice President, Controller and Chief Accounting Officer | ||