EXHIBIT 33.5

MANAGEMENTS ASSERTION OF COMPLIANCE

Management of the Agency and Trust division of
Citibank, N.A. (or Company) is responsible for assessing compliance with the servicing criteria set forth in Item 1122(d) of Regulation AB promulgated by the Securities and Exchange Commission.

Management has determined that the servicing criteria set forth in Item 1122(d) of Regulation AB are applicable in regard to the servicing platform
for the period as follows:

Platform: Publicly-issued (i.e., transaction-level reporting initially required under the
Securities Exchange Act of 1934, as amended) and certain privately issued (i.e., for which transaction-level reporting is required pursuant to contractual obligation) commercial mortgage-backed securities issued on or after January 1, 2011, for
which the Company provides the following servicing functions (the Platform):



| |  |  | paying agent, certificate administration and trustee; or
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| |  |  | certificate administration and paying agent
| | - |  | -------------------------------------------

Applicable Servicing Criteria: All servicing criteria set forth in Item 1122(d), to the extent required by Item 1122(d) servicing criteria in regards to the activities performed by the
Company with respect to the Platform as to any transaction, except for the following servicing criteria: 1122(d)(1)(iii), 1122(d)(4)(i)-1122(d)(4)(ii) and 1122(d)(4)(iv)-1122(d)(4)(xv), which management has determined are not applicable to the
activities the Company performs with respect to the Platform (the Applicable Servicing Criteria). With respect to criteria 1122(d)(2)(iii) and 1122(d)(4)(iii), there were no activities performed during the twelve months ended
December 31, 2011 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.

Period: Twelve months ended December 31, 2011 (the Period).

With respect
to the Platform as of and for the Period, the Companys management provides the following assertion of compliance with respect to the Applicable Servicing Criteria:



| |  |  | The Companys management is responsible for assessing the Companys compliance with the Applicable Servicing Criteria.
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| |  |  | The Companys management has assessed compliance with the Applicable Servicing Criteria. In making this assessment, management used the criteria
set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.
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| |  |  | Based on such assessment, the Company has complied, in all material respects, with the Applicable Servicing Criteria.
| | - |  | ---------------------------------------------------------------------------------------------------------------------

KPMG LLP, an independent registered public accounting firm, has issued an attestation report with respect to managements assertion of compliance
with the Applicable Servicing Criteria as of and for the Period.



CITIBANK, N.A.By:

/s/ Karen MontbachIts:

Managing Director


Dated: February 28, 2012