**EXHIBIT 33.1**

 

**Report on Assessment of Compliance with Applicable Regulation AB Servicing Criteria**

 

1.              Ford Motor Credit Company LLC (“Ford Credit”) 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, 2012 (the “Reporting Period”), including all servicing criteria except for inapplicable servicing criteria identified in paragraph 4 below and the portions of servicing criteria covered by a separate assessment and identified in Appendix A to this report.  The transactions covered by this report include asset-backed securities transactions involving automotive retail installment sale contracts completed on or after January 1, 2006 and registered with the Securities Exchange Commission for which Ford Credit acted as servicer (the “Platform”).

 

2.              Ford Credit has engaged vendors that are not servicers as defined in Item 1101(j) of Regulation AB to perform specific, limited or scripted activities with respect to the servicing criteria applicable to such vendors’ activities as set forth in Appendix A to this report.  Ford Credit has elected to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to each vendor.  Ford Credit has policies and procedures in place to provide reasonable assurance that the vendors’ activities comply in all material respects with the servicing criteria or portion of the servicing criteria applicable to each vendor.

 

3.              Except as set forth in paragraph 4 below, Ford Credit used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria.

 

4.              The servicing criteria in Item 1122(d)(1)(iii),1122(d)(1)(iv), 1122(d)(2)(iii), 1122(d)(2)(v), 1122(d)(2)(vi), 1122(d)(3)(i)(D), 1122(d)(3)(iii), and 1122(d)(4)(ix) through 1122(d)(4)(xiii) are inapplicable to Ford Credit based on the activities it performs, directly or through its vendors (including indenture trustees), with respect to the Platform.

 

5.              Ford Credit has complied, in all material respects, with the applicable servicing criteria as of December 31, 2012 and for the Reporting Period with respect to the Platform taken as a whole.

 

6.              Ford Credit has not identified and is not aware of any material instance of noncompliance by the vendors with the applicable servicing criteria as of December 31, 2012 and for the Reporting Period with respect to the Platform taken as a whole.

 

7.              Ford Credit has not identified any material deficiency in its policies and procedures to monitor the compliance by the vendors with the applicable servicing criteria as of December 31, 2012 and for the Reporting Period with respect to the Platform taken as a whole.

 

8.              PricewaterhouseCoopers LLP, a registered public accounting firm, has issued an attestation report on Ford Credit’s assessment of compliance with the applicable servicing criteria for the Reporting Period.

 
| March 19,   2013 |   |                            |
|-----------------------|--------|---------------------------------|
|                  |   | Ford   Motor Credit Company LLC |
|                  |   |                            |
|                  |   |                            |
|                  |   | By:                             | /s/   Brian E. Schaaf |
|                  |   |                            | Brian   E. Schaaf |
|                  |   |                            | Vice   President and Assistant Treasurer |

 

----

 

APPENDIX A

Shared Servicing Criteria

 
| **Reference**  | ** ** | **Criteria**                                                                                                                                                                                                                                                 | ** ** | **Performed   Directly by Ford   Credit**                                 | ** ** | **Performed by   Vendor(s) for   which Ford   Credit is the   Responsible   Party** | ** ** | **Performed by Indenture   Trustee**              |
|----------------|------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-------------------------------------------------------------------------------------|------------|--------------------------------------------------------------------------------------------------------------|------------|-------------------------------------------------------------|
| 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                  |       | Paying   to indenture trustee                                                       |       |                                                                                                         |       | Depositing   to custodial bank accounts                     |
| 1122(d)(2)(ii) |       | Disbursements   made via wire transfer on behalf of an obligor or to an investor are made   only by authorized personnel                                                                                                                                     |       | Paying   to indenture trustee                                                       |       |                                                                                                         |       | Disbursing   to investors                                   |
| 1122(d)(2)(iv) |       | The   related accounts for the transaction, such as cash reserve accounts or   accounts established as a form of overcollateralization, are separately   maintained (e.g., with respect to commingling of cash) as set forth in the   transaction agreements |       | Providing   indenture trustee instructions for opening accounts for the transaction |       |                                                                                                         |       | Establishing   and maintaining accounts for the transaction |
| 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                                                                                         |       | Providing   indenture trustee instructions for making investor distributions        |       |                                                                                                         |       | Remitting   to investors                                    |
| 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                                                                                                               |       | Preparing   investor reports                                                        |       |                                                                                                         |       | Reconciling   remittances to investors                      |

 

1

----

 
| **Reference**  | ** ** | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                            | ** ** | **Performed   Directly by Ford   Credit**                                                                  | ** ** | **Performed by   Vendor(s) for   which Ford   Credit is the   Responsible   Party**                                      | ** ** | **Performed by Indenture   Trustee** |
|----------------|------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|----------------------------------------------------------------------------------------------------------------------|------------|---------------------------------------------------------------------------------------------------------------------------------------------------|------------|------------------------------------------------|
| 1122(d)(4)(i)  |       | Collateral   or security on pool assets is maintained as required by the transaction   agreements or related pool assets                                                                                                                                                                                                                                                                                                                |       | Maintaining   security on financed vehicles and obtaining retail installment sale contracts   from dealers           |       | Maintaining   possession of retail installment sale contracts for lien perfection 

 

Reviewing   financed vehicle titles for lien notation |       |                                           |
| 1122(d)(4)(ii) |       | Pool   assets and related documents are safeguarded as required by the transaction   agreements                                                                                                                                                                                                                                                                                                                                         |       | Safeguarding   of vehicle titles and documents related to retail installment sale contracts                          |       | Safeguarding   of retail installment sale contracts                                                                                               |       |                                           |
| 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 |       | Posting   all payments on pool assets to Ford Credit’s obligor records within two   business days after receipt |       | Transferring   of obligor payments received at lockbox to Ford Credit                                                                             |       |                                           |
| 1122(d)(4)(vi) |       | Changes   with respect to the terms or status of an obligor’s pool asset (e.g., loan   modifications or re-agings) are made, reviewed and approved by authorized   personnel in accordance with the transaction agreements and related pool   asset documents                                                                                                                                                                      |       | Making   most extensions, due date changes and related changes to obligor’s pool asset                          |       | Handling   some extensions and due date changes                                                                                                   |       |                                           |

 

2

----

 
| **Reference**    | ** ** | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ** ** | **Performed   Directly by Ford   Credit**                                                                   | ** ** | **Performed by   Vendor(s) for   which Ford   Credit is the   Responsible   Party**                       | ** ** | **Performed by Indenture   Trustee** |
|------------------|------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------------------------------------------------------------------------------|------------|------------------------------------------------------------------------------------------------------------------------------------|------------|------------------------------------------------|
| 1122(d)(4)(vii)  |       | Loss   mitigation or recovery actions (e.g., forbearance plans, modifications and   deeds in lieu or foreclosure, foreclosures and repossessions, as applicable)   are initiated, conducted and concluded in accordance with the timeframes or   other requirements established by the transaction agreements.                                                                                                                                                                                                                    |       | Approving   and processing all customer requests for re-writes and transfers of equity to   obligor’s pool asset |       | Researching   customer eligibility for some re-writes and transfers of equity on certain   categories of obligor’s pool asset |       |                                           |
| 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). |       | Performing   collection efforts on most delinquent pool assets                                                        |       | Performing   some early stage collection efforts on certain categories of delinquent pool   assets                                 |       |                                           |

 

3

----