Management's Assertion

 

Report on Assessment of Compliance with ApplicableServicing Criteria

 

 

U.S. Bank National Association(“U.S. Bank”) is responsible for assessing compliance as of and for the year endedDecember 31, 2019 with the servicing criteria set forth in Item 1122 (d) ofRegulation AB applicable to it as set forth on Exhibit A hereto. This reportcovers asset backed securities transactions within the **U.S. Bank CorporateTrust Asset-Backed Securities Platform1 (the “Platform”)**

 

U.S. Bank hereby provides thefollowing report on its assessment of compliance with the servicing criteriaset forth in Item 1122 of Regulation AB applicable to it and as described onExhibit A hereto:

 

1.        U.S. Bank is responsiblefor assessing its compliance with the servicing criteria applicable to it asnoted on the accompanying Exhibit A;

 

2.        Except as set forth inparagraph 3 below, U.S. Bank used the criteria set forth in paragraph (d) ofItem 1122 of Regulation AB to assess its compliance with the applicableservicing criteria;

 

3.        The criteria listed in thecolumn titled “Inapplicable Servicing Criteria” on Exhibit A hereto areinapplicable to U.S. Bank based on the servicing activities it performsdirectly with respect to the Platform;

 

4.        U.S. Bank has complied, inall material respects, with the applicable servicing criteria as of and for theyear ended December 31, 2019; and

 

5.        Ernst & Young, LLP, aregistered public accounting firm, has issued an attestation report on U.S.Bank’s assessment of compliance with the applicable servicing criteria as ofand for the year ended December 31, 2019.

 

 

U.S BANK NATIONAL ASSOCIATION

 

 

/s/ Joseph Giordano

Name: Joseph Giordano

Title: Executive VicePresident

 

 

Date: February 27, 2020

 

 

1 The U.S. Bank Corporate Trust Asset-Backed SecuritiesPlatform (the "Platform") consists of the activities involved in the performanceof servicing functions for which the Company provides document custody servicesfor (i) publicly issued asset-backed and mortgage-backed transactions thesecurities of which were offered on or after January 1, 2006 and (ii) certainasset-backed transactions for which the Issuer has voluntarily elected to makeRegulation AB compliant filings under the Securities Exchange Act of 1934, asamended.

 

 

**EXHIBIT A to Management’sAssertion**

 

| **Reference**                          | **Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | **Applicable**

**Servicing Criteria** | **Inapplicable**

**Servicing Criteria** |
|----------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------|------------------------------------------|
| **General Servicing Considerations**   |
|  

1122(d)(1)(i)                  |  

Policies and procedures are  instituted to monitor any performance or other triggers and events of default  in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                   | ** **

**X**                        |
|  

1122(d)(1)(ii)                 |  

If any material servicing  activities are outsourced to third parties, policies and procedures are  instituted to monitor the third party’s performance and compliance with such  servicing activities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **

**X2**                     |                                     |
|  

1122(d)(1)(iii)                |  

Any requirements in the  transaction agreements to maintain a back-up servicer for the Pool Assets are  maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                   | ** **

**X**                        |
|  

1122(d)(1)(iv)                 |  

A fidelity bond and errors  and omissions policy is in effect on the party participating in the servicing  function throughout the reporting period in the amount of coverage required  by and otherwise in accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**                      |                                     |
|  

1122(d)(1)(v)                  |  

Aggregation of information,  as applicable, is mathematically accurate and the information conveyed  accurately reflects the information.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                   | ** **

**X**                        |
| **Cash Collection and Administration** |
|  

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 following receipt, or such  other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                   | ** **

**X**                        |
|  

1122(d)(2)(ii)                 |  

Disbursements made via wire  transfer on behalf of an obligor or to an investor are made only by  authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |                                   | ** **

**X**                        |
|  

1122(d)(2)(iii)                |  

Advances of funds or  guarantees regarding collections, cash flows or distributions, and any  interest or other fees charged for such advances, are made, reviewed and  approved as specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |                                   | ** **

**X**                        |
|  

1122(d)(2)(iv)                 |  

The related accounts for the  transaction, such as cash reserve accounts or accounts established as a form  of over collateralization, are separately maintained (e.g., with respect to  commingling of cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                   | ** **

**X**                        |
|  

1122(d)(2)(v)                  |  

Each custodial account is  maintained at a federally insured depository institution as set forth in the  transaction agreements. For purposes of this criterion, “federally insured  depository institution” with respect to a foreign financial institution means  a foreign financial institution that meets the requirements of Rule  13k-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                              |                                   | ** **

**X**                        |
|  

1122(d)(2)(vi)                 |  

Unissued checks are  safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                   | ** **

**X**                        |
|  

1122(d)(2)(vii)                |  

Reconciliations are prepared  on a monthly basis for all asset-backed securities related bank accounts,  including custodial accounts and related bank clearing accounts. These  reconciliations are (A) mathematically accurate; (B) prepared within 30  calendar days after the bank statement cutoff date, or such other number of  days specified in the transaction agreements; (C) reviewed and approved by  someone other than the person who prepared the reconciliation; and (D)  contain explanations for reconciling items. These reconciling items are  resolved within 90 calendar days of their original identification, or such  other number of days specified in the transaction agreements. |                                   | ** **

**X**                        |
| **Investor Remittances and Reporting** |
|  

1122(d)(3)(i)                  |  

Reports to investors,  including those to be filed with the Commission, are maintained in accordance  with the transaction agreements and applicable Commission requirements.  Specifically, such reports (A) are prepared in accordance with timeframes and  other terms set forth in the transaction agreements; (B) provide information  calculated in accordance with the terms specified in the transaction  agreements; (C) are filed with the Commission as required by its rules and  regulations; and (D) agree with investors’ or the trustee’s records as to the  total unpaid principal balance and number of Pool Assets serviced by the  Servicer.                                  |                                   | ** **

**X**                        |
|  

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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                   | ** **

**X**                        |
|  

1122(d)(3)(iii)                |  

Disbursements made to an  investor are posted within two business days to the Servicer’s investor  records, or such other number of days specified in the transaction  agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                   | ** **

**X**                        |
|  

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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                   | ** **

**X**                        |
| **Pool Asset Administration**          |
|  

1122(d)(4)(i)                  |  

Collateral or security on  pool assets is maintained as required by the transaction agreements or  related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X**                      |                                     |
|  

1122(d)(4)(ii)                 |  

Pool assets and related  documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **

**X**                      |                                     |
|  

1122(d)(4)(iii)                |  

Any additions, removals or substitutions  to the asset pool are made, reviewed and approved in accordance with any  conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **

**X**                      |                                     |
|  

1122(d)(4)(iv)                 |  

Payments on pool assets,  including any payoffs, made in accordance with the

related pool asset documents  are posted to the 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.                                                                                                                                                                                                                                                                                      |                                   | ** **

**X**                        |
|  

1122(d)(4)(v)                  |  

The Servicer’s records  regarding the pool assets agree with the Servicer’s records with respect to  an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |                                   | ** **

**X**                        |
|  

1122(d)(4)(vi)                 |  

Changes with respect to the  terms or status of an obligor's pool assets (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.                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                   | ** **

**X**                        |
|  

1122(d)(4)(vii)                |  

Loss mitigation or recovery  actions (e.g., forbearance plans, modifications and deeds in lieu of  foreclosure, foreclosures and repossessions, as applicable) are initiated,  conducted and concluded in accordance with the timeframes or other  requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                    |                                   | ** **

**X**                        |
|  

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).                                                                                                                                                                                   |                                   | ** **

**X**                        |
|  

1122(d)(4)(ix)                 |  

Adjustments to interest rates  or rates of return for pool assets with variable rates are computed based on  the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                   | ** **

**X**                        |
|  

1122(d)(4)(x)                  |  

Regarding any funds held in  trust for an obligor (such as escrow accounts): (A) such funds are analyzed,  in accordance with the obligor’s pool asset documents, on at least an annual  basis, or such other period specified in the transaction agreements; (B)  interest on such funds is paid, or credited, to obligors in accordance with  applicable pool asset documents and state laws; and (C) such funds are  returned to the obligor within 30 calendar days of full repayment of the  related pool assets, or such other number of days specified in the  transaction agreements.                                                                                                           |                                   | ** **

**X**                        |
|  

1122(d)(4)(xi)                 |  

Payments made on behalf of an  obligor (such as tax or insurance payments) are made on or before the related  penalty or expiration dates, as indicated on the appropriate bills or notices  for such payments, provided that such support has been received by the  servicer at least 30 calendar days prior to these dates, or such other number  of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                          |                                   | ** **

**X**                        |
|  

1122(d)(4)(xii)                |  

Any late payment penalties  in connection with any payment to be made on behalf of an obligor are paid  from the Servicer’s funds and not charged to the obligor, unless the late  payment was due to the obligor’s error or omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                   | ** **

**X**                        |
|  

1122(d)(4)(xiii)               |  

Disbursements made on behalf  of an obligor are posted within two business days to the obligor’s records  maintained by the servicer, or such other number of days specified in the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                   | ** **

**X**                        |
|  

1122(d)(4)(xiv)                |  

Delinquencies, charge-offs  and uncollectible accounts are recognized and recorded in accordance with the  transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                   | ** **

**X**                        |
|  

1122(d)(4)(xv)                 |  

Any external enhancement or  other support, identified in Item 1114(a)(1) through (3) or Item 1115 of  Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                   | ** **

**X**                        |

 

2 No servicing activities were performed by the Companythat required the servicing criteria to be complied with

 

 

Corporate Trust ABS Platform(C)