**MANAGEMENT’S ASSERTION OF COMPLIANCE**

 

 

Management of the Trust &Agency Services department of Deutsche Bank National Trust Company and DeutscheBank Trust Company Americas (collectively the “Company”) is responsible for assessingthe servicing criteria set forth in Item 1122(d) of Regulation AB promulgatedby the Securities and Exchange Commission to determine which criteria areapplicable to the Company in respect of the servicing platform describedbelow.  Management has determined that the servicing criteria areapplicable in regard to the servicing platform as of and for the period asfollows:

 

Platform: Publicly-issued (*i.e*., transaction-level reporting required under theSecurities Exchange Act of 1934, as amended) and certain privately-issued (*i.e*.,for which transaction-level reporting is required pursuant to contractualobligation) residential mortgage-backed securities, commercial mortgage-backedsecurities and other asset-backed securities issued on or after January 1,2006,  for which the Company provides trustee, certificate administrator,securities administration, paying agent or custodian services, as defined inthe transaction agreements, excluding publicly-issued securities sponsored orissued by any government sponsored entity (the “Platform”). 

 

Applicable ServicingCriteria:  All servicing criteriaset forth in Item 1122(d), to the extent required by Item 1122(d) servicingcriteria in regards to the activities performed by the Company with respect tothe Platform as to any transaction, except for the following criteria:1122(d)(4)(iv) – 1122(d)(4)(xiv), which management has determined are notapplicable to the activities the Company performs with respect to the Platform(the “Applicable Servicing Criteria”).  With respect to ApplicableServicing Criteria 1122(d)(1)(ii), 1122(d)(1)(iii), 1122(d)(2)(iii) and1122(d)(4)(iii) there were no activities performed during the year endedDecember 31, 2018 with respect to the Platform, because there were no occurrencesof events that would require the Company to perform such activities. 

 

Period:  Year ended December 31, 2018 (the“Period”).

 

Management's interpretationof Applicable Servicing Criteria: The Company’s management has determined that servicing criterion1122(d)(1)(iii) is applicable only with respect to its continuing obligation toact as, or locate a, successor servicer under the circumstances referred to incertain transaction agreements.  It is management's interpretation thatthe Company has no other active back-up servicing responsibilities in regardsto servicing criterion 1122(d)(1)(iii) as of and for the Period.  TheCompany’s management has determined that servicing criterion 1122(d)(1)(v) isapplicable only to the activities the Company performs related to themathematically accurate aggregation of information received from servicers andthe accurate conveyance of such information within reports to investors. The Company’s management has determined that servicing criterion 1122(d)(4)(iii)is applicable to the activities the Company performs with respect to thePlatform only as it relates to the Company’s obligation to report additions,removals or substitutions on reports to investors in accordance with thetransaction agreements. 

 

With respect to the Platformas of and for the Period, the Company’s management provides the followingassertion of compliance with respect to the Applicable Servicing Criteria: 

 

·        The Company’s management is responsiblefor assessing the Company’s compliance with the Applicable Servicing Criteria.

 

·        The Company’s management has assessed compliance withthe Applicable Servicing Criteria.  In making this assessment, managementused the criteria set forth by the Securities and Exchange Commission inparagraph (d) of Item 1122 of Regulation AB.  

 

·        Based on such assessment, the Company hascomplied, in all material respects with the Applicable ServicingCriteria.  

 

KPMG LLP, an independentregistered public accounting firm, has issued an attestation report withrespect to management’s assertion of compliance with the Applicable ServicingCriteria as of and for the Period.

 

 

**DEUTSCHE BANK NATIONALTRUST COMPANY**

 

 

By: /s/ David Co

Name: David Co

Its: Director

 

By: /s/ Matt Bowen

Name: Matt Bowen

Its: Managing Director

 

By: /s/ Kevin Fischer

Name: Kevin Fischer

Its: Director

 

 

**DEUTSCHE BANK TRUST COMPANYAMERICAS**

 

 

By: /s/ David Co

Name: David Co

Its: Director

 

By: /s/ Jenna Kaufman

Name: Jenna Kaufman

Its: Director

 

 

Dated: February 28, 2019