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 yearended December 31, 2019 with the servicing criteria set forth in Item 1122 (d)of Regulation 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 responsible for assessing itscompliance with the servicing criteria applicable to it as noted on theaccompanying Exhibit A;

 

2.       Except as set forth in paragraph 3 below,U.S. Bank used the criteria set forth in paragraph (d) of Item 1122 of RegulationAB to assess its compliance with the applicable servicing criteria;

 

3.       The criteria listed in the column titled“Inapplicable Servicing Criteria” on Exhibit A hereto are inapplicable to U.S.Bank based on the servicing activities it performs directly with respect to thePlatform;

 

4.       U.S. Bank has complied, in all materialrespects, with the applicable servicing criteria as of and for the year endedDecember 31, 2019; and

 

5.       Ernst & Young, LLP, a registeredpublic accounting firm, has issued an attestation report on U.S. Bank’sassessment of compliance with the applicable servicing criteria as of and forthe 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 theperformance of servicing functions for which the Company provides trustee,securities administration, registrar, paying agent and document custodyservices for (i) publicly issued asset-backed and mortgage-backed transactionsthe securities of which were offered on or after January 1, 2006 and (ii)certain asset-backed transactions for which the Issuer has voluntarily electedto make Regulation AB compliant filings under the Securities Exchange Act of1934, as amended.

 

 

**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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | ** **

**X3**                |                                |
|  

**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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | ** **

**X4**                |                                |
|  

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.

3 No servicing activities wereperformed by the Company that required the servicing criteria to be compliedwith.

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

 

 

Corporate Trust ABS Platform(B)