EXHIBIT 33.2





MANAGEMENT’S REPORT ON ASSESSMENT
OF COMPLIANCE WITH SEC

REGULATION AB SERVICING CRITERIA





MUFG Union Bank, N.A. (the “Bank”),
a wholly-owned subsidiary of MUFG Americas Holdings Corporation, provides this assessment of compliance with the following applicable
servicing criteria set forth in Item 1122(d) of Regulation AB Servicing Criteria as set forth on Exhibit A hereto. Management has
determined that the servicing criteria are applicable regarding the servicing platform for the period as follows:



Platform: Those publicly issued
asset-backed transactions the securities of which were issued on or after January 1, 2006 and backed by automobile loan and/or
lease assets for which the Bank provides trustee and paying agent services, as defined in the transaction agreements (the “Platform”).



Applicable Servicing Criteria: All
servicing criteria set forth in Item 1122(d), to the extent required in the related transaction agreements or required by the Item
1122(d) servicing criteria in regards to the activities performed by the Bank, except for the following criteria: 1122(d) 1(i),
1(ii), 1(iii), 1(iv), 1(v) 2(i), 2(iii), 2(vi), 2(vii), 3(i), 3(ii) (allocation of amounts due to investors), 4(i), 4(ii), 4(iii),
4(iv), 4(v), 4(vi), 4(vii), 4(viii), 4(ix),4(x), 4(xi), 4(xii), 4(xiii), 4(xiv), and 4(xv), which management has determined are
not applicable to the activities the Bank performs with respect to the Platform (the “Applicable Servicing Criteria”).



Period: As of December 31, 2019,
and for the period from January 1, 2019 to December 31, 2019 (the “Period”).

With respect to the Platform and the Period,
the Bank provides the following assessment of compliance with respect to the Applicable Servicing Criteria:

1. The Bank is responsible for assessing
its compliance with the Applicable Servicing Criteria.
2. The Bank has assessed compliance with
the Applicable Servicing Criteria, as described above as of and for the Period. In performing this assessment, management has used
the criteria set by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.
3. With respect to servicing criterion 1122(d)(3)(ii),
the Bank is not responsible for allocating amounts due to investors.
4. The Bank was in compliance with the Applicable
Servicing Criteria as of and for the Period in all material respects.



Deloitte & Touche LLP, an independent registered public
accounting firm, has issued an attestation report with respect to the Bank’s foregoing assessment of compliance as of and
for the Period.



MUFG UNION BANK, N.A.



By: /s/ Evelyn T. Furukawa

Evelyn T. Furukawa

Director, Head of Corporate Trust Client Account Management



By: /s/ Susana Ryan
Susana Ryan
Director, Head of GTS Business Controls & Governance



February 21, 2020













|Exhibit A to Management’s Assertion
|-----------------------------------
|Reference                          
|General Servicing Considerations   
|1122(d)(1)(i)                      
|1122(d)(1)(ii)                     
|1122(d)(1)(iii)                    
|1122(d)(1)(iv)                     
|1122(d)(1)(v)                      
|Cash Collection and Administration 
|1122(d)(2)(i)                      
|1122(d)(2)(ii)                     
|1122(d)(2)(iii)                    
|1122(d)(2)(iv)                     
|1122(d)(2)(v)                      
|1122(d)(2)(vi)                     
|1122(d)(2)(vii)                    















|Investor Remittances and Reporting
|----------------------------------
|1122(d)(3)(i)                     
|1122(d)(3)(ii)                    
|1122(d)(3)(iii)                   
|1122(d)(3)(iv)                    
|Pool Asset Administration         
|1122(d)(4)(i)                     
|1122(d)(4)(ii)                    
|1122(d)(4)(iii)                   
|1122(d)(4)(iv)                    
|1122(d)(4)(v)                     
|1122(d)(4)(vi)                    
|1122(d)(4)(vii)                   
|1122(d)(4)(viii)                  
|1122(d)(4)(ix)                    
|1122(d)(4)(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