Exhibit
33.1



Report
on Assessment of Compliance with Applicable Servicing Criteria of Mercedes-Benz Financial Services USA LLC



1.        
Mercedes-Benz Financial Services USA LLC is responsible for assessing compliance with the servicing criteria applicable to it
set forth in paragraph (d) of Item 1122 of Regulation AB as of December 31, 2019 and for the period from January 1, 2019, through
December 31, 2019 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report
include publicly issued asset-backed securities transactions involving United States consumer automotive lease contracts for which
Mercedes-Benz Financial Services USA LLC acts as servicer (the “Platform”).



2.        
Mercedes-Benz Financial Services USA LLC has engaged certain vendors, which are not servicers as defined by Item 1101(j) of Regulation
AB (the “Vendors”), to perform specific, limited or scripted activities, and Mercedes-Benz Financial Services USA
LLC elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable
to such Vendors’ activities as set forth in Appendix A hereto as permitted by Interpretation 17.06 of the SEC Division of
Corporation Finance Manual of Publicly Available Telephone Interpretations;



3.
        Mercedes-Benz Financial Services USA LLC has determined that the criteria in the
column titled “Inapplicable Servicing Criteria” on Appendix A hereto (collectively, the “Inapplicable Servicing
Criteria”) are not applicable to Mercedes-Benz Financial Services USA LLC based on the activities Mercedes-Benz Financial
Services USA LLC performs directly or through its Vendors with respect to the Platform. The criteria set forth in paragraph (d)
of Item 1122 of Regulation AB other than the Inapplicable Servicing Criteria are referred to as the “Applicable Servicing
Criteria”;



4.        
Mercedes-Benz Financial Services USA LLC has complied, in all material respects, with the Applicable Servicing Criteria as of
December 31, 2019, and for the Reporting Period with respect to the Platform taken as a whole, except as described in Appendix
B hereto;



5.        
Mercedes-Benz Financial Services USA LLC 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, 2019, and for the Reporting Period with respect to the Platform
taken as a whole;



6.        
Mercedes-Benz Financial Services USA LLC 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, 2019, and for the Reporting Period with
respect to the Platform taken as a whole; and



7.        
Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation report on Mercedes-Benz Financial
Services USA LLC’s compliance with the Applicable Servicing Criteria as of December 31, 2019, and for the Reporting Period.



March
19, 2020





|Mercedes-Benz Financial Services USA LLC |                              
|---------------------------------------- | -----------------------------
|                                         |                              
|By:                                      | /s/
Brian T. Stevens         
|                                         | Brian
T. Stevens             
|                                         | Vice
President and Controller



1







APPENDIX
A



|SERVICING
        CRITERIA | APPLICABLE
        
SERVICING CRITERIA                                                                                                                                                                                                                            | INAPPLICABLE
        
SERVICING
        CRITERIA
|-------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------
|                           |                                                                                                                                                                                                                                                                   |                                                 
|                           |                                                                                                                                                                                                                                                                   |                                                 
|                           |                                                                                                                                                                                                                                                                   |                                                 
|                           |                                                                                                                                                                                                                                                                   |                                                 
|                           |                                                                                                                                                                                                                                                                   |                                                 
|                           |                                                                                                                                                                                                                                                                   |                                                 
|                           |                                                                                                                                                                                                                                                                   |                                                 
|                           |                                                                                                                                                                                                                                                                   |                                                 
|                           |                                                                                                                                                                                                                                                                   |                                                 
|                           |                                                                                                                                                                                                                                                                   | Performed                                       
|                           |                                                                                                                                                                                                                                                                   | By                                              
|Reference                  | Criteria                                                                                                                                                                                                                                                          | Servicer                                        
|                           | 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.                                                              | X                                               
|1122(d)(1)(iii)            | Any
requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                 |                                                 
|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. |                                                 
|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.                                                                                                                                             | X1                                              
|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                  | X2                                              
|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.             | X                                               












1Not applicable to obligor disbursements.



2No occurrences during the Reporting Period.





2







|SERVICING
        CRITERIA | APPLICABLE
        
SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | INAPPLICABLE
    
SERVICING 
CRITERIA
|-------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | -------------------------------------
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                      
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|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | Performed                            
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | By                                   
|Reference                  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | Servicer                             
|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 240.13k-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                                                                                          |                                      
|1122(d)(2)(vi)             | Unissued
    checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                      
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | X3                                   








3Mercedes-Benz Financial Services USA LLC’s responsibility in regard to criterion 1122 (d)(3)(iii) is limited to amounts
remitted to Indenture Trustee (as defined in the transaction agreements), rather than the investor, as set forth in the transaction
agreements. The Indenture Trustee has provided a Report on Compliance with Applicable Servicing Criteria pursuant to Item 1122
of Regulation AB under the Securities and Exchange Act of 1934.





3







|SERVICING
        CRITERIA | APPLICABLE
        
SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | INAPPLICABLE
    
SERVICING 
CRITERIA
|-------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Performed                            
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | By                                   
|Reference                  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Servicer                             
|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 mortgage loan 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.                                                                                                                                                                                                                                                                                                                            | X4                                   
|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.                                                                                                                                                                                                                                                                                                                                                                      | X5                                   
|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                                    








4No occurrences during the Reporting Period.



5Investor reporting is based on the securitized value of the pool assets.





4







|SERVICING
        CRITERIA | APPLICABLE
        
SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | INAPPLICABLE
    
SERVICING 
CRITERIA
|-------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | -------------------------------------
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                      
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | Performed                            
|                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | By                                   
|Reference                  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | Servicer                             
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                         |                                      
|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 asset, or such other number of
days specified in the transaction agreements. |                                      
|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.                                                                                                                                                                                      |                                      
|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.                                                                                                                                                                                                                                                                                                                                                  |                                      
|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.                                                                                                                                                                                                                                                                                                                                                                            |                                      
|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.                                                                                                                                                                                                                                                                                                                                                                                                        |                                      





5







APPENDIX
B



Material
Instance of Noncompliance



Management’s
assessment of compliance with the Applicable Servicing Criteria set forth by the Securities and Exchange Commission in paragraph
(d) of Item 1122 of Regulation AB as of December 31, 2019 and for the Reporting Period, disclosed the following material instance
of noncompliance with servicing criterion 1122(d)(4)(vii).



| | ● | In
                                         regard to one account, the Servicer, Mercedes-Benz Financial Services USA LLC (“MBFS”),
                                         failed to send a pre-repo notice within the timeframe required by MBFS policy.
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



Management
Response



MBFS
follows applicable law in the provision of pre-repo notices. For the account in question, the pre-repo notice was sent four business
days late because MBFS did not document in its portfolio system that approval for repossession had been obtained. MBFS’s
procedures have been revised to clarify the requirements for documenting repossession approvals in MBFS’s portfolio system.





6