**Exhibit 33.9**

**MANAGEMENT’S ASSERTION OF COMPLIANCE**

  

Management of the Agency and Trust division of Citibank, N.A. (or“Company”) is responsible for assessing compliance with the servicing criteria set forth in Item 1122(d) of RegulationAB promulgated by the Securities and Exchange Commission.

 

Management has determined that the servicing criteria set forthin Item 1122(d) of Regulation AB are applicable in regard to the servicing platform as of and for the period as follows:

 

Platform:  Publicly-issued (*i.e.*, transaction-levelreporting initially required under the Securities Exchange Act of 1934, as amended) and certain privately-issued (*i.e.*,for which transaction-level reporting is required pursuant to contractual obligation) commercial mortgage-backed securities issuedon or after January 1, 2011,as listed in Appendix A, for which the Company provides the following servicing functions (the “Platform”):

 

· paying agent, certificateadministration and trustee; or

· certificate administration and paying agent

 

Applicable Servicing Criteria: All servicing criteriaset forth in Item 1122(d), to the extent required by Item 1122(d) servicing criteria in regards to the activities performed bythe Company with respect to the Platform as to any transaction, except for the following servicing criteria: 1122(d)(1)(iii), 1122(d)(4)(i)-1122(d)(4)(ii)and 1122(d)(4)(iv)-1122(d)(4)(xv), which management has determined are not applicable to the activities the Company performs withrespect to the Platform (the “Applicable Servicing Criteria”). Servicing criterion 1122(d)(1)(v) is applicableto the activities the Company performs with respect to the Platform for all transactions in the Platform, including those issuedon or before November 23, 2015 for which compliance was previously assessed under other servicing criteria in accordance with theSEC Division of Corporation Finance’s *Manual of Publicly Available Interpretations on Regulation AB and Related Rules,Interpretation 11.03*, as applicable,  as of and for the twelve months ended December 31, 2015; provided further that,Management has determined that servicing criterion 1122(d)(1)(v) is applicable only to the activities the Company performs relatedto the mathematically accurate aggregation of information received from servicers and the accurate conveyance of such informationwithin reports to investors.  Servicing criterion 1122(d)(4)(iii) is applicable to the activities the Company performs withrespect to the Platform only as it relates to the Company’s obligation to report additions, removals or substitutions onreports to investors in accordance with the transaction agreements. With respect to servicing criteria 1122(d)(2)(iii) and 1122(d)(4)(iii),there were no activities performed during the twelve months ended December 31, 2015 with respect to the Platform, because therewere no occurrences of events that would require the Company to perform such activities.

 

Period:  Twelve months ended December 31, 2015 (the“Period”).

 

With respect to the Platform as of and for the Period, the Company’smanagement provides the following assertion of compliance with respect to the Applicable Servicing Criteria:

 

· The Company’s management is responsible for assessingthe Company’s compliance with the Applicable Servicing Criteria.

 

· The Company’s management has assessed compliancewith the Applicable Servicing Criteria.  In making this assessment, management used the criteria set forth by the Securitiesand Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.

 

· Based on such assessment, the Company has complied, in allmaterial respects, with the Applicable Servicing Criteria.

 

KPMG LLP, an independent registered public accounting firm, hasissued an attestation report with respect to management’s assertion of compliance with the Applicable Servicing Criteriaas of and for the Period.

  

**CITIBANK, N.A.**

By: /s/  Karen Montbach

Its: Managing Director

 

Dated: February 26, 2016

 

Appendix A

 

Mortgage-backed Transactions and Securities Constituting thePlatform

 

**DEAL NAME**

CGCMT 2015-GC29

CGBAM 2015-SMRT

CCMT 2013-375P

CCMT 2012-GC8

CCMT 2013-GCJ11

CCMT 2013-GC15

CCMT 2013-GC17

CCMT 2014-GC23

CCMT 2014-GC25

CCMT 2015-GC27

CCMT 2015-GC31

CCMT 2015-GC33

CCMT 2015-GC35

CCMT 2015-P1

CFCRE 2011-C2

GSMC 2011-GC3

GSMST-2011-GC5

MSBAM 2014-C17