Management’s
Assertion



Report
on Assessment of Compliance with Applicable Servicing Criteria



U.S.
Bank National Association (“U.S. Bank”) is responsible for assessing compliance as of and for the year ended 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 report covers asset backed securities transactions within the U.S. Bank Corporate Trust Asset-Backed Securities Platform1(the “Platform”)



U.S.
Bank hereby provides the following report on its assessment of compliance with the servicing criteria set forth in Item 1122 of
Regulation AB applicable to it and as described on Exhibit A hereto:



| | 1. | U.S.
                                         Bank is responsible for assessing its compliance with the servicing criteria applicable
                                         to it as noted on the accompanying 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 Regulation AB 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 the Platform;
| | -- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 4. | U.S.
                                         Bank has complied, in all material respects, with the applicable servicing criteria as
                                         of and for the year ended December 31, 2019; and
| | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 5. | Ernst
                                         & Young, LLP, a registered public accounting firm, has issued an attestation report
                                         on U.S. Bank’s assessment of compliance with the applicable servicing criteria
                                         as of and for the year ended December 31, 2019.
| | -- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | U.S. BANK NATIONAL ASSOCIATION 
| | -------------------------------
| |                                
| | /s/ Joseph Giordano            
| | Name: Joseph Giordano          
| | Title: Executive Vice President



Date:
February 27, 2020










1The U.S. Bank Corporate Trust Asset-Backed Securities Platform (the “Platform”) consists of the activities involved
in the performance of servicing functions for which the Company provides trustee, securities administration, registrar, paying
agent and document custody services for (i) publicly issued asset-backed and mortgage-backed transactions the securities of which
were offered on or after January 1, 2006 and (ii) certain asset-backed transactions for which the Issuer has voluntarily elected
to make Regulation AB compliant filings under the Securities Exchange Act of 1934, as amended.











EXHIBIT
A to Management’s Assertion

|Reference                                                                   | Servicing
    Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | ApplicableServicingCriteria | InapplicableServicingCriteria
|--------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------- | -----------------------------
|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                           |                              








2No servicing activities were performed by the Company that required the servicing criteria to be complied with.

3No servicing activities were performed by the Company that required the servicing criteria to be complied with.

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





Corporate Trust ABS Platform (B)1







|Reference                          | Servicing
    Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ApplicableServicingCriteria | InapplicableServicingCriteria
|---------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------- | -----------------------------
|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                            





Corporate Trust ABS Platform (B)2







|Reference        | Servicing
    Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | Applicable
    
Servicing 
Criteria | InapplicableServicingCriteria
|---------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------- | -----------------------------
|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                                   |                              



Corporate Trust ABS Platform (B)3