**Exhibit 33.9**

MANAGEMENT’S ASSERTION ON 

COMPLIANCE WITH REGULATION AB CRITERIA 

For Wells Fargo Bank, National Association, as Master Servicer 

Principal Global Investors, LLC, in its capacity as Primary Servicer (the “Asserting Party”) is responsible for assessing compliancefor the transactions listed on Attachment A for the period January 1, 2015 through December 31, 2015, except as noted on Attachment A (the “Reporting Period”) with the servicing criteria set forth in Title 17,Section 229.1122(d) of the Code of Federal Regulations (the “CFR”), except for the criteria set forth in Sections 229.1122(d)(1)(ii)-(iii), 229.1122(d)(3)(i)— (iv), 229.1122(d)(4)(ix), and 229.1122(d)(4)(xv), in the CFR, whichthe Asserting Party has concluded are not applicable to the servicing of the transactions listed on Attachment A, backed by commercial mortgage loans and primarily serviced by the Asserting Party (the “Applicable Servicing Criteria”). 

The Asserting Party has assessed compliance with the Applicable Servicing Criteria for the Reporting Period and has concluded that theAsserting Party has complied, in all material respects, with the Applicable Servicing Criteria for the transactions listed on Attachment A backed by commercial mortgages primarily serviced by the Asserting Party. 

With respect to servicing criteria 1122(d)(1)(i) and 1122(d)(4)(i) (the “Criteria”), the Asserting Party has engaged various vendorsto perform certain activities required by these Criteria. The Asserting Party has determined that none of these vendors are considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Asserting Party has elected totake responsibility for assessing compliance with these servicing criteria applicable to each vendor as permitted by Interpretation 17.06 of the SEC Division of Corporation Finance Manual of Publicly Available Telephone Interpretations(Interpretation 17.06). As permitted by Interpretation 17.06, the Asserting Party has asserted that it has policies and procedures in place designed to provide reasonable assurance that the vendors’ activities comply in all material respectswith the servicing criteria applicable to each vendor. The Asserting Party is solely responsible for determining that it meets the SEC requirements to apply Interpretation 17.06 for the vendors and related criterion as described herein. 

Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report on the assessment of compliancewith the Applicable Servicing Criteria for the Reporting Period as set forth in this assertion. 

Principal Global Investors, LLC, as Primary Servicer 

 

Date: 2/17/16 

**Attachment A**

Commercial Mortgage Pass-Through Certificates 

Wells Fargo Bank, National Association, as Master Servicer 

Series 1999-LIFE1 dated August 1, 1999 

Series 2000-PRINdated September 1, 2000 

Series 2001-TOP1 dated February 1, 2001 

Series 2001-TOP2 dated May 1, 2001 

Series 2001-TOP3 datedJuly 1, 2001 

Series 2001-TOP4 dated November 1, 2001 

Series 2001-TOP5 dated December 1, 2001 

Series 2002-TOP6dated March 1, 2002 

Series 2002-TOP7 dated June 1, 2002 

Series 2002-TOP8 dated October 1, 2002 

Series 2003-Top9dated February 1, 2003 

Series 2003-Top10 dated April 1, 2003 

Series 2003-Top11 dated August 1, 2003 

Series 2003-Top12dated October 1, 2003 

Series 2004-Top13 dated February 1, 2004 

Series 2004-Top14 dated April 1, 2004 

Series 2004-Top15dated July 1, 2004 

Series 2004-1Q8 dated August 1, 2004 

Series 2004-Top16 dated November 1, 2004 

Series 2005-Top17dated January 1, 2005 

Series 2005-IQ9 dated February 1, 2005 

Series 2005-Top18 dated April 1, 2005 

Series 2005-PWR 8dated June 1, 2005 

Series 2005-Top19 dated July 1, 2005 

Series 2005-PWR9 dated September 2005 

Series 2005-Top20 datedOctober 1, 2005 

Series 2005 HQ7 dated November 1, 2005 

Series 2005 PWR10 dated December 1, 2005 

Series 2006-Top21dated January 1, 2006 

Series 2006 PWR11 dated March 1, 2006 

Series 2006-Top22 dated April 1, 2006 

Series 2006 PWR12dated June 1, 2006 

Series 2006-Top23 dated August 1, 2006 

Series 2006-HQ9 dated August 1, 2006 

Series 2006 PWR13dated September 1, 2006 

Series 2006-Top24 dated October 1, 2006 

Series 2006 PWR14 dated December 1, 2006 

Series 2007 Top25dated January 30, 2007 

Series 2007 PWR15 dated March 29, 2007 

Series 2007 Top26 dated April 18, 2007 

Series 2007 PWR16dated June 27, 2007 

Series 2007 Top27 dated July 30, 2007 

Series 2007 PWR17 dated September 27, 2007 

Series 2007Top28 dated October 25, 2007 

Series 2007 PWR18 dated December 27, 2007 

Series 2008 Top 29 dated February 29, 2008 

Series 2011 C-2dated March 1, 2011 

Series 2011 C-3 dated June 1, 2011 

Series 2011 C-4 dated August 1, 2011 

Series 2011 C-5 datedNovember 1, 2011 

Series 2012 C-8 dated August 1, 2012 

Series 2012 C-9 dated October 1, 2012 

Series 2012 C10 datedDecember 1, 2012 

Series 2013 C11 dated February 1, 2013 

Series 2013 C13 dated May 1, 2013 

Series 2013 C17 datedNovember 1, 2013 

Series 2014 – FL1 dated January 1, 2014 

Series 2014 - LC14 dated February 1, 2014 

Series 2014 -LC16 dated June 1, 2014 

Series 2014 - C19 dated March 1, 2014 

Series 2014 - C21 dated August 1, 2014 

Series 2015 - C27dated March 1, 2015 

Series 2015 - P1 dated August 1, 2015 

Series 2015 - P2 dated December 1, 2015