**Exhibit 33.2**

 

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 October 31, 2016 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 Platform****1 (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 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 October 31, 2016; 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 October 31, 2016.

 

 
|   | U.S. BANK NATIONAL ASSOCIATION    |
|--------|-----------------------------------|
|   |                              |
|   | /s/ Bryan R. Calder               |   |
|   | Name: Bryan R. Calder             |   |
|   | Title: Executive Vice   President |

 

Date: January 10, 2017

 

 

 

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1 The 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 and paying agent services for (i) publicly issued asset-backed and mortgage-backed securities 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.

 

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**EXHIBIT A to Management’s Assertion**

 
| **Reference**                                                    | **Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                                        | **Applicable   Servicing   Criteria**

** ** | **Inapplicable   Servicing   Criteria** |
|------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------|-----------------------------------------|
| ** **

**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)(I)(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.                                                                                                                                                                                                                                                                                                 | ** **                                        | ** **

**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.

                                                                                                                                                                                                                                                                    | ** **                                        | ** **

**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.

                                                                                                                                                                                                                                                                                      |  

**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.

                                                                                                                                                                                |                                              |  

**X**                           |
|  

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**                           |

 
| Corporate Trust ABS   Platform | 1

  |   |
|--------------------------------|-----------|--------|

 

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| **Reference**                                        | **Servicing   Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | **Applicable   Servicing   Criteria**

** ** | **Inapplicable   Servicing   Criteria** |
|------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------|-----------------------------------------|
|  

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 | 2

  |   |
|--------------------------------|-----------|--------|

 

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| **Reference**                 | **Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | **Applicable   Servicing   Criteria** | **Inapplicable   Servicing   Criteria** |
|-------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|-----------------------------------------|
|  

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 | 3

  |   |
|--------------------------------|-----------|--------|

 

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