MANAGEMENT’S
ASSERTION OF COMPLIANCE



Management
of the Trust & Agency Services department of Deutsche Bank National Trust
Company and Deutsche Bank Trust Company Americas (collectively the “Company”) is
responsible for assessing the servicing criteria set forth in Item 1122(d) of
Regulation AB promulgated by the Securities and Exchange Commission to determine
which criteria are applicable to the Company in respect of the servicing
platform described below. Management has determined that the servicing criteria
are applicable in regard to the servicing platform as of and for the period as
follows:



Platform: Publicly-issued (i.e.,
 transaction-level reporting 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)
residential mortgage-backed securities, commercial mortgage-backed securities
and other asset-backed securities issued on or after January 1, 2006, for which
the Company provides trustee, certificate administrator, securities
administration, paying agent or custodianservices, as defined in the
transaction agreements, excluding publicly-issued securities sponsored or issued
by any government sponsored entity(the “Platform”).



Applicable
Servicing Criteria: All servicing criteria set forth in Item 1122(d), to the
extent required by Item 1122(d) servicing criteria in regards to the activities
performed by the Company with respect to the Platform as to any transaction,
except for the following criteria: 1122(d)(4)(iv) – 1122(d)(4)(xiv), which
management has determined are not applicable to the activities the Company
performs with respect to the Platform (the “Applicable Servicing Criteria”).
With respect to Applicable Servicing Criteria 1122(d)(1)(ii), 1122(d)(1)(iii),
1122(d)(2)(iii) and 1122(d)(4)(iii) there were no activities performed during
the year ended December 31, 2017 with respect to the Platform, because there
were no occurrences of events that would require the Company to perform such
activities.



Period:
Year ended December 31, 2017 (the “Period”).



Management’s
interpretation of Applicable Servicing Criteria: The Company’s management
has determined that servicing criterion 1122(d)(1)(iii) is applicable only with
respect to its continuing obligation to act as, or locate a, successor servicer
under the circumstances referred to in certain transaction agreements. It is
management’s interpretation that the Company has no other active back-up
servicing responsibilities in regards to servicing criterion 1122(d)(1)(iii) as
of and for the Period. The Company’s management has determined that servicing
criterion 1122(d)(1)(v) is applicable only to the activities the Company
performs related to the mathematically accurate aggregation of information
received from servicers and the accurate conveyance of such information within
reports to investors. The Company’s management has determined that servicing
criterion 1122(d)(4)(iii) is applicable to the activities the Company performs
with respect to the Platform only as it relates to the Company’s obligation to
report additions, removals or substitutions on reports to investors in
 accordance with the transaction agreements.



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



| | · | The

             Company’s
                                                                   management

                                               is responsible

                               for assessing

              the Company’s

      compliance
                                                             with the

                                       Applicable

                   Servicing

      Criteria.                                                                                                                                                                                                                                                                                          
| | - | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
| |   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
| | · | The

      Company’s management
                                                         has assessed compliance

                                    with the Applicable

           Servicing Criteria.
                                                             In making this
      assessment,
                                                management used the

                       criteria set forth by
                                                                           the
      Securities and Exchange
                                                            Commission in
      paragraph
                                              (d) of Item 1122 of

                     Regulation AB.
| |   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
| | · | Based
                                                                            on
      such assessment,
                                                     the Company has complied,

                                  in all material respects

              with the Applicable
                                                                Servicing
      Criteria.                                                                                                                                                                                                                                                                                                                                                    



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















|                               | DEUTSCHE
      BANK NATIONAL TRUST COMPANY
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|                               | DEUTSCHE
      BANK TRUST COMPANY AMERICAS
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|Dated:
      February 28, 2018 |