**MANAGEMENT’S ASSERTION OFCOMPLIANCE**

 

 

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

 

Platform:  Publicly-issued *(i.e.*, transaction-levelreporting required under the Securities Exchange Act of 1934, as amended) andcertain privately-issued *(i.e.*, for which transaction-level reporting isrequired pursuant to contractual obligation) residential mortgage-backedsecurities, commercial mortgage-backed securities and other asset-backedsecurities issued on or after January 1, 2006,  for which the Companyprovides trustee, certificate administrator, securities administration, payingagent or custodian services, as defined in the transaction agreements,excluding publicly-issued securities sponsored or issued by any governmentsponsored entity (the “Platform”). 

 

Applicable Servicing Criteria:  All servicing criteria set forth in Item1122(d), to the extent required by Item 1122(d) servicing criteria in regardsto the activities performed by the Company with respect to the Platform as toany transaction, except for the following criteria: 1122(d)(4)(iv) –1122(d)(4)(xiv), which management has determined are not applicable to theactivities the Company performs with respect to the Platform (the “ApplicableServicing Criteria”).  With respect to Applicable Servicing Criteria1122(d)(1)(ii), 1122(d)(1)(iii), 1122(d)(2)(iii) and 1122(d)(4)(iii) there wereno activities performed during the year ended December 31, 2016 with respect tothe Platform, because there were no occurrences of events that would requirethe Company to perform such activities. 

 

Period:  Year ended December 31, 2016 (the “Period”).

 

Management's interpretationof Applicable Servicing Criteria: The Company’s management has determined that servicing criterion1122(d)(1)(iii) is applicable only with respect to its continuing obligation toact as, or locate a, successor servicer under the circumstances referred to incertain transaction agreements.  It is management's interpretation thatthe Company has no other active back-up servicing responsibilities in regardsto servicing criterion 1122(d)(1)(iii) as of and for the Period.  TheCompany’s management has determined that servicing criterion 1122(d)(1)(v) isapplicable only to the activities the Company performs related to themathematically accurate aggregation of information received from servicers andthe accurate conveyance of such information within reports to investors. The Company’s management has determined that servicing criterion1122(d)(4)(iii) is applicable to the activities the Company performs withrespect to the Platform only as it relates to the Company’s obligation toreport additions, removals or substitutions on reports to investors inaccordance with the transaction agreements. 

 

With respect to the Platformas of and for the Period, the Company’s management provides the followingassertion of compliance with respect to the Applicable Servicing Criteria: 

 

• The Company’s management isresponsible for assessing the Company’s compliance with the ApplicableServicing Criteria.

 

• The Company’s management hasassessed compliance with the Applicable Servicing Criteria.  In makingthis assessment, management used the criteria set forth by the Securities andExchange Commission in paragraph (d) of Item 1122 of Regulation AB.  

 

• Based on such assessment,the Company has complied, in all material respects with the ApplicableServicing Criteria.  

 

KPMG LLP, an independentregistered public accounting firm, has issued an attestation report withrespect to management’s assertion of compliance with the Applicable ServicingCriteria as of and for the Period.

 

 

**DEUTSCHE BANK NATIONALTRUST COMPANY**

 

 

By: /s/ David Co

Name: David Co

Its: Director

 

By: /s/ Matt Bowen

Name: Matt Bowen

Its: Managing Director

 

By: /s/ Kevin Fischer

Name: Kevin Fischer

Its: Director

 

 

**DEUTSCHE BANK TRUST COMPANYAMERICAS**

 

 

By: /s/ David Co

Name: David Co

Its: Director

 

By: /s/ Jenna Kaufman

Name: Jenna Kaufman

Its: Director

 

 

Dated: February 24, 2017