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**MANAGEMENT’S ASSERTION OFCOMPLIANCE**

 

Management of the Trust &Agency Services department of Deutsche Bank National Trust Company and DeutscheBank Trust Company Americas (collectively the “Company”) is responsible for assessingthe servicing criteria set forth in Item 1122(d) of Regulation AB promulgatedby the Securities and Exchange Commission to determine which criteria areapplicable to the Company in respect of the servicing platform described below.Management has determined that the servicing criteria are applicable in regardto the servicing platform as of and for 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 Company providestrustee, certificate administrator, securities administration, paying agent orcustodian services, as defined in the transaction agreements, excludingpublicly-issued securities sponsored or issued by any government sponsoredentity (the “Platform”).

 

Applicable ServicingCriteria: All servicing criteria setforth in Item 1122(d), to the extent required by Item 1122(d) servicingcriteria in regards to the activities performed by the Company with respect tothe Platform as to any transaction, except for the following criteria:1122(d)(4)(iv) – 1122(d)(4)(xiv), which management has determined are notapplicable to the activities the Company performs with respect to the Platform(the “Applicable Servicing Criteria”). With respect to Applicable ServicingCriteria 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, 2019 withrespect to the Platform, because there were no occurrences of events that wouldrequire the Company to perform such activities.

 

Period: Year ended December 31, 2019 (the “Period”).

 

Management's interpretationof Applicable Servicing Criteria: TheCompany’s management has determined that servicing criterion 1122(d)(1)(iii) isapplicable only with respect to its continuing obligation to act as, or locatea, successor servicer under the circumstances referred to in certaintransaction agreements. It is management's interpretation that the Company hasno other active back-up servicing responsibilities in regards to servicingcriterion 1122(d)(1)(iii) as of and for the Period. The Company’s managementhas determined that servicing criterion 1122(d)(1)(v) is applicable only to theactivities the Company performs related to the mathematically accurateaggregation of information received from servicers and the accurate conveyanceof such information within reports to investors. The Company’s management hasdetermined that servicing criterion 1122(d)(4)(iii) is applicable to theactivities the Company performs with respect to the Platform only as it relatesto the Company’s obligation to report additions, removals or substitutions onreports to investors in accordance 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 making thisassessment, management used the criteria set forth by the Securities andExchange Commission in paragraph (d) of Item 1122 of Regulation AB.

 

∙ Based on such assessment, theCompany has complied, in all material respects with the Applicable ServicingCriteria.

 

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 NATIONAL TRUSTCOMPANY

 

By: /s/ David Co

Name: David Co

Its : Director

 

By: /s/ Matt Bowen

Name: Matt Bowen

Its: Managing Direction

 

By: /s/ Christopher Corcoran

Name: Christopher Corcoran

Its: Director

 

 

DEUTSCHE BANK TRUST COMPANYAMERICAS

 

By: /s/ David Co

Name: David Co

Its : Director

 

Dated: February 28, 2020