**MANAGEMENT’S ASSERTION OFCOMPLIANCE**

 

 

Management of the Trust & Agency Servicesdepartment of Deutsche Bank National Trust Company and Deutsche Bank TrustCompany Americas (collectively the “Company”) is responsible for assessing theservicing criteria set forth in Item 1122(d) of Regulation AB promulgated bythe Securities and Exchange Commission to determine which criteria areapplicable to the Company in respect of the servicing platform describedbelow.  Management has determined that the servicing criteria areapplicable in regard to the servicing platform as of and for the period asfollows:

 

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”). 

 

ApplicableServicing Criteria:  Allservicing criteria set forth in Item 1122(d), to the extent required by Item1122(d) servicing criteria in regards to the activities performed by theCompany with respect to the Platform as to any transaction, except for thefollowing criteria: 1122(d)(4)(iv) – 1122(d)(4)(xiv), which management hasdetermined are not applicable to the activities the Company performs withrespect to the Platform (the “Applicable Servicing Criteria”).  With respectto 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 duringthe year ended December 31, 2017 with respect to the Platform, because therewere no occurrences of events that would require the Company to perform suchactivities. 

 

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

 

Management'sinterpretation of Applicable Servicing Criteria : The Company’s management has determined thatservicing criterion 1122(d)(1)(iii) is applicable only with respect to itscontinuing obligation to act as, or locate a, successor servicer under thecircumstances referred to in certain transaction agreements. It is management'sinterpretation that the Company has no other active back-up servicingresponsibilities in regards to servicing criterion 1122(d)(1)(iii) as of andfor the Period.  The Company’s management has determined that servicingcriterion 1122(d)(1)(v) is applicable only to the activities the Companyperforms related to the mathematically accurate aggregation of informationreceived from servicers and the accurate conveyance of such information withinreports to investors. The Company’s management has determined that servicingcriterion 1122(d)(4)(iii) is applicable to the activities the Company performswith respect 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 Platform as of and for the Period,the Company’s management provides the following assertion of compliance withrespect 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 Securitiesand Exchange 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 independent registered public accountingfirm, has issued an attestation report with respect to management’s assertionof compliance with the Applicable Servicing Criteria as of and for the Period.

 

 

**DEUTSCHE BANK NATIONAL TRUST 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 COMPANY AMERICAS**

 

By: /s/ David Co

Name: David Co

Its: Director

 

By: /s/ Jenna Kaufman

Name: Jenna Kaufman

Its: Director

 

Dated: February 28, 2018