**EXHIBIT 33.1**

 

**Certification Regarding Compliance with Applicable Servicing Criteria**

 

1.             New Holland Credit Company, LLC (“New Holland”) is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-month period ending December 31, 2019 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report include publicly registered asset-backed securities transactions for which New Holland acted as servicer involving equipment receivables, other than transactions registered prior to compliance with Regulation AB (the “Platform”);

 

2.             New Holland has engaged certain vendors (the “Vendors”) to perform specific, limited or scripted activities, and New Holland elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors’ activities as set forth in Appendix A hereto;

 

3.             Except as set forth in paragraph 4 below, New Holland used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria;

 

4.             The criteria listed in the column titled “Inapplicable Servicing Criteria” on Appendix A hereto are inapplicable to New Holland based on the activities it performs, directly or through its Vendors, with respect to the Platform;

 

5.             New Holland has complied, in all material respects, with the applicable servicing criteria to it as set forth on Appendix A hereto as of December 31, 2019 and for the Reporting Period with respect to the Platform taken as a whole;

 

6.             New Holland has not identified and is not aware of any material instance of noncompliance by the Vendors with the applicable servicing criteria to them as set forth on Appendix A hereto as of December 31, 2019 and for the Reporting Period with respect to the Platform taken as a whole;

 

7.             New Holland has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors with the applicable servicing criteria to them as set forth on Appendix A hereto as of December 31, 2019 and for the Reporting Period with respect to the Platform taken as a whole;

 

8.             None of the Vendors are servicers as defined in Item 1101(j) of Regulation AB;

 

9.             New Holland has policies and procedures in place designed to provide reasonable assurance that the Vendors’ activities comply in all material respects with the servicing criteria applicable to such Vendors; and

 

10.          Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report on New Holland’s assessment of compliance with the applicable servicing criteria as set forth on Appendix A hereto as of December 31, 2019 and for the Reporting Period.

 

 
| March 23, 2020 |                              |
|---------------------|-----------------------------------|
|                |                              |
|                | New Holland Credit   Company, LLC |
|                |                              |
|                | By:                               | /s/ Carlo Alberto Sisto |
|                | Name:                             | Carlo Alberto Sisto |
|                | Title:                            | President |

 

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**APPENDIX A**

 
| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               |       | **Criteria**                                                                                                                                                                                                                                                            |       | **Performed   Directly   by   New   Holland** |   | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** |   | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | **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)(1)(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                                                                                                                                              |       | **X**                                         |   | **X** |   |   |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                      | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               |       | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                  |       | **Performed   Directly   by   New   Holland** |   | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** |   | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | more than two business days of receipt, or such   other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                               |       |                                          |   |   |   |   |
| 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   overcollateralization, 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** |
| 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   (A) are mathematically accurate; (B) are                                                                                                                                                        |       | **X**                                         |   |   |   |   |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               |       | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |       | **Performed   Directly   by   New   Holland** |   | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** |   | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | prepared within 30 calendar days after the bank   statement cutoff date, or such other number of days specified in the   transaction agreements; (C) are 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.                                                                                                                                                                                                                  |       | ** **                                    |   |   |   |   |
|                        |       |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |       |                                          |   |   |   |   |
|                        |       | **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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |       | **X**                                         |   |   |   |   |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                               | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               |       | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                           |       | **Performed   Directly   by   New   Holland** |   | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** |   | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | agreements.                                                                                                                                                                                                                                                                                                                                                                                                                            |       | ** **                                    |   |   |   |   |
| 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**                                         |   | **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   applicable 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                                                                                                                                                                                                                                                                                    |       | **X**                                         |   |   |   |   |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               |       | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |       | **Performed   Directly   by   New   Holland** |   | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** |   | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |       | ** **                                    |   |   |   |   |
| 1122(d)(4)(vi)         |       | Changes with respect to the terms or status of an   obligor’s pool asset (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                                                                                                                                                                                                                                                                                                                |       |                                          |   |   |   | **X** |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                  | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               |       | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                              |       | **Performed   Directly   by   New   Holland** |   | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** |   | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | 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 asset, or such other number of days   specified in the transaction agreements.       |       |                                          |   |   |   |   |
| 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 uncollectable   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                                                                                                                                                                                                                                                                                                                                           |       |                                          |   |   |   | **X** |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                    | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|-----------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               |       | **Criteria**                                                                                                                |       | **Performed   Directly   by   New   Holland** |   | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** |   | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | 1114(a)(1) through (3) or Item 1115 of   Regulation AB, is maintained as set forth in the transaction agreements. |       |                                          |   |   |   |   |

 

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