Exhibit 33.1
 
  Platform
 Applicable Servicing Criteria
  Period
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The Bank of New York Mellon
    
    
    
    The Bank of New York MellonThe Bank of New York Mellon Trust Company, N.A.
    
    
    
    The Bank of New York Mellon Trust Company, N.A.BNY Mellon Trust of Delaware/s/ Robert L. Griffin

Robert L. Griffin
    
    
    
    /s/ Patrick J. Tadie

Patrick J. TadieAuthorized Officer
    
    
    
    Authorized Officer
  /s/ Samir Pandiri

Samir PandiriAuthorized Officer
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Payments on pool assets are deposited into the appropriate custodial bank accounts
and related bank clearing accounts no more than two business days of receipt, or such other number
of days specified in the transaction agreements.
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APPLICABLE TO
    
    NOT APPLICABLEREG AB REFERENCE
    
    SERVICING CRITERIA
    
    PLATFORM
    
    TO PLATFORMGeneral Servicing Considerations1122(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.
    
    X1122(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.
    
    
    
    X1122(d)(1)(iii)
    
    Any requirements in the
transaction agreements to
maintain a back-up servicer for
the pool assets are maintained.
    
    
    
    X1122(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.
    
    
    
    XCash Collection and Administration1122(d)(2)(i)
    
    Payments on pool assets are
deposited into the appropriate
custodial bank accounts and
related bank clearing accounts no
more than two business days
following receipt, or such other
number of days specified in the
transaction agreements.
    
    X1122(d)(2)(ii)
    
    Disbursements made via wire
transfer on behalf of an obligor
or to an investor are made only
by authorized personnel.
    
    X1122(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.
    
    X1122(d)(2)(iv)
    
    The related accounts for the
transaction, such as cash reserve
accounts or accounts established
as a form of over
collateralization, are separately
maintained (e.g., with respect to
commingling of cash) as set forth
in the transaction agreements.
    
    X1122(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.
    
    X1122(d)(2)(vi)
    
    Unissued checks are safeguarded
so as to prevent unauthorized
access.
    
    X1122(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 are (A)
mathematically accurate; (B)
prepared within 30 calendar days
after the bank statement cutoff
date, or such other number of
days specified in the transaction
agreements; (C) 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
    
    X
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APPLICABLE TO
    
    NOT APPLICABLEREG AB REFERENCE
    
    SERVICING CRITERIA
    
    PLATFORM
    
    TO PLATFORMInvestor Remittances and Reporting1122(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.
    
    X1122(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 agreements.
    
    X1122(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.
    
    X1122(d)(3)(iv)
    
    Amounts remitted to investors per
the investor reports agree with
cancelled checks, or other form
of payment, or custodial bank
statements
    
    XPool Asset Administration1122(d)(4)(i)
    
    Collateral or security on pool
assets is maintained as required
by the transaction agreements or
related mortgage loan documents.
    
    X1122(d)(4)(ii)
    
    pool asset and related documents
are safeguarded as required by
the transaction agreements
    
    X1122(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.
    
    X1122(d)(4)(iv)
    
    Payments on pool assets,
including any payoffs, made in
accordance with the related pool
asset documents are posted to the
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.
    
    X1122(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
balance.
    
    X1122(d)(4)(vi)
    
    Changes with respect to the terms
or status of an obligors pool
assets (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.
    
    
    
    X1122(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
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APPLICABLE TO
    
    NOT APPLICABLEREG AB REFERENCE
    
    SERVICING CRITERIA
    
    PLATFORM
    
    TO PLATFORM1122(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).
    
    
    
    X1122(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.
    
    X1122(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 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 assets, or such
other number of days specified in
the transaction agreements.
    
    
    
    X1122(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.
    
    
    
    X1122(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.
    
    
    
    X1122(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.
    
    
    
    X1122(d)(4)(xiv)
    
    Delinquencies, charge-offs and
uncollectible accounts are
recognized and recorded in
accordance with the transaction
agreements.
    
    
    
    X1122(d)(4)(xv)
    
    Any external enhancement or other
support, identified in Item
1114(a)(1) through (3) or Item
1115 of Regulation AB, is
maintained as set forth in the
transaction agreements
    
    X
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