EXHIBIT 33.2



MANAGEMENT’S REPORT ON ASSESSMENT OF COMPLIANCE
WITH SEC
REGULATION AB SERVICING CRITERIA



MUFG Union Bank, N.A. (the
 “Bank”), a wholly-owned subsidiary of MUFG Americas Holdings Corporation, provides this assessment of compliance with
the following applicable servicing criteria set forth in Item 1122(d) of Regulation AB Servicing Criteria as set forth on
Exhibit A hereto. Management has determined that the servicing criteria are applicable regarding the servicing platform for the
period as follows:



Platform:
Those publicly issued asset-backed transactions the securities of which were issued on or after January 1, 2006 and backed by automobile
loan and/or lease assets for which, in connection with the transaction agreements, the Bank provided (a) trustee and paying agent
services during the Principal Period (as defined below) and (b) sub-trustee and sub-paying agent services as delegate of U.S. Bank
National Association (the successor trustee and the successor paying agent) during the Delegation Period (as defined below) (the “Platform”).



Applicable
Servicing Criteria: All servicing criteria set forth in Item 1122(d), to the extent required in the related transaction agreements
or required by the Item 1122(d) servicing criteria in regards to the activities performed by the Bank, except for the following criteria:
1122(d) 1(i), 1(ii), 1(iii), 1(iv), 1(v) 2(i), 2(iii), 2(vi), 2(vii), 3(i), 3(ii) (allocation of amounts due to investors),
4(i), 4(ii), 4(iii), 4(iv), 4(v), 4(vi), 4(vii), 4(viii), 4(ix),4(x), 4(xi), 4(xii), 4(xiii), 4(xiv), and 4(xv), which management has
determined are not applicable to the activities the Bank performs with respect to the Platform (the “Applicable Servicing Criteria”).



Period:
For the period from January 1, 2021 through March 14, 2021 (the “Principal period”) and for the period from March 15,
2021 (the effective date of the sale, as it relates to the Platform, of MUFG Union Bank, N.A.’s Corporate Trust Debt Servicing division
to U.S. Bank National Association) to August 02, 2021 (the “Delegation Period” and, collectively with the Principal Period,
the “Period”.)



With respect to the Platform and the Period, the
Bank provides the following assessment of compliance with respect to the Applicable Servicing Criteria:



| | 1. | The Bank is responsible for assessing its compliance with the Applicable Servicing Criteria.
| | -- | --------------------------------------------------------------------------------------------



| | 2. | The Bank has assessed compliance with the Applicable Servicing Criteria, as described above as of and
for the Period. In performing this assessment, management has used the criteria set by the Securities and Exchange Commission in paragraph
(d) of Item 1122 of Regulation AB.
| | -- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 3. | With respect to servicing criterion 1122(d)(3)(ii), the Bank is not responsible for allocating amounts
due to investors.
| | -- | ------------------------------------------------------------------------------------------------------------------------



| | 4. | The Bank was in compliance with the Applicable Servicing Criteria as of and for the Period in all material
respects.
| | -- | --------------------------------------------------------------------------------------------------------------------













Deloitte & Touche LLP, an independent
registered public accounting firm, has issued an attestation report with respect to the Bank’s foregoing assessment of compliance
as of and for the Period.



MUFG UNION BANK, N.A.





|By: | /s/ Kaori Noda Sipes |  | By: | /s/ Charles D Present
|--- | -------------------- |  | --- | ---------------------

|Kaori Noda Sipes
Director, Head of Institutional Agency Services Client
Support Transaction Banking |  |  | Charles D Present
 Managing Director, Transaction Banking of the
 Americas
|--------------------------------------------------------------------------------------------------- |  |  | --------------------------------------------------------------------------







February 9, 2022













|Exhibit A to Management’s Assertion
|-----------------------------------
|Reference                          
|General Servicing Considerations   
|1122(d)(1)(i)                      
|1122(d)(1)(ii)                     
|1122(d)(1)(iii)                    
|1122(d)(1)(iv)                     
|1122(d)(1)(v)                      
|Cash Collection and Administration 
|1122(d)(2)(i)                      
|1122(d)(2)(ii)                     
|1122(d)(2)(iii)                    













|1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                               | 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 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
|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 agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | X(only as to remittances) |  













|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
|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 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 balance.                                                                                                                                                                                                                                                                    |   | X
|1122(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.                                                                                                                                                      |   | 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 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. |  | X
|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 uncollectible 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 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements. |  | X