**Exhibit 33.1**

**MANAGEMENT’S ASSERTION OF COMPLIANCE**

Management of the Trust & Securities Services department of Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas(collectively the “Company”) is responsible for assessing the servicing criteria set forth in Item 1122(d) of Regulation AB promulgated by the Securities and Exchange Commission to determine which criteria are applicable to theCompany in respect of the servicing platform described below. Management has determined that the servicing criteria are applicable in regard to the servicing platform as of and for the period as follows: 

Platform: Publicly-issued (*i.e.*, transaction-level reporting required under the Securities Exchange Act of 1934, as amended) and certainprivately-issued (*i.e.*, for which transaction-level reporting is required pursuant to contractual obligation) residential mortgage-backed securities, commercial mortgage-backed securities and other asset-backed securities issued on or afterJanuary 1, 2006, for which the Company provides trustee, certificate administrator, securities administration, paying agent or custodian services, as defined in the transaction agreements, excluding publicly-issued securities sponsored orissued by any government sponsored entity (the “Platform”). 

Applicable Servicing Criteria: All servicing criteria set forth inItem 1122(d), to the extent required by Item 1122(d) servicing criteria in regards to the activities performed by the Company with respect to the Platform as to any transaction, except for the followingcriteria: 1122(d)(4)(iv) – 1122(d)(4)(xiv), which management has determined are not applicable to the activities the Company performs with respect to the Platform (the “Applicable Servicing Criteria”). With respect toApplicable Servicing Criteria 1122(d)(1)(ii), 1122(d)(1)(iii) and 1122(d)(2)(iii) there were no activities performed during the year ended December 31, 2014 with respect to the Platform, because there were no occurrences of events thatwould require the Company to perform such activities. 

Period: Year ended December 31, 2014 (the “Period”). 

Management’s interpretation of Applicable Servicing Criteria: The Company’s management has determined that servicingcriterion 1122(d)(1)(iii) is applicable only with respect to its continuing obligation to act as, or locate a, successor servicer under the circumstances referred to in certain transaction agreements. It is management’s interpretation thatthe Company has no other active back-up servicing responsibilities in regards to servicing criterion 1122(d)(1)(iii) as of and for the Period. The Company’s management has determined that servicing criterion 1122(d)(4)(iii) isapplicable to the activities the Company performs with respect to the Platform only as it relates to the Company’s obligation to report additions, removals or substitutions on reports to investors in accordance 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 with respect to theApplicable Servicing Criteria: 

 

 

 

KPMG LLP, an independent registered public accounting firm, has issued an attestation report with respect to management’s assertion of compliance withthe 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/ Jenna Kaufman                Name: Jenna Kaufman                Its: Director
Dated: February 27, 2015