**EXHIBIT 33.1**

 

**Report on Assessment of Compliance with Applicable Regulation AB Servicing Criteria**

 

1.              Ford Motor Credit Company LLC (“Ford Credit”) 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 year ended December 31, 2016 (the “Reporting Period”), including all servicing criteria except for inapplicable servicing criteria identified in paragraph 4 below and the portions of servicing criteria covered by a separate assessment and identified in Appendix A to this report.  The transactions covered by this report include asset-backed securities transactions involving automotive retail installment sale contracts completed on or after January 1, 2006 and registered with the Securities Exchange Commission for which Ford Credit acted as servicer (the “Platform”).

 

2.              Ford Credit has engaged vendors that are not servicers as defined in Item 1101(j) of Regulation AB to perform specific, limited or scripted activities with respect to the servicing criteria applicable to such vendors’ activities as set forth in Appendix A to this report.  Ford Credit has elected to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to each vendor.  Ford Credit has policies and procedures in place to provide reasonable assurance that the vendors’ activities comply in all material respects with the servicing criteria or portion of the servicing criteria applicable to each vendor.

 

3.              Except as set forth in paragraph 4 below, Ford Credit 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 servicing criteria in Item 1122(d)(1)(iii), 1122(d)(1)(iv), 1122(d)(2)(iii), 1122(d)(2)(vi), 1122(d)(3)(i)(D), 1122(d)(3)(iii), and 1122(d)(4)(ix) through 1122(d)(4)(xiii) are inapplicable to Ford Credit based on the activities it performs, directly or through its vendors (including indenture trustees), with respect to the Platform.

 

5.              Ford Credit has complied, in all material respects, with the applicable servicing criteria as of December 31, 2016 and for the Reporting Period with respect to the Platform taken as a whole.

 

6.              Ford Credit has not identified and is not aware of any material instance of noncompliance by the vendors with the applicable servicing criteria as of December 31, 2016 and for the Reporting Period with respect to the Platform taken as a whole.

 

7.              Ford Credit has not identified any material deficiency in its policies and procedures to monitor the compliance by the vendors with the applicable servicing criteria as of December 31, 2016 and for the Reporting Period with respect to the Platform taken as a whole.

 

8.              PricewaterhouseCoopers LLP, a registered public accounting firm, has issued an attestation report on Ford Credit’s assessment of compliance with the applicable servicing criteria for the Reporting Period.

 

March 21, 2017

 
|   | Ford   Motor Credit Company LLC |
|--------|---------------------------------|
|   |                            |
|   |                            |   |
|   | By:                             | /s/ Brian E. Schaaf |
|   |                            | Brian   E. Schaaf |
|   |                            | Vice   President and Assistant Treasurer |

 

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APPENDIX A

Shared Servicing Criteria

 
| **Reference**  | ** ** | **Criteria**                                                                                                                                                                                                                                               | ** ** | **Performed   Directly by Ford   Credit**                                 | ** ** | **Performed by   Vendor(s) for   which Ford   Credit is the   Responsible   Party** | ** ** | **Performed by Indenture   Trustee**              |
|----------------|------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-------------------------------------------------------------------------------------|------------|--------------------------------------------------------------------------------------------------------------|------------|-------------------------------------------------------------|
| 1122(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 of receipt, or such other number of days   specified in the transaction agreements                |       | Paying to indenture trustee                                                         |       |                                                                                                         |       | Depositing to custodial bank accounts                       |
| 1122(d)(2)(ii) |       | Disbursements made via wire transfer on behalf of an   obligor or to an investor are made only by authorized personnel                                                                                                                                     |       | Paying to indenture trustee                                                         |       |                                                                                                         |       | Disbursing to investors                                     |
| 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 |       | Providing indenture trustee instructions for opening   accounts for the transaction |       |                                                                                                         |       | Establishing and maintaining accounts for the   transaction |
| 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                                                                                       |       | Providing indenture trustee instructions for making   investor distributions        |       |                                                                                                         |       | Remitting to investors                                      |
| 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                                                                                                             |       | Preparing investor reports                                                          |       |                                                                                                         |       | Reconciling remittances to investors                        |

 

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| **Reference**  | ** ** | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                          | ** ** | **Performed   Directly by Ford   Credit**                                                                | ** ** | **Performed by   Vendor(s) for   which Ford   Credit is the   Responsible   Party**                                   | ** ** | **Performed by Indenture   Trustee** |
|----------------|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|--------------------------------------------------------------------------------------------------------------------|------------|------------------------------------------------------------------------------------------------------------------------------------------------|------------|------------------------------------------------|
| 1122(d)(4)(i)  |       | Collateral or security on pool assets is maintained   as required by the transaction agreements or related pool assets                                                                                                                                                                                                                                                                                                                |       | Maintaining security on financed vehicles and   obtaining retail installment sale contracts from dealers           |       | Maintaining possession of retail installment sale   contracts for lien perfection

 

Reviewing financed vehicle titles for lien notation |       |                                           |
| 1122(d)(4)(ii) |       | Pool assets and related documents are safeguarded as   required by the transaction agreements                                                                                                                                                                                                                                                                                                                                         |       | Safeguarding of vehicle titles and documents related   to retail installment sale contracts                        |       | Safeguarding of retail installment sale contracts                                                                                              |       |                                           |
| 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 |       | Posting all payments on pool assets to Ford Credit’s   obligor records within two business days after receipt |       | Transferring of obligor payments received at lockbox   to Ford Credit                                                                          |       |                                           |
| 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                                                                                                                                                                      |       | Making most extensions, due date changes and related   changes to obligor’s pool asset                        |       | Handling some extensions and due date changes                                                                                                  |       |                                           |

 

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| **Reference**    | ** ** | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** ** | **Performed   Directly by Ford   Credit**                                                                 | ** ** | **Performed by   Vendor(s) for   which Ford   Credit is the   Responsible   Party**                     | ** ** | **Performed by Indenture   Trustee** |
|------------------|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|---------------------------------------------------------------------------------------------------------------------|------------|----------------------------------------------------------------------------------------------------------------------------------|------------|------------------------------------------------|
| 1122(d)(4)(vii)  |       | Loss mitigation or recovery actions (e.g.,   forbearance plans, modifications and deeds in lieu or foreclosure,   foreclosures and repossessions, as applicable) are initiated, conducted and   concluded in accordance with the timeframes or other requirements established   by the transaction agreements.                                                                                                                                                                                                                  |       | Approving and processing all customer requests for   re-writes and transfers of equity to obligor’s pool asset |       | Researching customer eligibility for some re-writes   and transfers of equity on certain categories of obligor’s pool asset |       |                                           |
| 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). |       | Performing collection efforts on most delinquent   pool assets                                                      |       | Performing some early stage collection efforts on   certain categories of delinquent pool assets                                 |       |                                           |

 

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