Exhibit 33.2



MANAGEMENT’S ASSESSMENT OF COMPLIANCE



Management of the Agency and Trust division of Citibank, N.A.
(or “Company”) is responsible for assessing compliance with the servicing criteria set forth in Item 1122(d)
of Regulation AB promulgated by the Securities and Exchange Commission.



Management has determined that the servicing criteria in Item
1122(d) of Regulation AB are applicable in regard to the servicing platform as of and for the period as follows:



Platform: Publicly-issued (i.e., transaction-level
reporting initially required under the Securities Exchange Act of 1934, as amended) and certain privately-issued (i.e.,
for which transaction-level reporting is required pursuant to contractual obligation) automobile loan or lease-backed securities,
equipment loan-backed securities and student loan-backed securities issued on or after January 1, 2006, as listed in Appendix A,
for which the Company provides trustee and paying agent services (the “Platform”).



Applicable Servicing Criteria: All servicing
criteria set forth in Item 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, except for the following servicing criteria: 1122(d)(1)(i)-1122(d)(1)(v), 1122(d)(2)(iii),
1122(d)(2)(vi)-1122(d)(2)(vii), 1122(d)(3)(i) and 1122(d)(4)(i)-1122(d)(4)(xv), which management has determined are not applicable
to the activities the Company performs with respect to the Platform (the “Applicable Servicing Criteria”). With respect
to the Platform, Applicable Servicing Criterion 1122(d)(3)(ii) is applicable only as it relates to remittances.



Period: Twelve months ended December 31, 2019
(the “Period”).



With respect to the Platform as of and for the Period, the Company’s
management provides the following assessment of compliance with respect to the Applicable Servicing Criteria:



| | · | The Company’s management is responsible for assessing the Company’s compliance with the Applicable Servicing Criteria.
| | - | ----------------------------------------------------------------------------------------------------------------------



| | · | The Company’s management has assessed compliance with the Applicable Servicing Criteria. In making this assessment, management
used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · | Based on such assessment, the Company has complied, in all material respects, with the Applicable Servicing Criteria.
| | - | ---------------------------------------------------------------------------------------------------------------------



KPMG LLP, an independent registered public accounting firm,
has issued an attestation report with respect to management’s assessment of compliance with the Applicable Servicing Criteria
as of and for the Period.



| | CITIBANK, N.A. |                  
| | -------------- | -----------------
| |                |                  
| | By:            | Karen Montbach   
| |                |                  
| | Its:           | Managing Director



Dated: February 21, 2020











Appendix A



Asset-backed
Transactions and Securities Constituting the Platform



DEAL NAME

|ACOLT ABF Credit Facility                                                                                                                                                                                                                                      | 
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | 
|AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2014-2                                                                                                                                                                                                                | 
|AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2014-3                                                                                                                                                                                                                | 
|AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2015-2                                                                                                                                                                                                                | 
|AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2015-3                                                                                                                                                                                                                | 
|AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2016-2                                                                                                                                                                                                                | 
|AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2016-3                                                                                                                                                                                                                | 
|AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2017-2                                                                                                                                                                                                                | 
|AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2017-3
        AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2018-2
        AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2018-3
        AMERICREDIT AUTOMOBILE RECEIVABLES TRUST 2019-3
        BMW Vehicle Lease Trust 2016-2 | 
|HART 2015-A                                                                                                                                                                                                                                                    | 
|HART 2015-B                                                                                                                                                                                                                                                    | 
|HART 2015-C                                                                                                                                                                                                                                                    | 
|HART 2016-A                                                                                                                                                                                                                                                    | 
|HART 2016-B                                                                                                                                                                                                                                                    | 
|HART 2017-A                                                                                                                                                                                                                                                    | 
|HART 2017-B
        HART 2018-A
        HART 2018-B
        HART 2019-A
        HART 2019-B
        SLC 2006-A                                                                                                                                                 | 
|VALET 2018-1
        VALT 2019-A
        Drive Auto Receivables Trust 2019-2                                                                                                                                                                                   |