**Exhibit 33.2**

 

Management’s Assertion

 

Report on Assessment of Compliance with Applicable Servicing Criteria

 

U.S. Bank National Association (“U.S. Bank”) is responsible for assessing compliance as of and for the year ended December 31, 2016 with the servicing criteria set forth in Item 1122 (d) of Regulation AB applicable to it as set forth on  Exhibit A hereto.  This report covers asset backed securities transactions within the **U.S. Bank Corporate Trust Asset-Backed Securities Platform(1) (the “Platform”)**

 

U.S. Bank hereby provides the following report on its assessment of compliance with the servicing criteria set forth in Item 1122 of Regulation AB applicable to it and as described on Exhibit A hereto:

 

1.              U.S. Bank is responsible for assessing its compliance with the servicing criteria applicable to it as noted on the accompanying Exhibit A;

 

2.              Except as set forth in paragraph 3 below, U.S. Bank used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess its compliance with the applicable servicing criteria;

 

3.              The criteria listed in the column titled “Inapplicable Servicing Criteria” on Exhibit A hereto are inapplicable to U.S. Bank based on the servicing activities it performs directly with respect to the Platform;

 

4.              U.S. Bank has complied, in all material respects, with the applicable servicing criteria as of and for the year ended December 31, 2016; and

 

5.              Ernst & Young, LLP, a registered public accounting firm, has issued an attestation report on U.S. Bank’s assessment of compliance with the applicable servicing criteria as of and for the year ended December 31, 2016.

 

 
|   | U.S. BANK NATIONAL   ASSOCIATION |
|--------|----------------------------------|
|   |                             |
|   |                             |
|   | /s/ Joseph Giordano              |
|   | Name: Joseph Giordano            |
|   | Title: Senior Vice   President   |

 

 

Date:  February 28, 2017

 

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(1)  The U.S. Bank Corporate Trust Asset-Backed Securities Platform (the “Platform”) consists of the activities involved in the performance of servicing functions for which the Company provides trustee, securities administration, registrar and paying agent services for (i) publicly issued asset-backed and mortgage-backed transactions the securities of which were offered on or after January 1, 2006 and (ii) certain asset-backed transactions for which the Issuer has voluntarily elected to make Regulation AB compliant filings under the Securities Exchange Act of 1934, as amended.

 

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**EXHIBIT A to Management’s Assertion**

 
| **Reference**   | ** ** | **Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                   | ** ** | **Applicable   Servicing   Criteria** | ** ** | **Inapplicable   Servicing   Criteria** |
|-----------------|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|---------------------------------------|------------|-----------------------------------------|
| ** **      | ** ** | ** **                                                                                                                                                                                                                                                                                                                                                                                                    | ** ** | ** **                            | ** ** | ** **                              |
|            |       | **General   Servicing Considerations**                                                                                                                                                                                                                                                                                                                                                                        |       |                                  |       |                                    |
| ** **      |       |                                                                                                                                                                                                                                                                                                                                                                                                          |       |                                  |       |                                    |
| 1122(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.                                                                                                                                                                                                                                                  |       | **X**                                 |       |                                    |
|            |       |                                                                                                                                                                                                                                                                                                                                                                                                          |       | ** **                            |       |                                    |
| 1122(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.                                                                                                                                                                                                 |       | **X(2)**                              |       |                                    |
|            |       |                                                                                                                                                                                                                                                                                                                                                                                                          |       | ** **                            |       |                                    |
| 1122(d)(1)(iii) |       | Any requirements in the transaction agreements to   maintain a back-up servicer for the Pool Assets are maintained.                                                                                                                                                                                                                                                                                           |       |                                  |       | **X**                                   |
|            |       |                                                                                                                                                                                                                                                                                                                                                                                                          |       |                                  |       | ** **                              |
| 1122(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.                                                                                                                                       |       | **X**                                 |       |                                    |
|            |       |                                                                                                                                                                                                                                                                                                                                                                                                          |       | ** **                            |       |                                    |
| 1122(d)(1)(v)   |       | Aggregation of information, as applicable, is   mathematically accurate and the information conveyed accurately reflects the   information.                                                                                                                                                                                                                                                                   |       | **X(3)**                              |       |                                    |
|            |       |                                                                                                                                                                                                                                                                                                                                                                                                          |       | ** **                            |       |                                    |
|            |       | **Cash   Collection and Administration**                                                                                                                                                                                                                                                                                                                                                                      |       |                                  |       |                                    |
| ** **      |       |                                                                                                                                                                                                                                                                                                                                                                                                          |       |                                  |       |                                    |
| 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 following receipt, or such other number of days   specified in the transaction agreements.                                                                                                                                                           |       | **X**                                 |       |                                    |
|            |       |                                                                                                                                                                                                                                                                                                                                                                                                          |       | ** **                            |       |                                    |
| 1122(d)(2)(ii)  |       | Disbursements made via wire transfer on behalf of an   obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                       |       | **X**                                 |       |                                    |
|            |       |                                                                                                                                                                                                                                                                                                                                                                                                          |       | ** **                            |       |                                    |
| 1122(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.                                                                                                                                                                               |       | **X(4)**                              |       |                                    |
|            |       |                                                                                                                                                                                                                                                                                                                                                                                                          |       | ** **                            |       |                                    |
| 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**                                 |       |                                    |

 

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(2)  No servicing activities were performed by the Company that required the servicing criteria to be complied with.

(3)  No servicing activities were performed by the Company that required the servicing criteria to be complied with.

(4)  No servicing activities were performed by the Company that required the servicing criteria to be complied with.

 

Corporate Trust ABS Platform (A)

 

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| **Reference**       | ** ** | **Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | ** ** | **Applicable   Servicing   Criteria** | ** ** | **Inapplicable   Servicing   Criteria** |
|---------------------|------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|---------------------------------------|------------|-----------------------------------------|
| ** **          |       | ** **                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |       | ** **                            |       | ** **                              |
| 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**                                 |       |                                    |
|                |       |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |       | ** **                            |       |                                    |
| 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**                                   |

 

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| **Reference**    | ** ** | **Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | ** ** | **Applicable   Servicing   Criteria** | ** ** | **Inapplicable   Servicing   Criteria** |
|------------------|------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|---------------------------------------|------------|-----------------------------------------|
| ** **       |       | ** **                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |       | ** **                            |       | ** **                              |
| 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**                                 |       |                                    |

 

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