Exhibit 33.16



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Managements Report on Assessment of Compliance with SEC Regulation AB Servicing Criteria



|1. | C-III Asset Management LLC (C-III) 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 12- month period ending December 31, 2016 (the Reporting Period). The transactions covered by this report include all
transactions for which C-III acted as servicer involving first lien commercial mortgage loans (the Platform).
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|2. | Except as set forth in paragraph 3 below, C-III used criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing
criteria.
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|3. | The criteria listed in the column title Inapplicable Servicing Criteria on Appendix A hereto are inapplicable to C-III based on the activities it performs with respect
to the Platform.
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|4. | C-III 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.
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|5. | Dixon Hughes Goodman LLP, an independent registered public accounting firm, has issued an attestation report on C-IIIs assessment of compliance with the applicable servicing
criteria for the Reporting Period.
|-- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Date: February 6, 2017



C-III Asset Management LLC/s/ Kevin C. DonahueKevin C. Donahue, President/s/ James A. AstonJames A. Aston, Executive Managing Director and Treasurer/s/ John RoachJohn Roach, Senior Vice President of Portfolio Management


5221 N. OConnor Blvd., Suite 600, Irving, TX 75039

t 972.868.5300    f 972.868.5490

www.c3cp.com



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APPENDIX A



|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                 |  |                                                           |  |                                                                                     |  |                                                                          
|------------------ |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------- |  | --------------------------------------------------------- |  | ----------------------------------------------------------------------------------- |  | -------------------------------------------------------------------------
|SERVICING CRITERIA |  | APPLICABLE
SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                   |  | INAPPLICABLE
SERVICING
CRITERIA
|Reference          |  | Criteria                                                                                                                                                                                                                                                                                                                                                                        |  | PerformedDirectly byC-III       |  | PerformedbyVendor(s)for whichC-III is theResponsibleParty |  | Performed bysubservicer(s)
or vendor(s) for
which
C-III is NOT 
theResponsibleParty |  | NOTperformed by
C-III or by
subservicer(s)
or vendor(s)
retained by
C-III
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                 | 
|                   |  | 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                               |  |                                                           |  |                                                                                     |  |                                                                          
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                 | 
|1122(d)(1)(iii)    |  | Any requirements in the transaction agreements to maintain aback-up servicer for the pool assets are maintained.                                                                                                                                                                                                                                                                |  |                                 |  |                                                           |  |                                                                                     |  | X                                                                        
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                 | 
|1122(d)(1)i(v)     |  | 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                               |  |                                                           |  |                                                                                     |  |                                                                          
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                 | 
|                   |  | 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                               |  |                                                           |  |                                                                                     |  |                                                                          
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                 | 
|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.                                                                                                                           |  | 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                               |  |                                                           |  |                                                                                     |  |                                                                          
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                 |  |                                



5221 N. OConnor
Blvd., Suite 600, Irving, TX 75039

t 972.868.5300    f 972.868.5490

www.c3cp.com



---

LOGO



|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |                                |  |                                                                 |  |                                                                                    |  |                                                                     
|------------------ |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------ |  | --------------------------------------------------------------- |  | ---------------------------------------------------------------------------------- |  | --------------------------------------------------------------------
|SERVICING CRITERIA |  | APPLICABLESERVICING
CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  | INAPPLICABLESERVICING
CRITERIA
|Reference          |  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |  | Performed
Directly by
C-III    |  | Performed
by Vendor(s)
for which C-III is the Responsible
Party |  | Performed bysubservicer(s)or vendor(s)
for which C-III is NOT the
ResponsibleParty |  | NOTperformed byC-III or bysubservicer(s)or vendor(s)retained byC-III
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |                                | 
|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 mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  | X                              |  |                                                                 |  |                                                                                    |  |                                                                     
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |                               
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |                                | 
|1122(d)(4)(ii)     |  | Pool asset 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                              |  |                                                                 |  |                                                                                    |  |                                                                     
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |                               
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |                               
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |                               
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |                               
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |                               
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  |                               



5221 N. OConnor
Blvd., Suite 600, Irving, TX 75039

t 972.868.5300    f 972.868.5490

www.c3cp.com



---

LOGO



|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  |                                |  |                                                                 |  |                                                                                    |  |                                                                     
|------------------ |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------ |  | --------------------------------------------------------------- |  | ---------------------------------------------------------------------------------- |  | --------------------------------------------------------------------
|SERVICING CRITERIA |  | APPLICABLESERVICING
CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  | INAPPLICABLESERVICING
CRITERIA
|Reference          |  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  | Performed
Directly by
C-III    |  | Performed
by Vendor(s)
for which C-III is the Responsible
Party |  | Performed bysubservicer(s)or vendor(s)
for which C-III is NOT the
ResponsibleParty |  | NOTperformed byC-III or bysubservicer(s)or vendor(s)retained byC-III
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  |                                | 
|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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