Exhibit 33.1

Report
on Assessment of Compliance with Applicable Servicing Criteria for Asset-Backed

Securities of USAA Federal Savings Bank

|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|-- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|1. | USAA Federal
 Savings Bank (FSB) is responsible for assessing compliance with the
 servicing criteria applicable to it under paragraph (d) of Item 1122 of
 Regulation AB, as of December 31, 2010 and for the period from January 1,
 2010 through December 31, 2010 (the Reporting Period), as set forth in
 Appendix A hereto. The transactions covered by this report include
 asset-backed securities transactions for which FSB acted as servicer
 involving retail auto loans other than transactions consummated prior to the
 effectiveness of Regulation AB (the Platform). See Appendix B for the
 asset backed transactions covered by this platform;
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|2. | FSB used the
 criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess
 the compliance with the applicable servicing criteria;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|3. | The criteria
 listed in the column titled Inapplicable Servicing Criteria on Appendix A
 hereto are inapplicable to FSB based on the activities it performs, directly
 or through its Vendors, with respect to the Platform;                                                                                                                                                                                                                                                                                                                                                                                                                                         
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|4. | FSB has
 complied, in all material respects, with the applicable servicing criteria as
 of December 31, 2010 and for the Reporting Period with respect to the
 Platform taken as a whole;                                                                                                                                                                                                                                                                                                                                                                                                                                                                              
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|5. | Ernst &
 Young LLP, an independent registered public accounting firm, has issued an
 attestation report for the Platform on FSBs assessment of compliance with
 the applicable servicing criteria for the Reporting Period.                                                                                                                                                                                                                                                                                                                                                                                                                                           

|                |                            |                                 |                   
|--------------- | -------------------------- | ------------------------------- | ------------------
|                | USAA FEDERAL
 SAVINGS BANK
|                |                           
|                | By:                        | /s/                             | TIMOTHY P.
 BOOKER
|                |                           
|                |                            | Name:  Timothy P. Booker       
|                |                            | Title:    VP,
 Consumer Lending
|                |                            |                                
|March 31,
 2011 |                            |                                

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APPENDIX A

|                   |  |                                                                                                                                                                                                                                                                                                                                                                                      |  |                                   |  |                                                                     |  |                                                                                           |  |                                                                              | 
|------------------ |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |  | --------------------------------- |  | ------------------------------------------------------------------- |  | ----------------------------------------------------------------------------------------- |  | ---------------------------------------------------------------------------- | 
|SERVICING CRITERIA |  | APPLICABLE
 
 SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                     |  | INAPPLICABLE
 SERVICING
 CRITERIA | 
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                      |  |                                   | 
|Reference          |  | Criteria                                                                                                                                                                                                                                                                                                                                                                             |  | Performed
 Directly
 by
 FSB      |  | Performed
 by
 Vendor(s)
 for which
 FSB is the
 Responsible
 Party |  | Performed by
 subservicer(s)
 or vendor(s)
 for which
 FSB is NOT
 the Responsible
 Party |  | NOT
 performed by
 FSB or by
 subservicer(s)
 or vendor(s)
 retained by
 FSB | 
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                      |  |                                   |  |                                                                     |  |                                                                                           |  |                                                                              | 
|                   |  | 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 a back-up servicer for
 the pool assets are maintained.                                                                                                                                                                                                                                                                  |  |                                   |  |                                                                     |  |                                                                                           |  | X                                                                            | 
|1122(d)(1)(iv)     |  | A fidelity
 bond and errors and omissions policy is in effect on the party participating
 in the servicing function throughout the reporting period in the amount of
 coverage required by and otherwise in accordance with the terms of the
 transaction agreements.                                                                                                                |  | X                                 |  |                                                                     |  |                                                                                           |  |                                                                              | 
|                   |  | 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                                 |  |                                                                     |  | 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                                                                            | 

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|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  |                                   |  |                                                                     |  |                                                                                           |  |                                                                              | 
|------------------ |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | --------------------------------- |  | ------------------------------------------------------------------- |  | ----------------------------------------------------------------------------------------- |  | ---------------------------------------------------------------------------- | 
|SERVICING CRITERIA |  | APPLICABLE
 
 SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  | INAPPLICABLE
 SERVICING
 CRITERIA | 
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  |                                   | 
|Reference          |  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |  | Performed
 Directly
 by
 FSB      |  | Performed
 by
 Vendor(s)
 for which
 FSB is the
 Responsible
 Party |  | Performed by
 subservicer(s)
 or vendor(s)
 for which
 FSB is NOT
 the Responsible
 Party |  | NOT
 performed by
 FSB or by
 subservicer(s)
 or vendor(s)
 retained by
 FSB | 
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  |                                   |  |                                                                     |  |                                                                                           |  |                                                                              | 
|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                                 |  |                                                                     |  | 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                                 |  |                                                                     |  | 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                                 |  |                                                                     |  | 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                                 |  |                                                                     |  |                                                                                           |  |                                                                              | 
|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                                 |  |                                                                     |  |                                                                                           |  |                                                                              | 

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|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  |                                   |  |                                                                     |  |                                                                                           |  |                                                                              | 
|------------------ |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | --------------------------------- |  | ------------------------------------------------------------------- |  | ----------------------------------------------------------------------------------------- |  | ---------------------------------------------------------------------------- | 
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  |                                   |  |                                                                     |  |                                                                                           |  |                                                                              | 
|SERVICING CRITERIA |  | APPLICABLE
 
 SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  | INAPPLICABLE
 SERVICING
 CRITERIA | 
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  |                                   | 
|Reference          |  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  | Performed
 Directly
 by
 FSB      |  | Performed
 by
 Vendor(s)
 for which
 FSB is the
 Responsible
 Party |  | Performed by
 subservicer(s)
 or vendor(s)
 for which
 FSB is NOT
 the Responsible
 Party |  | NOT
 performed by
 FSB or by
 subservicer(s)
 or vendor(s)
 retained by
 FSB | 
|                   |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |  |                                   |  |                                                                     |  |                                                                                           |  |                                                                              | 
|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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APPENDIX B

|    |                              
|--- | -----------------------------
|1)  | USAA Auto
 Owner Trust 2006-1
|    |                              
|2)  | USAA Auto
 Owner Trust 2006-2
|    |                              
|3)  | USAA Auto
 Owner Trust 2006-3
|    |                              
|4)  | USAA Auto
 Owner Trust 2006-4
|    |                              
|5)  | USAA Auto
 Owner Trust 2007-1
|    |                              
|6)  | USAA Auto
 Owner Trust 2007-2
|    |                              
|7)  | USAA Auto
 Owner Trust 2008-1
|    |                              
|8)  | USAA Auto
 Owner Trust 2008-2
|    |                              
|9)  | USAA Auto
 Owner Trust 2008-3
|    |                              
|10) | USAA Auto
 Owner Trust 2009-1
|    |                              
|11) | USAA Auto
 Owner Trust 2009-2
|    |                              
|12) | USAA Auto
 Owner Trust 2010-1

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