Exhibit 33.1Certification Regarding Compliance with Applicable Servicing Criteria1. National City Bank (the “Servicer”) is responsible for assessing compliance with theservicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as ofand for the 12-month period ending December 31, 2006 (the “Reporting Period”), as set forth inExhibit A hereto. The transactions covered by this report include all asset-backed securitiestransactions conducted by National City Credit Card Master Note Trust that were registeredwith the Securities and Exchange Commission pursuant to the Securities Act of 1933 where therelated asset-backed securities were outstanding at any time during the Reporting Period (the“Platform”).2. The Servicer has engaged certain vendors (“Vendors”) to perform specific, limited or scriptedactivities, and the Servicer elects to take responsibility for assessing compliance with theservicing criteria or portion of the servicing criteria applicable to such Vendors’ activitiesas set forth in Exhibit A hereto.3. Except as set forth in paragraph 4 below, the Servicer used the criteria set forth inparagraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicableservicing criteria.4. The criteria listed in the column titled “Inapplicable Servicing Criteria” on Exhibit Ahereto are inapplicable to the Servicer based on the activities it performs, directly orthrough its Vendors, with respect to the Platform.5. The Servicer has complied, in all material respects, with the applicable servicing criteriaas of December 31, 2006 and for the Reporting Period with respect to the Platform taken as awhole.6. The Servicer has not identified and is not aware of any material instance of noncompliance bythe Vendors with the applicable servicing criteria as of December 31, 2006 and for theReporting Period with respect to the Platform taken as a whole.7. The Servicer has not identified any material deficiency in its policies and procedures tomonitor the compliance by the Vendors with the applicable servicing criteria as of December31, 2006 and for the Reporting Period with respect to the Platform taken as a whole.8. Ernst & Young LLP, a registered public accounting firm, has issued an attestation report onthe Servicer’s assessment of compliance with the applicable servicing criteria as of December31, 2006 and for the Reporting Period.     March 30, 2007 National City Bank, as Servicer         /s/ Russell A. Cronin, Jr. By: Russell A. Cronin, Jr., Senior Vice President  
 

 
Exhibit A                       ***Applicable***  ***Performed***  ***Inapplicable***        ***Servicing***  ***by***  ***Servicing***     ***Servicing Criteria***  ***Criteria***  ***Vendors***  ***Criteria***  **Reference**  **Criteria**              **General Servicing Considerations**           1122(d)(1)(i)  Policies and procedures areinstituted to monitor anyperformance or other triggers andevents of default in accordancewith the transaction agreements.  X        1122(d)(1)(ii)  If any material servicingactivities are outsourced tothird parties, policies andprocedures are instituted tomonitor the third party’sperformance and compliance withsuch servicing activities.  X        1122(d)(1)(iii)  Any requirements in thetransaction agreements tomaintain a back-up servicer forthe credit card accounts oraccounts are maintained.        X  1122(d)(1)(iv)  A fidelity bond and errors andomissions policy is in effect onthe party participating in theservicing function throughout thereporting period in the amount ofcoverage required by andotherwise in accordance with theterms of the transactionagreements.  X           **Cash Collection and Administration**           1122(d)(2)(i)  Payments on credit card accountsare deposited into theappropriate custodial bankaccounts and related bankclearing accounts no more thantwo business days followingreceipt, or such other number ofdays specified in the transactionagreements.  X        1122(d)(2)(ii)  Disbursements made via wiretransfer on behalf of an obligoror to an investor are made onlyby authorized personnel.        X  1122(d)(2)(iii)  Advances of funds or guaranteesregarding collections, cash flowsor distributions, and anyinterest or other fees chargedfor such advances, are made,reviewed and approved asspecified in the transactionagreements.        X  1122(d)(2)(iv)  The related accounts for thetransaction, such as cash reserveaccounts or accounts establishedas a form ofovercollateralization, areseparately maintained (e.g., withrespect to commingling of cash)as set forth in the transactionagreements.  X        1122(d)(2)(v)  Each custodial account ismaintained at a federally insureddepository institution as setforth in the transactionagreements. For purposes of thiscriterion, “federally insureddepository institution” withrespect to a foreign financialinstitution means a foreignfinancial institution that meetsthe requirements of Rule13k-1(b)(1) of the SecuritiesExchange Act.  X        1122(d)(2)(vi)  Unissued checks are safeguardedso as to prevent unauthorizedaccess.        X  1122(d)(2)(vii)  Reconciliations are prepared on amonthly basis for allasset-backed securities relatedbank accounts, includingcustodial accounts and relatedbank clearing accounts. Thesereconciliations are (A)mathematically accurate; (B)prepared within 30 calendar daysafter the bank statement cutoffdate, or such other number ofdays specified in the transactionagreements; (C) reviewed andapproved by someone other thanthe person who prepared thereconciliation; and (D) containexplanations for reconcilingitems. These reconciling itemsare resolved within 90 calendardays of their originalidentification, or such othernumber of days specified in thetransaction agreements.  X        
 

 
                       ***Applicable***  ***Performed***  ***Inapplicable***        ***Servicing***  ***by***  ***Servicing***     ***Servicing Criteria***  ***Criteria***  ***Vendors***  ***Criteria***  **Reference**  **Criteria**              **Investor Remittances and Reporting**           1122(d)(3)(i)  Reports to investors, includingthose to be filed with theCommission, are maintained inaccordance with the transactionagreements and applicableCommission requirements.Specifically, such reports (A)are prepared in accordance withtimeframes and other terms setforth in the transactionagreements; (B) provideinformation calculated inaccordance with the termsspecified in the transactionagreements; (C) are filed withthe Commission as required by itsrules and regulations; and (D)agree with investors’ or thetrustee’s records as to the totalunpaid principal balance andnumber of credit card accountsserviced by the Servicer.  X        1122(d)(3)(ii)  Amounts due to investors areallocated and remitted inaccordance with timeframes,distribution priority and otherterms set forth in thetransaction agreements.  X        1122(d)(3)(iii)  Disbursements made to an investorare posted within two businessdays to the Servicer’s investorrecords, or such other number ofdays specified in the transactionagreements.        X  1122(d)(3)(iv)  Amounts remitted to investors perthe investor reports agree withcancelled checks, or other formof payment, or custodial bankstatements.  X           **Pool Asset Administration**           1122(d)(4)(i)  Collateral or security on creditcard accounts is maintained asrequired by the transactionagreements or related asset pooldocuments.        X  1122(d)(4)(ii)  Account and related documents aresafeguarded as required by thetransaction agreements  X        1122(d)(4)(iii)  Any additions, removals orsubstitutions to the asset poolare made, reviewed and approvedin accordance with any conditionsor requirements in thetransaction agreements.  X        1122(d)(4)(iv)  Payments on credit card accounts,including any payoffs, made inaccordance with the relatedcredit card accounts documentsare posted to the Servicer’sobligor records maintained nomore than two business days afterreceipt, or such other number ofdays specified in the transactionagreements, and allocated toprincipal, interest or otheritems (e.g., escrow) inaccordance with the related assetpool documents.  X  X(1)     1122(d)(4)(v)  The Servicer’s records regardingthe accounts and the accountsagree with the Servicer’s recordswith respect to an obligor’sunpaid principal balance.  X        1122(d)(4)(vi)  Changes with respect to the termsor status of an obligor’s account(e.g., loan modifications orre-agings) are made, reviewed andapproved by authorized personnelin accordance with thetransaction agreements andrelated pool asset documents.  X        1122(d)(4)(vii)  Loss mitigation or recoveryactions (e.g., forbearance plans,modifications and deeds in lieuof foreclosure, foreclosures andrepossessions, as applicable) areinitiated, conducted andconcluded in accordance with thetimeframes or other requirementsestablished by the transactionagreements.  X        1122(d)(4)(viii)  Records documenting collectionefforts are maintained during theperiod an Account is delinquent inaccordance with the transactionagreements. Such records aremaintained on at least a monthlybasis, or such other periodspecified in the transactionagreements, and describe theentity’s activities in monitoringdelinquent Accounts including,for example, phone calls, lettersand payment rescheduling plans incases where delinquency is deemedtemporary (e.g., illness orunemployment).  X        1122(d)(4)(ix)  Adjustments to interest rates orrates of return for Accounts withvariable rates are computed basedon the related Account documents.  X        
 

 
                       ***Applicable***  ***Performed***  ***Inapplicable***        ***Servicing***  ***by***  ***Servicing***     ***Servicing Criteria***  ***Criteria***  ***Vendors***  ***Criteria***  **Reference**  **Criteria**           1122(d)(4)(x)  Regarding any funds held in trustfor an obligor (such as escrowaccounts): (A) such funds areanalyzed, in accordance with theobligor’s Account documents, onat least an annual basis, or suchother period specified in thetransaction agreements; (B)interest on such funds is paid,or credited, to obligors inaccordance with applicableAccount documents and state laws;and (C) such funds are returnedto the obligor within 30 calendardays of full repayment of therelated Accounts, or such othernumber of days specified in thetransaction agreements.        X  1122(d)(4)(xi)  Payments made on behalf of anobligor (such as tax or insurancepayments) are made on or beforethe related penalty or expirationdates, as indicated on theappropriate bills or notices forsuch payments, provided that suchsupport has been received by theservicer at least 30 calendardays prior to these dates, orsuch other number of daysspecified in the transactionagreements.        X  1122(d)(4)(xii)  Any late payment penalties inconnection with any payment to bemade on behalf of an obligor arepaid from the servicer’s fundsand not charged to the obligor,unless the late payment was dueto the obligor’s error oromission.        X  1122(d)(4)(xiii)  Disbursements made on behalf ofan obligor are posted within twobusiness days to the obligor’srecords maintained by theservicer, or such other number ofdays specified in the transactionagreements.        X  1122(d)(4)(xiv)  Delinquencies, charge-offs anduncollectible accounts arerecognized and recorded inaccordance with the transactionagreements.  X        1122(d)(4)(xv)  Any external enhancement or othersupport, identified in Item1114(a)(1) through (3) or Item1115 of Regulation AB, ismaintained as set forth in thetransaction agreements.        X   (1) Vendors are First Express and First Data Resources, Inc. (FDR). First Express provideslock box service. A majority of payments on credit cards are received through FirstExpress, although some payments on credit cards come directly to National City Bank. FirstExpress transmits payment information electronically, which is uploaded to the FDRservicing system daily. For those payments received directly by National City Bank,National City Bank processes the payments and sends a file directly to FDR for posting.