EXHIBIT 33.1
 Certification Regarding Compliance with Applicable Servicing Criteria
 1.
    
    American Express Travel Related Services Company, Inc. (the Asserting Party) is responsible
for assessing compliance as of December 31, 2009 and for the period from January 1, 2009
through December 31, 2009 (the Reporting Period), with the servicing criteria applicable to
the Asserting Party under paragraph (d) of Item 1122 of Regulation AB, as set forth in
Appendix A hereto (such servicing criteria, excluding the criteria listed in the column titled
Inapplicable Servicing Criteria on Appendix A hereto, the Applicable Servicing Criteria).
The transactions covered by this report include all asset-backed securities transactions
backed by credit and charge card receivables issued by the American Express Credit Account
Master Trust and the American Express Issuance Trust, for which transactions the Asserting
Party acted as servicer, that were registered with the Securities and Exchange Commission
pursuant to the Securities Act of 1933, as amended, where the related asset-backed securities
were outstanding during the Reporting Period (the Platform), as listed in Appendix B hereto;
 2.
    
    The Asserting Party has engaged one vendor (the Vendor), which is not considered a
servicer as defined in Item 1101(j) of Regulation AB, to perform specific, limited or
scripted activities, and the Asserting Party elects to take responsibility for assessing
compliance with the servicing criteria or portion of the servicing criteria applicable to such
Vendors activities as set forth in Appendix A hereto. The Asserting Party has policies and
procedures in place designed to provide reasonable assurance that the Vendors activities
comply in all material respects with the servicing criteria applicable to such Vendor;
 3.
    
    Except as set forth in paragraph 4 below, the Asserting Party used the criteria set forth in
paragraph (d) of Item 1122 of Regulation AB to assess the compliance by the Asserting Party
with the Applicable Servicing Criteria as of December 31, 2009 and for the Reporting Period
with respect to the Platform taken as a whole;
 4.
    
    The criteria listed in the column titled Inapplicable Servicing Criteria on Appendix A
hereto are inapplicable to the Asserting Party based on the activities it performs, directly
or through its wholly-owned subsidiaries, Amex Card Services Company, American Express
Centurion Bank and American Express Bank, FSB (collectively, the Affiliated Subservicers)
with respect to the Platform taken as a whole;




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5.
    
    The Asserting Party has assessed compliance with the Applicable Servicing Criteria by each
of the Asserting Party and the Affiliated Subservicers for the Reporting Period and has
concluded that it and each such party has complied, in all material respects, with the
Applicable Servicing Criteria as of December 31, 2009 and for the Reporting Period with
respect to the Platform taken as a whole;
 6.
    
    The Asserting Party has not identified and is not aware of any material instance of
noncompliance by the Vendor with the Applicable Servicing Criteria as of December 31, 2009 and
for the Reporting Period with respect to the Platform taken as a whole;
 7.
    
    The Asserting Party has not identified any material deficiency in its policies and procedures
to monitor the compliance by the Vendor with the Applicable Servicing Criteria as of December
31, 2009 and for the Reporting Period with respect to the Platform taken as a whole; and
 8.
    
    PricewaterhouseCoopers LLP, an independent registered public accounting firm, has issued an
attestation report for the Platform on the Asserting Partys assessment of compliance with the
Applicable Servicing Criteria as of December 31, 2009 and for the Reporting Period.
 By
    /s/ Stephen J. BakonyiName:
    Stephen J. BakonyiTitle:
    Vice President, American Express
Travel Related Services Company, Inc.Date: March 26, 2010




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APPLICABLESERVICING CRITERIAPerformed byPerformed
    
    Vendor(s) for whichDirectly
    
    Asserting Party isSERVICING CRITERIA
    
    by
    
    the Responsible
    
    INAPPLICABLEReference
    
    Criteria
    
    Asserting Party
    
    Party
    
    SERVICING CRITERIAGeneral Servicing Considerations1122(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.
    
    X1122(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.
    
    X1122(d)(1)(iii)
    
    Any requirements in the transaction agreements to maintain a back-up
servicer for the pool assets are maintained.
    
    
    
    
    
    X1122(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.
    
    
    
    
    
    XCash Collection and Administration1122(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.
    
    X1122(d)(2)(ii)
    
    Disbursements made via wire transfer on behalf of an obligor or to
an investor are made only by authorized personnel.
    
    X1122(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.
    
    
    
    
    
    X1122(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.
    
    
    
    
    
    X1122(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.
    
    X1122(d)(2)(vi)
    
    Unissued checks are safeguarded so as to prevent unauthorized access.
    
    
    
    
    
    X




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APPLICABLESERVICING CRITERIAPerformed byPerformed
    
    Vendor(s) for whichDirectly
    
    Asserting Party isSERVICING CRITERIA
    
    by
    
    the Responsible
    
    INAPPLICABLEReference
    
    Criteria
    
    Asserting Party
    
    Party
    
    SERVICING CRITERIA1122(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.
    
    XInvestor Remittances and Reporting1122(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.
    
    X1122(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.
    
    X1122(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.
    
    
    
    
    
    X1122(d)(3)(iv)
    
    Amounts remitted to investors
per the investor reports agree with
cancelled checks, or other form of
payment, or custodial bank statements.
    
    XPool Asset Administration1122(d)(4)(i)
    
    Collateral or security on pool
assets is maintained as required by
the transaction agreements or related
pool asset documents.
    
    
    
    
    
    X1122(d)(4)(ii)
    
    Pool assets and related
documents are safeguarded as required
by the transaction agreements.
    
    X1122(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.
    
    X1122(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.
    
    X1122(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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APPLICABLESERVICING CRITERIAPerformed byPerformed
    
    Vendor(s) for whichDirectly
    
    Asserting Party isSERVICING CRITERIA
    
    by
    
    the Responsible
    
    INAPPLICABLEReference
    
    Criteria
    
    Asserting Party
    
    Party
    
    SERVICING CRITERIA1122(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.
    
    X1
    
    X11122(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.
    
    X1122(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).
    
    X1122(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.
    
    X1122(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
asset, or such
other number of
days specified in
the transaction
agreements.
    
    
    
    
    
    X1122(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.
    
    
    
    
    
    X1122(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.
    
    
    
    
    
    X1122(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.
    
    
    
    
    
    X1122(d)(4)(xiv)
    
    Delinquencies,
charge-offs and
uncollectible
accounts are
recognized and
recorded in
accordance with the
transaction
agreements.
    
    X1122(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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1
    
    American Express Travel Related Services Company, Inc. has engaged one vendor 
eFunds  that handled cardmember disputes, with respect to which such vendor was
authorized to change the amount owed by a cardmember, including waiving certain interest and
penalty fees.




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American Express Issuance Trust
 
 American Express Credit Account Master Trust