Exhibit 33.1**Certification Regarding Compliance with Applicable Servicing Criteria**1. American Express Travel Related Services Company, Inc. (the “Asserting Party”) is responsiblefor assessing compliance as of December 31, 2007 and for the period from January 1, 2007through December 31, 2007 (the “Reporting Period”), with the servicing criteria applicable tothe Asserting Party under paragraph (d) of Item 1122 of Regulation AB, as set forth inAppendix 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 transactionsbacked by credit and charge card receivables issued by the American Express Credit AccountMaster Trust and the American Express Issuance Trust, for which transactions the AssertingParty acted as servicer, that were registered with the Securities and Exchange Commissionpursuant to the Securities Act of 1933, as amended, where the related asset-backed securitieswere 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 orscripted activities, and the Asserting Party elects to take responsibility for assessingcompliance with the servicing criteria or portion of the servicing criteria applicable to suchVendor’s activities as set forth in Appendix A hereto. The Asserting Party has policies andprocedures in place designed to provide reasonable assurance that the Vendor’s activitiescomply 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 inparagraph (d) of Item 1122 of Regulation AB to assess the compliance by the Asserting Partywith the Applicable Servicing Criteria as of December 31, 2007 and for the Reporting Periodwith respect to the Platform taken as a whole;4. The criteria listed in the column titled “Inapplicable Servicing Criteria” on Appendix Ahereto are inapplicable to the Asserting Party based on the activities it performs, directlyor through its wholly-owned subsidiaries, Amex Card Services Company, American ExpressCenturion Bank and American Express Bank, FSB (collectively, the “Affiliated Subservicers”)with respect to the Platform taken as a whole;5. The Asserting Party has assessed compliance with the Applicable Servicing Criteria by each ofthe Asserting Party and the Affiliated Subservicers for the Reporting Period and has concludedthat it and each such party has complied, in all material respects, with the ApplicableServicing Criteria as of December 31, 2007 and for the Reporting Period with respect to thePlatform taken as a whole;6. The Asserting Party has not identified and is not aware of any material instance ofnoncompliance by the Vendor with the Applicable Servicing Criteria as of December 31, 2007 andfor 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 andprocedures to monitor the compliance by the Vendor with the Applicable Servicing Criteria asof December 31, 2007 and for the Reporting Period with respect to the Platform taken as awhole; and8. PricewaterhouseCoopers LLP, an independent registered public accounting firm, has issued anattestation report for the Platform on the Asserting Party’s assessment of compliance with theApplicable Servicing Criteria as of December 31, 2007 and for the Reporting Period.         By: /s/ Stephen J. Bakonyi    Name:  Stephen J. Bakonyi    Title: Vice President, American Express      Travel Related Services Company, Inc.    Date: March 14, 2008  
 

 
APPENDIX A                 **INAPPLICABLE**    **APPLICABLE** **SERVICING****SERVICING CRITERIA** **SERVICING CRITERIA** **CRITERIA**      **Performed**        **by**        **Vendor(s)**      **Performed** **for which**      **Directly** **Asserting**      **by** **Party is the**      **Asserting** **Responsible**  **Reference** **Criteria** **Party** **Party**    **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 pool assets 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 pool assets aredeposited into the appropriatecustodial bank accounts andrelated bank clearing accounts nomore than two business daysfollowing receipt, or such othernumber of days specified in the transaction agreements. **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**
 

 
                 **INAPPLICABLE**    **APPLICABLE** **SERVICING****SERVICING CRITERIA** **SERVICING CRITERIA** **CRITERIA**      **Performed**        **by**        **Vendor(s)**      **Performed** **for which**      **Directly** **Asserting**      **by** **Party is the**      **Asserting** **Responsible**  **Reference** **Criteria** **Party** **Party**  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**               **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 pool assets serviced bythe 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 poolassets is maintained as requiredby the transaction agreements orrelated pool asset documents.     **X**         1122(d)(4)(ii) Pool assets and related documentsare safeguarded as required bythe transaction 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 pool assets,including any payoffs, made inaccordance with the related poolasset documents are posted to theServicer’s obligor recordsmaintained no more than twobusiness days after receipt, orsuch other number of daysspecified in the transactionagreements, and allocated toprincipal, interest or otheritems (e.g., escrow) inaccordance with the related poolasset documents. **X**             1122(d)(4)(v) The Servicer’s records regardingthe pool assets agree with theServicer’s records with respectto an obligor’s unpaid principalbalance. **X**    
 

 
                 **INAPPLICABLE**    **APPLICABLE** **SERVICING****SERVICING CRITERIA** **SERVICING CRITERIA** **CRITERIA**      **Performed**        **by**        **Vendor(s)**      **Performed** **for which**      **Directly** **Asserting**      **by** **Party is the**      **Asserting** **Responsible**  **Reference** **Criteria** **Party** **Party**  1122(d)(4)(vi) Changes withrespect to theterms or status ofan obligor’s poolassets (e.g., loanmodifications orre-agings) aremade, reviewed andapproved byauthorizedpersonnel inaccordance with thetransactionagreements andrelated pool assetdocuments. **X****1** **X****1**           1122(d)(4)(vii) Loss mitigation orrecovery actions(e.g., forbearanceplans,modifications anddeeds in lieu offoreclosure,foreclosures andrepossessions, asapplicable) areinitiated,conducted andconcluded inaccordance with thetimeframes or otherrequirementsestablished by thetransactionagreements. **X**             1122(d)(4)(viii) Records documentingcollection effortsare maintainedduring the period apool asset isdelinquent inaccordance with thetransactionagreements. Suchrecords aremaintained on atleast a monthlybasis, or suchother periodspecified in thetransactionagreements, anddescribe theentity’s activitiesin monitoringdelinquent poolassets including,for example, phonecalls, letters andpaymentrescheduling plansin cases wheredelinquency isdeemed temporary(e.g., illness orunemployment). **X**             1122(d)(4)(ix) Adjustments tointerest rates orrates of return forpool assets withvariable rates arecomputed based onthe related poolasset documents. **X**             1122(d)(4)(x) Regarding any fundsheld in trust foran obligor (such asescrow accounts): (A) such funds areanalyzed, inaccordance with theobligor’s poolasset documents, onat least an annualbasis, or suchother periodspecified in thetransactionagreements; (B)interest on suchfunds is paid, orcredited, toobligors inaccordance withapplicable poolasset documents andstate laws; and (C)such funds arereturned to theobligor within 30calendar days offull repayment ofthe related poolasset, or suchother number ofdays specified inthe transactionagreements.     **X**         1122(d)(4)(xi) Payments made onbehalf of anobligor (such astax or insurancepayments) are madeon or before therelated penalty orexpiration dates,as indicated on theappropriate billsor notices for suchpayments, providedthat such supporthas been receivedby the Servicer atleast 30 calendardays prior to thesedates, or suchother number ofdays specified inthe transactionagreements.     **X**         1122(d)(4)(xii) Any late paymentpenalties inconnection with anypayment to be madeon behalf of anobligor are paidfrom the Servicer’sfunds and notcharged to theobligor, unless thelate payment wasdue to theobligor’s error oromission.     **X**         1122(d)(4)(xiii) Disbursements madeon behalf of anobligor are postedwithin two businessdays to theobligor’s recordsmaintained by theServicer, or suchother number ofdays specified inthe transactionagreements.     **X**         1122(d)(4)(xiv) Delinquencies,charge-offs anduncollectibleaccounts arerecognized andrecorded inaccordance with thetransactionagreements. **X**             1122(d)(4)(xv) Any externalenhancement orother support,identified in Item1114(a)(1) through(3) or Item 1115 ofRegulation AB, ismaintained as setforth in thetransactionagreements.     **X** 1 American Express Travel Related Services Company, Inc. has engaged one vendor —eFunds Corporation — that handled cardmember disputes, withrespect to which such vendor was authorized to change the amount owed by a cardmember, includingwaiving certain interest and penalty fees.
 

 
Appendix B