Exhibit 34.1

 

 

 

Reportof Independent Registered Public Accounting Firm

 

The Board of Directors

USAA Federal Savings Bank

 

We have examined management’s****assertion, included in the accompanying Report on Assessment of Compliance with Applicable Servicing Criteria for Asset-BackedSecurities of USAA Federal Savings Bank (the Management Certification), that USAA Federal Savings Bank (the Bank) complied withthe servicing criteria set forth in Item 1122 (d) of the Securities and Exchange Commission’s Regulation AB for the retailauto loan platform as of and for the year ended December 31, 2015, except for 1122(d)(1)(iii), 1122(d)(2)(ii), 1122(d)(2)(iv),1122(d)(2)(v), 1122(d)(2)(vi), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii),1122(d)(4)(xiii), and 1122(d)(4)(xv), which the Bank has determined are not applicable to the activities performed by them withrespect to the servicing platform covered by this report. See Appendix A of the Management Certification for the asset backed transactionscovered by this platform.****Management is responsible for the Bank’s compliance with those servicing criteria.Our responsibility is to express an opinion on management’s assertion about the Bank’s compliance with the servicingcriteria based on our examination.

 

Our examination was conducted in accordancewith attestation standards established by the American Institute of Certified Public Accountants, as adopted by the Public CompanyAccounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Bank’scompliance with the applicable servicing criteria and performing such other procedures as we considered necessary in the circumstances.Our examination included testing of less than all of the individual asset backed transactions and securities that comprise theplatform, testing of less than all of the servicing activities related to the Platform and determining whether the Bank processedthose selected transactions and performed those selected activities in compliance with the servicing criteria and as permittedby Regulation AB Compliance and Disclosure Interpretations of the Division of Corporation Finance, Section 200.06, “VendorsEngaged by Servicers” (C&DI 200.06). Furthermore, our procedures were limited to the selected transactions and servicingactivities performed by the Bank during the period covered by this report. Our procedures were not designed to determine whethererrors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated orreported by the Bank during the period covered by this report for the selected transactions or any other transactions. We believethat our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on theBank’s compliance with the servicing criteria.

** **

As described in management’s assertion,for servicing criteria 1122 (d)(4)(i) and 1122 (d)(4)(ii), the Bank has engaged various vendors to perform the activities requiredby these servicing criteria. The Bank has determined that these vendors are not considered a “servicer” as definedin Item 1101(j) of Regulation AB, and the Bank has elected to take responsibility for assessing compliance with the applicableservicing criteria applicable to each vendor as permitted by C&DI 200.06. As permitted by C&DI 200.06, the Bank has assertedthat it has policies and procedures in place designed to provide reasonable assurance that the vendors’ activities complyin all material respects with servicing criteria

 

 

 

 

applicable to each vendor. The Bankis solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendors and relatedcriteria as described in its assertion, and we performed no procedures with respect to the Bank’s eligibility to apply C&DI200.06.****

** **

In our opinion, management’s assertionthat the Bank complied with the aforementioned servicing criteria, including servicing criteria 1122 (d)(4)(i) and 1122 (d)(4)(ii)for which compliance is determined based on C&DI 200.06 as described above, as of and for the year ended December 31, 2015for the retail auto loan****platform, is fairly stated, in all material respects. ****

** **

 

 

/s/ Ernst & Young LLP

 

March 30, 2016