**Exhibit 33.2**

 

Management’s Assertion

 

Report on Assessment of Compliance with Applicable Servicing Criteria

 

 

U.S. Bank National Association (“U.S. Bank”) is responsible for assessing compliance as of October 31, 2014 and for the period from November 1, 2013 through October 31, 2014 with the servicing criteria set forth in Item 1122(d) of Regulation AB applicable to it as set forth on Exhibit A hereto.  This Report covers asset backed securities transactions within the **U.S. Bank Corporate Trust Asset-Backed Securities Platform****1**** (the “Platform”).**

 

U.S. Bank hereby provides the following report on its assessment of compliance with the servicing criteria set forth in Item 1122 of Regulation AB applicable to it and as described on Exhibit A hereto:

 

1.            U.S. Bank is responsible for assessing its compliance with the servicing criteria applicable to it as noted on the accompanying Exhibit A;

 

2.            Except as set forth in paragraph 3 below, U.S. Bank used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess its compliance with the applicable servicing criteria;

 

3.            The criteria listed in the column titled “Inapplicable Servicing Criteria” on Exhibit A hereto are inapplicable to U.S. Bank based on the activities it performs directly with respect to the Platform.

 

4.            U.S. Bank has complied, in all material respects, with the applicable servicing criteria as of October 31, 2014 and for the period from November 1, 2013 through October 31, 2014.

 

5.            Ernst & Young, LLP, a registered public accounting firm, has issued an attestation report on U.S. Bank’s assessment of compliance with the applicable servicing criteria as of October 31, 2014 and for the period from November 1, 2013 through October 31, 2014.

 

 
|                              | U.S. BANK NATIONAL   ASSOCIATION  |
|-----------------------------------|-----------------------------------|
|                              |                              |
|                              |                              |
|                              | /s/ Bryan R Calder                |   |
|                              | Name: Bryan R. Calder             |
|                              | Title: Executive Vice   President |
|                              |                              |
| Date:  January 13, 2015 |                              |

 

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1 The U.S. Bank Corporate Trust Asset-Backed Securities Platform (the “Platform”) consists of the activities involved in the performance of servicing functions for which the Company provides trustee, securities administration, registrar or paying agent services for (i) publicly issued asset-backed and mortgage backed transactions the securities which were offered on or after January 1, 2006 and (ii) certain asset backed transactions for which the Issuer has voluntarily elected to make Regulation AB compliant filings under the Securities Exchange Act of 1934, as amended.  The Platform does not include transactions comprised of the repackaging of corporate debt and/or other agency securities.

 

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**EXHIBIT A to Management’s Assertion**

** **
| **Reference**                                        | **Servicing   Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | **Applicable   Servicing   Criteria** | **Inapplicable   Servicing   Criteria** |
|------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|-----------------------------------------|
| ** **

**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**                     | ** **

                       |
|  

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 over   collateralization, 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**                           |
| 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**                           |

 
| Corporate Trust ABS Platform | 1

  |   |
|------------------------------|-----------|--------|

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| **Reference**                                        | **Servicing   Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | **Applicable   Servicing   Criteria** | **Inapplicable   Servicing   Criteria** |
|------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|-----------------------------------------|
| ** **

**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**                           |
|  

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**                     |  

                           |
|  

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 pool asset documents. 

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | ** **

                     |  

**X**                           |
|  

1122(d)(4)(ii)                               |  

Pool assets 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**                           |
|  

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**                           |

 
| Corporate Trust ABS Platform | 2

  |   |
|------------------------------|-----------|--------|

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| **Reference**            | **Servicing   Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **Applicable   Servicing   Criteria** | **Inapplicable   Servicing   Criteria** |
|--------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|-----------------------------------------|
|  

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**

                |

 
| Corporate Trust ABS Platform | 3

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|------------------------------|-----------|--------|

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