EX-33.4


MANAGEMENT'S ASSERTION OF COMPLIANCE

Management of the Trust & Securities Services department of Deutsche Bank
National Trust Company and Deutsche Bank Trust Company Americas (collectively
the "Company") is responsible for assessing the servicing criteria set forth in
Item 1122(d) of Regulation AB promulgated by the Securities and Exchange
Commission to determine which criteria are applicable to the Company in respect
of the servicing platform described below. Management has determined that the
servicing criteria are applicable in regard to the servicing platform for the
period as follows:

Platform: Publicly-issued (i.e., transaction-level reporting required under the
Securities Exchange Act of 1934, as amended) and certain privately-issued
(i.e., for which transaction-level reporting is required pursuant to
contractual obligation) residential mortgage-backed securities, commercial
mortgage-backed securities and other asset-backed securities issued on or after
January 1, 2006, for which the Company provides trustee, securities
administration, paying agent or custodian services, as defined in the
transaction agreements, excluding publicly-issued securities sponsored or
issued by any government sponsored entity (the "Platform").

Applicable Servicing Criteria: All servicing criteria set forth in Item
1122(d), to the extent required by Item 1122( d) servicing criteria in regards
to the activities performed by the Company with respect to the Platform as to
any transaction, except for the following criteria: 1122(d)(4)(iv) -
1122(d)(4)(xiv), which management has determined are not applicable to the
activities the Company performs with respect to the Platform (the "Applicable
Servicing Criteria"). With respect to Applicable Servicing Criteria
1122(d)(1)(ii), 1122(d)(1)(iii), 1122(d)(2)(iii) and 1122(d)(4)(iii) there were
no activities performed during the year ended December 31, 2013 with respect to
the Platform, because there were no occurrences ofevents that would require the
Company to perform such activities.

Period: Year ended December 31, 2013 (the "Period").

Management's interpretation of Applicable Servicing Criteria: The Company's
management has determined that servicing criterion 1122(d)(1)(iii) is
applicable only with respect to its continuing obligation to act as, or locate
a, successor servicer under the circumstances referred to in certain
transaction agreements. It is management's interpretation that the Company has
no other active back-up servicing responsibilities in regards to servicing
criterion 1122(d)(1)(iii) as of and for the Period. The Company's management
has determined that servicing criterion 1122(d)(4)(iii) is applicable to the
activities the Company performs with respect to the Platform only as it relates
to the Company's obligation to report additions, removals or substitutions on
reports to investors in accordance with the transaction agreements.

With respect to the Platform and the Period, the Company's management provides
the following assertion of compliance with respect to the Applicable Servicing
Criteria:

* The Company's management is responsible for assessing the Company's
  compliance with the Applicable Servicing Criteria.

* The Company's management has assessed compliance with the Applicable
  Servicing Criteria. In making this assessment, management used the criteria
  set forth by the Securities and Exchange Commission in paragraph (d) of Item
  1122 of Regulation AB.

* Based on such assessment, the Company has complied, in all material respects
  with the Applicable Servicing Criteria.

KPMG LLP, an independent registered public accounting firm, has issued an
attestation report with respect to management's assertion of compliance with
the Applicable Servicing Criteria as of and for the Period.


(page)


DEUTSCHE BANK NATIONAL TRUST COMPANY

By: /s/ David Co
Name: David Co
Its: Director

By: /s/ Matt Bowen
Name: Matt Bowen
Its: Managing Director

By: /s/ Kevin Fischer
Name: Kevin Fischer
Its: Director


DEUTSCHE BANK TRUST COMPANY AMERICAS

By: /s/ Jenna Kaufman
Name: Jenna Kaufman
Its: Director


Dated: February 28, 2014