**EXHIBIT 33.1**

 

**Certification Regarding Compliance with Applicable Servicing Criteria**

 

1.                                                                                      New Holland Credit Company, LLC (“New Holland”) is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the 12-month period ending December 31, 2018 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report include publicly registered asset-backed securities transactions for which New Holland acted as servicer involving equipment receivables, other than transactions registered prior to compliance with Regulation AB (the “Platform”);

 

2.                                                                                      New Holland has engaged certain vendors (the “Vendors”) to perform specific, limited or scripted activities, and New Holland elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors’ activities as set forth in Appendix A hereto;

 

3.                                                                                      Except as set forth in paragraph 4 below, New Holland used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria;

 

4.                                                                                      The criteria listed in the column titled “Inapplicable Servicing Criteria” on Appendix A hereto are inapplicable to New Holland based on the activities it performs, directly or through its Vendors, with respect to the Platform;

 

5.                                                                                      New Holland has complied, in all material respects, with the applicable servicing criteria to it as set forth on Appendix A hereto as of December 31, 2018 and for the Reporting Period with respect to the Platform taken as a whole;

 

6.                                                                                      New Holland has not identified and is not aware of any material instance of noncompliance by the Vendors with the applicable servicing criteria to them as set forth on Appendix A hereto as of December 31, 2018 and for the Reporting Period with respect to the Platform taken as a whole;

 

7.                                                                                      New Holland has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors with the applicable servicing criteria to them as set forth on Appendix A hereto as of December 31, 2018 and for the Reporting Period with respect to the Platform taken as a whole;

 

8.                                                                                      None of the Vendors are servicers as defined in Item 1101(j) of Regulation AB;

 

9.                                                                                      New Holland has policies and procedures in place designed to provide reasonable assurance that the Vendors’ activities comply in all material respects with the servicing criteria applicable to such Vendors; and

 

10.                                                                               Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report on New Holland’s assessment of compliance with the applicable servicing criteria as set forth on Appendix A hereto as of December 31, 2018 and for the Reporting Period.

 
| March 25, 2019 |                            |
|---------------------|---------------------------------|
|                |                            |
|                | New Holland Credit Company, LLC |
|                |                            |
|                |                            |
|                | By:                             | /s/ Brett D. Davis |
|                | Name:                           | Brett D. Davis |
|                | Title:                          | President |

 

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** **

**APPENDIX A**

 
| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               | ** ** | **Criteria**                                                                                                                                                                                                                                                            | ** ** | **Performed   Directly   by   New   Holland** | ** ** | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** | ** ** | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       |                                                                                                                                                                                                                                                                    |       |                                          |   |   |   |   |
|                        |       | **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** |
| 1122(d)(1)(v)               |       | Aggregation of information, as applicable, is mathematically   accurate and the information conveyed accurately reflects the information.                                                                                                                               |       | **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 of receipt, or such other number of                                                                            |       | **X**                                         |   | **X** |   |   |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                      | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               | ** ** | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                  | ** ** | **Performed   Directly   by   New   Holland** | ** ** | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** | ** ** | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                 |       |                                          |   |   |   |   |
| 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 overcollateralization, 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 (A) are mathematically   accurate; (B) are prepared within 30 calendar days                                                                                                                       |       | **X**                                         |   |   |   |   |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               | ** ** | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** ** | **Performed   Directly   by   New   Holland** | ** ** | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** | ** ** | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | after the bank statement cutoff date, or such other number of   days specified in the transaction agreements; (C) are 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.                                                                                                                                                                                                                                                   |       |                                          |   |   |   |   |
|                        |       |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |       |                                          |   |   |   |   |
|                        |       | **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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |       | **X**                                         |   |   |   |   |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                               | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               | ** ** | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                           | ** ** | **Performed   Directly   by   New   Holland** | ** ** | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** | ** ** | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | investor are posted within two business days to the servicer’s   investor records, or such other number of days specified in the transaction   agreements.                                                                                                                                                                                                                                                                        |       | ** **                                    |   |   |   |   |
| 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**                                         |   | **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 applicable   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                                                                                                                                                                                                                                                                                                                                                                       |       | **X**                                         |   |   |   |   |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               | ** ** | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** ** | **Performed   Directly   by   New   Holland** | ** ** | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** | ** ** | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | pool asset (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.                                                                                                                                                                                                                                                                                                                                  |       | ** **                                    |   |   |   |   |
| 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**                                         |   |   |   |   |
| 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                                                                                                                                                                                                                                                                              |       |                                          |   |   |   | **X** |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                                                                                                                                                                                                                                                                                                                                                  | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               | ** ** | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                              | ** ** | **Performed   Directly   by   New   Holland** | ** ** | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** | ** ** | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | 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.                                       |       |                                          |   |   |   |   |
| 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 uncollectable 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                                                                                                                                                                                                                                                                                                       |       |                                          |   |   |   | **X** |

 

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| **SERVICING CRITERIA** | ** ** | **APPLICABLE   SERVICING CRITERIA**                                           | ** ** | **INAPPLICABLE   SERVICING   CRITERIA**       |
|-----------------------------|------------|------------------------------------------------------------------------------------|------------|-----------------------------------------------|
| **Reference**               | ** ** | **Criteria**                                                                       | ** ** | **Performed   Directly   by   New   Holland** | ** ** | **Performed   by   Vendor(s)   for which   New Holland   is the   Responsible   Party** | ** ** | **NOT performed by   New   Holland or by   subservicer(s) or   vendor(s) retained   by   New Holland** |
|                        |       | 1115 of Regulation AB, is maintained as set forth in the   transaction agreements. |       |                                          |   |   |   |   |

 

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