**EXHIBIT 33.1**

 

**Report on Assessment of Compliance with Applicable Regulation AB Servicing Criteria**

 

1.              Ford Motor Credit Company LLC (“Ford Credit”) 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 year ended December 31, 2012 (the “Reporting Period”), including all servicing criteria except for inapplicable servicing criteria identified in paragraph 4 below and the portions of servicing criteria identified in Appendix A to this report.  The transactions covered by this report include asset-backed securities transactions involving automotive dealer floorplan finance receivables completed on or after January 1, 2006 and registered with the Securities Exchange Commission for which Ford Credit acted as servicer (the “Platform”).

 

2.              Ford Credit has engaged vendors that are not servicers as defined in Item 1101(j) of Regulation AB to perform specific, limited or scripted activities with respect to the servicing criteria applicable to such vendors’ activities as set forth in Appendix A to this report.  Ford Credit has elected to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to each vendor.  Ford Credit has policies and procedures in place to provide reasonable assurance that the vendors’ activities comply in all material respects with the servicing criteria or portion of the servicing criteria applicable to each vendor.

 

3.              Except as set forth in paragraph 4 below, Ford Credit 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 servicing criteria in Items 1122(d)(1)(iv), 1122(d)(2)(iii), 1122(d)(2)(v), 1122(d)(2)(vi), 1122(d)(3)(i)(D), 1122(d)(3)(iii), 1122(d)(4)(x) through (xiii) and 1122(d)(4)(xv) are inapplicable to Ford Credit based on the activities it performs, directly or through the indenture trustee, with respect to the Platform.

 

5.              Ford Credit has complied, in all material respects, with the applicable servicing criteria as of December 31, 2012 and for the Reporting Period with respect to the Platform taken as a whole.

 

6.              Ford Credit has not identified and is not aware of any material instance of noncompliance by the vendors with the applicable servicing criteria as of December 31, 2012 and for the Reporting Period with respect to the Platform taken as a whole.

 

7.              Ford Credit has not identified any material deficiency in its policies and procedures to monitor the compliance by the vendors with the applicable servicing criteria as of December 31, 2012 and for the Reporting Period with respect to the Platform taken as a whole.

 

8.              PricewaterhouseCoopers LLP, a registered public accounting firm, has issued an attestation report on Ford Credit’s assessment of compliance with the applicable servicing criteria for the Reporting Period.

 
| March   25, 2013 | Ford   Motor Credit Company LLC |
|------------------|---------------------------------|
|             |                            |
|             |                            |
|             | By:                             | /s/   Brian E. Schaaf |
|             |                            | Brian   E. Schaaf |
|             |                            | Vice   President and Assistant Treasurer |

 

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APPENDIX A

Shared Servicing Criteria

 
| **Reference**  | ** ** | **Criteria**                                                                                                                                                                                                                                                 | ** ** | **Performed   Directly by Ford   Credit**                                 | ** ** | **Performed by   Vendor(s) for   which Ford Credit   is the Responsible   Party** | ** ** | **Performed by   Indenture Trustee**              | ** ** |
|----------------|------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------|-------------------------------------------------------------------------------------|------------|-----------------------------------------------------------------------------------------------------------------|------------|-------------------------------------------------------------|------------|
| 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 days specified in the transaction agreements                  |       | Paying   to indenture trustee                                                       |       |                                                                                                            |       | Depositing   to custodial bank accounts                     |       |
|           |       |                                                                                                                                                                                                                                                         |       |                                                                                |       |                                                                                                            |       |                                                        |       |
| 1122(d)(2)(ii) |       | Disbursements   made via wire transfer on behalf of an obligor or to an investor are made   only by authorized personnel                                                                                                                                     |       | Paying   to indenture trustee                                                       |       |                                                                                                            |       | Disbursing   to investors                                   |       |
|           |       |                                                                                                                                                                                                                                                         |       |                                                                                |       |                                                                                                            |       |                                                        |       |
| 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 |       | Providing   indenture trustee instructions for opening accounts for the transaction |       |                                                                                                            |       | Establishing   and maintaining accounts for the transaction |       |
|           |       |                                                                                                                                                                                                                                                         |       |                                                                                |       |                                                                                                            |       |                                                        |       |
| 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                                                                                         |       | Providing   indenture trustee instructions for making investor distributions        |       |                                                                                                            |       | Remitting   to investors                                    |       |
|           |       |                                                                                                                                                                                                                                                         |       |                                                                                |       |                                                                                                            |       |                                                        |       |
| 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                                                                                                               |       | Preparing   investor reports                                                        |       |                                                                                                            |       | Reconciling   remittances to investors                      |       |

 

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| **Reference**  | ** ** | **Criteria**                                                                                                             | ** ** | **Performed   Directly by Ford   Credit**                              | ** ** | **Performed by   Vendor(s) for   which Ford Credit   is the Responsible   Party** | ** ** | **Performed by   Indenture Trustee** |
|----------------|------------|--------------------------------------------------------------------------------------------------------------------------|------------|----------------------------------------------------------------------------------|------------|-----------------------------------------------------------------------------------------------------------------|------------|------------------------------------------------|
| 1122(d)(4)(i)  |       | Collateral   or security on pool assets is maintained as required by the transaction   agreements or related pool assets |       | Maintaining   security on financed vehicles                                      |       | Perform   on site inventory audits of financed vehicles and related title documents                             |       |                                           |
|           |       |                                                                                                                     |       |                                                                             |       |                                                                                                            |       |                                           |
| 1122(d)(4)(ii) |       | Pool   assets and related documents are safeguarded as required by the transaction   agreements                          |       | Safeguarding   of documents relating to, evidencing and/or securing a receivable |       | Perform   on site inventory audits of financed vehicles and related title documents                             |       |                                           |

 

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