EXHIBIT 33.1

REPORT ON ASSESSMENT OF COMPLIANCE WITH APPLICABLE SERVICINGCRITERIA PURSUANT TO ITEM 1122 OF REGULATION AB

|1. | CIT Financial USA, Inc. (CIT-FUSA)
          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, 2006 (the Reporting
          Period), as set forth in Appendix A hereto. The transactions
          covered by this report include all publicly issued asset-backed securities
          transactions involving
          equipment loan and lease receivables, which asset-backed securities transactions were issued on or after  January
    1, 2006 for which CIT-FUSA acted as master servicer (the Platform);
|-- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|  
|2. | Except as set forth in paragraph
          3 below, CIT-FUSA 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 Appendix A hereto
          are inapplicable to CIT-FUSA based on the activities it performs with respect to the Platform;                                                                                                                                                                                                                                                                                                                                                                                                                                                                       
|  
|4. | CIT-FUSA has complied, in all material
          respects, with the applicable servicing criteria as of December 31,
          2006 and for the Reporting Period with respect to the Platform taken
          as a whole; and                                                                                                                                                                                                                                                                                                                                                                                                                                                            
|  
|5. | PricewaterhouseCoopers LLP, a registered
          public accounting firm, has issued an attestation report on CIT-FUSAs
          assessment of compliance with the applicable servicing criteria for
          the Reporting Period.                                                                                                                                                                                                                                                                                                                                                                                                                                                  
|  

March 30, 2007

| | CIT Financial USA, Inc., as Servicer
| | ------------------------------------
|
| | By:                                 
| |                                     
| |                                     

---



EXHIBIT 33.1

APPENDIX A

CIT Financial USA, Inc. (the Company)

|Servicing Criteria                 |  | Applicable Servicing Criteria   |  | Inapplicable Servicing Criteria
|---------------------------------- |  | ------------------------------- |  | -------------------------------
|Reference                          |  | Criteria                        |  | Performed                      
|                                   |  |                                 |  | Directly by                    
|                                   |  |                                 |  | the Company                    
|                                   |  |                                 |  |                                
|                                   |  |                                 |  |                                
|                                   |  |                                 |  |                                
|                                   |  |                                 |  |                                
|                                   |  |                                 |  |                                
|General Servicing Considerations   |  |                                 |  |                                
|1122(d)(1)(i)                      |  | Policies and procedures are     |  | X                              
|                                   |  | instituted to monitor any       |  |                                
|                                   |  | performance or other triggers   |  |                                
|                                   |  | and events of default in        |  |                                
|                                   |  | accordance with the             |  |                                
|                                   |  | transaction agreements.         |  |                                
|1122(d)(1)(ii)                     |  | If any material servicing       |  | X1,2                           
|                                   |  | activities are outsourced to    |  |                                
|                                   |  | third parties, policies and     |  |                                
|                                   |  | procedures are instituted to    |  |                                
|                                   |  | monitor the third partys       |  |                                
|                                   |  | performance and compliance      |  |                                
|                                   |  | with such servicing activities. |  |                                
|1122(d)(1)(iii)                    |  | Any requirements in the         |  |                                
|                                   |  | transaction agreements to       |  |                                
|                                   |  | maintain a back-up servicer     |  |                                
|                                   |  | for the pool assets are         |  |                                
|                                   |  | maintained.                     |  |                                
|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.                     |  |                                
|Cash Collection and Administration |  |                                 |  |                                
|1122(d)(2)(i)                      |  | Payments on pool assets are     |  | X3                             
|                                   |  | 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.     |  |                                

---



EXHIBIT 33.1

|Servicing Criteria |  | Applicable Servicing Criteria          |  | Inapplicable Servicing Criteria
|------------------ |  | -------------------------------------- |  | -------------------------------
|Reference          |  | Criteria                               |  | Performed                      
|                   |  |                                        |  | Directly by                    
|                   |  |                                        |  | the Company                    
|                   |  |                                        |  |                                
|                   |  |                                        |  |                                
|                   |  |                                        |  |                                
|                   |  |                                        |  |                                
|                   |  |                                        |  |                                
|1122(d)(2)(ii)     |  | Disbursements made via wire            |  | X4                             
|                   |  | transfer on behalf of an               |  |                                
|                   |  | obligor or to an investor are          |  |                                
|                   |  | made only by authorized                |  |                                
|                   |  | personnel.                             |  |                                
|1122(d)(2)(iii)    |  | Advances of funds or                   |  | X5                             
|                   |  | 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.            |  |                                
|1122(d)(2)(iv)     |  | The related accounts for the           |  | X                              
|                   |  | 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.                |  |                                
|1122(d)(2)(v)      |  | Each custodial account is              |  | X6                             
|                   |  | 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         |  |                                
|                   |  | § 240.13k-1(b)(1) under the Securities |  |                                
|                   |  | Exchange Act of 1934, as amended.      |  |                                
|1122(d)(2)(vi)     |  | Unissued checks are                    |  |                                
|                   |  | safeguarded so as to prevent           |  |                                
|                   |  | unauthorized access.                   |  |                                
|1122(d)(2)(vii)    |  | Reconciliations are prepared           |  | X7                             
|                   |  | 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 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                |  |                                

---



EXHIBIT 33.1

|Servicing Criteria                 |  | Applicable Servicing Criteria     |  | Inapplicable Servicing Criteria
|---------------------------------- |  | --------------------------------- |  | -------------------------------
|Reference                          |  | Criteria                          |  | Performed                      
|                                   |  |                                   |  | Directly by                    
|                                   |  |                                   |  | the Company                    
|                                   |  |                                   |  |                                
|                                   |  |                                   |  |                                
|                                   |  |                                   |  |                                
|                                   |  |                                   |  |                                
|                                   |  |                                   |  |                                
|                                   |  | (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   |  | X8                             
|                                   |  | 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.         |  |                                
|1122(d)(3)(ii)                     |  | Amounts due to investors are      |  | X 9                            
|                                   |  | allocated and remitted in         |  |                                
|                                   |  | accordance with timeframes,       |  |                                
|                                   |  | distribution priority and other   |  |                                
|                                   |  | terms set forth in the            |  |                                
|                                   |  | transaction agreements.           |  |                                
|1122(d)(3)(iii)                    |  | Disbursements made to an          |  | X10                            
|                                   |  | 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     |  | X                              
|                                   |  | per the investor reports agree    |  |                                
|                                   |  | with cancelled checks, or other   |  |                                
|                                   |  | form of payment, or custodial     |  |                                
|                                   |  | bank statements.                  |  |                                
|Pool Asset Administration          |  |                                   |  |                                
|1122(d)(4)(i)                      |  | Collateral or security on pool    |  |                                
|                                   |  | assets is maintained as           |  |                                
|                                   |  | required by the transaction       |  |                                

---



EXHIBIT 33.1

|Servicing Criteria |  | Applicable Servicing Criteria   |  | Inapplicable Servicing Criteria
|------------------ |  | ------------------------------- |  | -------------------------------
|Reference          |  | Criteria                        |  | Performed                      
|                   |  |                                 |  | Directly by                    
|                   |  |                                 |  | the Company                    
|                   |  |                                 |  |                                
|                   |  |                                 |  |                                
|                   |  |                                 |  |                                
|                   |  |                                 |  |                                
|                   |  |                                 |  |                                
|                   |  | agreements or related pool      |  |                                
|                   |  | asset documents.                |  |                                
|1122(d)(4)(ii)     |  | Pool assets and related         |  |                                
|                   |  | documents are safeguarded as    |  |                                
|                   |  | required by the transaction     |  |                                
|                   |  | agreements.                     |  |                                
|1122(d)(4)(iii)    |  | Any additions, removals or      |  | X11                            
|                   |  | substitutions to the asset pool |  |                                
|                   |  | are made, reviewed and          |  |                                
|                   |  | approved in accordance with     |  |                                
|                   |  | any conditions or requirements  |  |                                
|                   |  | in the transaction agreements.  |  |                                
|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.           |  |                                
|1122(d)(4)(v)      |  | The servicers records          |  | X12                            
|                   |  | regarding the pool assets agree |  |                                
|                   |  | with the servicers records     |  |                                
|                   |  | with respect to an obligors    |  |                                
|                   |  | unpaid principal balance.       |  |                                
|1122(d)(4)(vi)     |  | Changes with respect to the     |  |                                
|                   |  | terms or status of an obligors |  |                                
|                   |  | 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.     |  |                                
|1122(d)(4)(viii)   |  | Records documenting             |  |                                
|                   |  | collection efforts are          |  |                                
|                   |  | maintained during the period a  |  |                                

---



EXHIBIT 33.1

|Servicing Criteria |  | Applicable Servicing Criteria     |  | Inapplicable Servicing Criteria
|------------------ |  | --------------------------------- |  | -------------------------------
|Reference          |  | Criteria                          |  | Performed                      
|                   |  |                                   |  | Directly by                    
|                   |  |                                   |  | the Company                    
|                   |  |                                   |  |                                
|                   |  |                                   |  |                                
|                   |  |                                   |  |                                
|                   |  |                                   |  |                                
|                   |  |                                   |  |                                
|                   |  | 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).         |  |                                
|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.             |  |                                
|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 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.       |  |                                

---



EXHIBIT 33.1

|Servicing Criteria |  | Applicable Servicing Criteria   |  | Inapplicable Servicing Criteria
|------------------ |  | ------------------------------- |  | -------------------------------
|Reference          |  | Criteria                        |  | Performed                      
|                   |  |                                 |  | Directly by                    
|                   |  |                                 |  | the Company                    
|                   |  |                                 |  |                                
|                   |  |                                 |  |                                
|                   |  |                                 |  |                                
|                   |  |                                 |  |                                
|                   |  |                                 |  |                                
|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.                       |  |                                
|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.     |  |                                
|1122(d)(4)(xiv)    |  | Delinquencies, charge-offs      |  | X13                            
|                   |  | and uncollectable accounts are  |  |                                
|                   |  | recognized and recorded in      |  |                                
|                   |  | accordance with the             |  |                                
|                   |  | transaction agreements.         |  |                                
|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.     |  |                                

---



EXHIBIT 33.1

Footnotes to Appendix A Servicing Criteria

1The Company
only provides certain limited monitoring of the lockbox function provided by
JPMorgan Chase Bank, N.A., a vendor retained by its subservicers, CIT Communications Finance Corporation
and  CIT Technology Financing Services, Inc. The Companys monitoring of
this function primarily consists of relationship management, including participation in periodic site visits to inspect such vendors operations as they relate to the lockbox function. All other monitoring of the lockbox
function provided to subservicers, CIT Communications Finance Corporation and
CIT  Technology Financing Services, Inc., is performed by such subservicers.

2The Company only provides certain limited monitoring of the document imaging and storage function provided by Archive Systems, Inc., a vendor retained by its subservicers, CIT Communications Finance
Corporation and CIT Technology Financing Services, Inc. The Companys monitoring of this function consists of accessing the vendors computer network for purposes of monitoring system availability and performance. All other monitoring of
the document imaging and storage function provided to subservicers, CIT Communications Finance Corporation and CIT Technology Financing Services, Inc., is performed by such subservicers.

3The Company performs all of criterion 1122(d)(2)(i) only with respect to collecting payments on pool assets received from subservicer, Dell Financial Services, L.P.  Such
subservicer and its lockbox vendors perform the remainder of criterion 1122(d)(2)(i) with respect to collecting payments on such pool assets from obligors.

4The Company performs all of criterion 1122(d)(2)(ii) with respect to authorized disbursements of funds from its own concentration account to the indenture trustee. Such funds
represent payments on pool assets received from subservicer, Dell Financial Services, L.P. The Company also instructs subservicers, CIT Communications Finance Corporation and CIT Technology Financing Services, Inc., as to timing and amounts of
disbursements of funds to the indenture trustee from accounts held by such subservicers.  The indenture trustee makes disbursements to investors. The indenture trustee for the transaction is not required to furnish an assessment and attestation
under Item 1122 of Regulation AB. The Company does not make disbursements on behalf of an obligor.

5The Company performs all of criterion 1122(d)(2)(iii) with respect to advances of funds from its own concentration account. The Company also reviews and approves advances of
funds and any interest and other fees charged for such advances made by its subservicers, CIT Communication Finance Corporation and CIT Technology Financing Services, Inc., from accounts held by such subservicers. The Company does not guarantee collections, cash flows or
distributions.

6The Company performs all of criterion 1122(d)(2)(v) only with respect to the related accounts for the transaction and its own concentration account. Its subservicers perform
criterion 1122(d)(2)(v) with respect to accounts held by such subservicers.

7The Company performs all of criterion 1122(d)(2)(vii) only with respect to its own concentration account.  Its subservicers perform criterion 1122(d)(2)(vii) with respect to
accounts held by such subservicers.

8Part (D) of criterion 1122(d)(3)(i) is inapplicable to the Company. The Company does not have access to investors or the trustees records as to the total unpaid principal balance and number of pool assets serviced.

9The Company performs all of criterion  1122(d)(3)(ii) with
respect to  allocations  of amounts due  investors and  remittance  from its own
concentration  account of such amounts to the indenture  trustee.    The  Company  also   instructs
subservicers, CIT Communications Finance Corporation and CIT Technology Financing
Services,  Inc.,  as to timing  and  amounts  of  remittances  to the  indenture
trustee. The indenture
trustee   remits  such  amounts  to  investors. The indenture trustee for the transaction is not required to furnish an
assessment and attestation under Item 1122 of Regulation AB.

10The Company performs all of criterion 1122(d)(3)(iii) only with respect to posting of disbursements to the indenture trustee from its own concentration account. Its subservicers, CIT Communications Finance Corporation and CIT Technology Financing Services, Inc.,
perform criterion 1122(d)(3)(iii) with respect to posting of disbursements to the indenture trustee from accounts held by such subservicers. The indenture trustee makes disbursements to investors. The indenture trustee for the transaction is not
required to furnish an assessment and attestation under Item 1122 of Regulation AB.

11The Company performs all of criterion 1122(d)(4)(iii) with respect to additions, removals or substitutions made with respect to pool assets serviced by subservicer, Dell
Financial Services, L.P.  The Company also reviews, approves and issues instructions with respect to additions, removals or substitutions made with respect to pool assets serviced by its other subservicers.

12The Company performs criterion 1122(d)(4)(v) only to the extent of receiving and recording information about pool assets and obligor unpaid principal balances from its
subservicers in the form of raw data input from such subservicers platform receivables systems.  Such information is initially determined and recorded by each subservicer.

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EXHIBIT 33.1

13The Company performs criterion 1122(d)(4)(xiv) only to the extent of receiving and recording information about delinquencies, chargeoffs and uncollectible accounts from its
subservicers in the form of raw data input from such subservicer's platform receivable system.  Delinquencies, chargeoffs and uncollectible accounts are initially recognized and recorded by each subservicer.

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