**Exhibit 33.2**

 

Management’s Assertion

 

Report on Assessment of Compliance with Applicable Servicing Criteria

 

 

U.S. Bank National Association (“U.S. Bank”) is responsible for assessing compliance as of and for the year ended November 3, 2019 with the servicing criteria set forth in Item 1122(d) of Regulation AB applicable to it as set forth on Exhibit A hereto.  This report covers asset backed securities transactions within the **U.S. Bank Corporate Trust Asset-Backed Securities Platform1 (the “Platform”).**

 

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

 

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

 

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

 

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

 

4.      U.S. Bank has complied, in all material respects, with the applicable servicing criteria as of and for the year ended November 3, 2019; and

 

5.            Ernst & Young, LLP, a registered public accounting firm, has issued an attestation report on U.S. Bank’s assessment of compliance with the applicable servicing criteria as of and for the year ended November 3, 2019.

 

 
|                               | U.S. BANK NATIONAL ASSOCIATION          |
|------------------------------------|-----------------------------------------|
|                               |                                    |
|                               |                                    |
|                               |    /s/   Joseph Giordano |   |
|                               | Name:  Joseph Giordano             |
|                               | Title:  Executive Vice President   |
|                               |                                    |
| Date:  December 20, 2019 |                                    |

 

 

 

 

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1 The U.S. Bank Corporate Trust Asset-Backed Securities Platform (the "Platform") consists of the activities involved in the performance of servicing functions for which the Company provides trustee, securities administration, registrar and paying agent services for (i) publicly issued asset-backed and mortgage-backed securities transactions the securities of which were offered on or after January 1, 2006 and (ii) certain asset- backed transactions for which the Issuer has voluntarily elected to make Regulation AB compliant filings under the Securities Exchange Act of 1934, as amended.

 

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**EXHIBIT A to Management’s Assertion**

 

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

** ** |
|----------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------|-----------------------------------------------------|
| ** **

**General Servicing Considerations**   |
|  

1122(d)(1)(i)                              |  

Policies and procedures are instituted to monitor any performance or   other triggers and events of default in accordance with the transaction   agreements.                                                                                                                                                                                                                                                  |  

** **                    |  

**X**                                       |
|  

1122(d)(1)(ii)                             |  

If any material   servicing activities are outsourced to third parties, policies and procedures   are instituted to monitor the third party’s performance and compliance with   such servicing activities.                                                                                                                                                                                               | ** **

                     |  

**X**                                       |
|  

1122(d)(1)(iii)                            |  

Any requirements in the   transaction agreements to maintain a back-up servicer for the Pool Assets are   maintained.                                                                                                                                                                                                                                                                                         | ** **

                     |  

**X**                                       |
|  

1122(d)(1)(iv)                             |  

A fidelity bond and   errors and omissions policy is in effect on the party participating in the   servicing function throughout the reporting period in the amount of coverage   required by and otherwise in accordance with the terms of the transaction   agreements.                                                                                                                                     | ** **

                     |  

**X**                                       |
|  

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 following receipt, or such   other number of days specified in the transaction agreements.

                                                                                                                                                    | ** **

                     | ** **

**X**                                   |
|  

1122(d)(2)(ii)                             |  

Disbursements made via   wire transfer on behalf of an obligor or to an investor are made only by   authorized personnel.                                                                                                                                                                                                                                                                                     | ** **

**X**                     | ** **

                                   |
|  

1122(d)(2)(iii)                            |  

Advances of funds or   guarantees regarding collections, cash flows or distributions, and any   interest or other fees charged for such advances, are made, reviewed and   approved as specified in the transaction agreements.                                                                                                                                                                               | ** **

                     |  

**X**                                       |
|  

1122(d)(2)(iv)                             |  

The related accounts for   the transaction, such as cash reserve accounts or accounts established as a   form of over collateralization, are separately maintained (e.g., with respect   to commingling of cash) as set forth in the transaction agreements. 

                                                                                                                                          | ** **

**X**                     | ** **

                                   |
|  

1122(d)(2)(v)                              |  

Each custodial account   is maintained at a federally insured depository institution as set forth in   the transaction agreements. For purposes of this criterion, “federally   insured depository institution” with respect to a foreign financial institution   means a foreign financial institution that meets the requirements of   Rule 13k-1(b)(1) of the Securities Exchange Act. | ** **

**X**                     |  

                                       |
|  

1122(d)(2)(vi)                             |  

Unissued checks are   safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                       | ** **

                     |  

**X**                                       |

 
| Corporate   Trust ABS Platform | 1 |   |
|--------------------------------|---|--------|

 

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

1122(d)(2)(vii)                       |  

Reconciliations are   prepared on a monthly basis for all asset-backed securities related bank   accounts, including custodial accounts and related bank clearing accounts.   These reconciliations are (A) mathematically accurate; (B) prepared   within 30 calendar days after the bank statement cutoff date, or such other   number of days specified in the transaction agreements; (C) reviewed and   approved by someone other than the person who prepared the reconciliation;   and (D) contain explanations for reconciling items. These reconciling   items are resolved within 90 calendar days of their original identification,   or such other number of days specified in the transaction agreements. | ** **

                     |  

**X**                           |
| ** **

**Investor Remittances and Reporting** |
|  

1122(d)(3)(i)                              |  

Reports to investors,   including those to be filed with the Commission, are maintained in accordance   with the transaction agreements and applicable Commission requirements.   Specifically, such reports (A) are prepared in accordance with   timeframes and other terms set forth in the transaction agreements;   (B) provide information calculated in accordance with the terms   specified in the transaction agreements; (C) are filed with the   Commission as required by its rules and regulations; and (D) agree   with investors’ or the trustee’s records as to the total unpaid principal   balance and number of Pool Assets serviced by the Servicer.

                        | ** **

                     |  

**X**                           |
|  

1122(d)(3)(ii)                             |  

Amounts due to investors   are allocated and remitted in accordance with timeframes, distribution   priority and other terms set forth in the transaction agreements.

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **

**X**                     |  

                           |
|  

1122(d)(3)(iii)                            |  

Disbursements made to an   investor are posted within two business days to the Servicer’s investor   records, or such other number of days specified in the transaction   agreements.

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**                     | ** **

                       |
|  

1122(d)(3)(iv)                             |  

Amounts remitted to   investors per the investor reports agree with cancelled checks, or other form   of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ** **

**X**                     | ** **

                       |
| ** **

**Pool Asset Administration**          |
|  

1122(d)(4)(i)                         |  

Collateral or security   on pool assets is maintained as required by the transaction agreements or   related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | ** **

                     |  

**X**                           |
|  

1122(d)(4)(ii)                             |  

Pool assets and related   documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | ** **

                     |  

**X**                           |
|  

1122(d)(4)(iii)                            |  

Any additions, removals   or substitutions to the asset pool are made, reviewed and approved in   accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | ** **

                     |  

**X**                           |
|  

1122(d)(4)(iv)                             |  

Payments on pool assets,   including any payoffs, made in accordance with the related pool asset   documents are posted to the Servicer’s obligor records maintained no more   than two business days after receipt, or such other number of days specified   in the transaction agreements, and allocated to principal, interest or other   items (e.g., escrow) in accordance with the related pool asset documents.                                                                                                                                                                                                                                                                                                                | ** **

                     | ** **

**X**                       |
|  

1122(d)(4)(v)                              | The Servicer’s records   regarding the pool assets agree with the Servicer’s records with respect to   an obligor’s unpaid principal balance.

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | ** **

                     |  

**X**                           |

 
| Corporate   Trust ABS Platform | 2 |   |
|--------------------------------|---|--------|

 

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

1122(d)(4)(vi)        |  

Changes with respect to   the terms or status of an obligor’s pool assets (e.g., loan modifications or   re-agings) are made, reviewed and approved by authorized personnel in   accordance with the transaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                        | ** **

                     |  

**X**                           |
|  

1122(d)(4)(vii)       |  

Loss mitigation or   recovery actions (e.g., forbearance plans, modifications and deeds in lieu of   foreclosure, foreclosures and repossessions, as applicable) are initiated,   conducted and concluded in accordance with the timeframes or other   requirements established by the transaction agreements.

                                                                                                                                                                                                                                                                                                     | ** **

                     |  

**X**                           |
|  

1122(d)(4)(viii)      |  

Records documenting   collection efforts are maintained during the period a pool asset is   delinquent in accordance with the transaction agreements. Such records are   maintained on at least a monthly basis, or such other period specified in the   transaction agreements, and describe the entity’s activities in monitoring   delinquent pool assets including, for example, phone calls, letters and   payment rescheduling plans in cases where delinquency is deemed temporary   (e.g., illness or unemployment).

                                                                                  | ** **

                     |  

**X**                           |
|  

1122(d)(4)(ix)        |  

Adjustments to interest   rates or rates of return for pool assets with variable rates are computed   based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

                     | ** **

**X**

                |
|  

1122(d)(4)(x)         |  

Regarding any funds held   in trust for an obligor (such as escrow accounts): (A) such funds are   analyzed, in accordance with the obligor’s pool asset documents, on at least   an annual basis, or such other period specified in the transaction   agreements; (B) interest on such funds is paid, or credited, to obligors   in accordance with applicable pool asset documents and state laws; and   (C) such funds are returned to the obligor within 30 calendar days of   full repayment of the related pool assets, or such other number of days   specified in the transaction agreements. | ** **

                     | ** **

**X**

                |
|  

1122(d)(4)(xi)        |  

Payments made on behalf   of an obligor (such as tax or insurance payments) are made on or before the   related penalty or expiration dates, as indicated on the appropriate bills or   notices for such payments, provided that such support has been received by the   servicer at least 30 calendar days prior to these dates, or such other number   of days specified in the transaction agreements.                                                                                                                                                                                                                 | ** **

                     |  

**X**                           |
|  

1122(d)(4)(xii)       |  

Any late payment   penalties in connection with any payment to be made on behalf of an obligor   are paid from the Servicer’s funds and not charged to the obligor, unless the   late payment was due to the obligor’s error or omission.                                                                                                                                                                                                                                                                                                                                                                       | ** **

                     |  

**X**                           |
|  

1122(d)(4)(xiii)      |  

Disbursements made on   behalf of an obligor are posted within two business days to the obligor’s   records maintained by the servicer, or such other number of days specified in   the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                      | ** **

                     | ** **

**X**

                |
|  

1122(d)(4)(xiv)  |  

Delinquencies,   charge-offs and uncollectible accounts are recognized and recorded in   accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ** **

                     |  

**X**                           |
|  

1122(d)(4)(xv)        |  

Any external enhancement   or other support, identified in Item 1114(a)(1) through (3) or Item   1115 of Regulation AB, is maintained as set forth in the transaction   agreements.                                                                                                                                                                                                                                                                                                                                                                                                                             | ** **

                     | ** **

**X**

                |

 
| Corporate   Trust ABS Platform | 3 |   |
|--------------------------------|---|--------|

 

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