Exhibit 33.1**Management’s Assertion on Compliance with Applicable Servicing Criteria**1. Advanta Bank Corp. (“ABC”) is responsible for assessing compliance with the servicingcriteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for thetwelve months ended December 31, 2007 (the “Reporting Period”), as set forth in Appendix Ahereto. The transactions covered by this report include all asset-backed securitiestransactions conducted by the Advanta Business Card Master Trust backed by revolving businesspurpose credit card receivables for which ABC acted as servicer (the “Platform”); 2. ABC has engaged certain vendors, which are not servicers as defined in Item 1101(j) ofRegulation AB (the “Vendors”), to perform specific, limited or scripted activities, and ABCelects to take responsibility for assessing compliance with the servicing criteria or portionof the servicing criteria applicable to such Vendors’ activities as set forth in Appendix Ahereto; 3. Except as set forth in paragraph 4 below, ABC used the criteria set forth in paragraph (d) ofItem 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 Ahereto are inapplicable to ABC based on the activities it performs, directly or through itsVendors, with respect to the Platform; 5. ABC has complied, in all material respects, with the applicable servicing criteria as ofDecember 31, 2007 and for the Reporting Period with respect to the Platform taken as a whole; 6. ABC has not identified and is not aware of any material instance of noncompliance by theVendors with the applicable servicing criteria as of December 31, 2007 and for the ReportingPeriod with respect to the Platform taken as a whole; 7. ABC has not identified any material deficiency in its policies and procedures to monitor thecompliance by the Vendors with the applicable servicing criteria as of December 31, 2007 andfor the Reporting Period with respect to the Platform taken as a whole; and 8. KPMG LLP, an independent registered public accounting firm, has issued an attestation reporton ABC’s assessment of compliance with the applicable servicing criteria as of December 31,2007 and for the Reporting Period.       ADVANTA BANK CORP.         /s/ Michael Coco Michael Coco    Vice President and Treasurer    Date: March 27, 2008         /s/ David B. Weinstock David B. Weinstock    Vice President    Date: March 27, 2008  

 
APPENDIX A                   **INAPPLICABLE**    **APPLICABLE** **SERVICING****SERVICING CRITERIA** **SERVICING CRITERIA** **CRITERIA**        **Performed by**          **subservicer(s)** **NOT**      **Performed by** **or vendor(s)** **performed by**      **Vendor(s)** **for which** **ABC or by**    **Performed** **for which** **ABC is NOT** **subservicer(s)**    **Directly** **ABC is the** **the** **or vendor(s)**    **by** **Responsible** **Responsible** **retained by****Reference** **Criteria** **ABC** **Party** **Party** **ABC**  **General Servicing Considerations**        1122(d)(1)(i) Policies and procedures areinstituted to monitor anyperformance or other triggers andevents of default in accordancewith the transaction agreements. **X**                 1122(d)(1)(ii) If any material servicingactivities are outsourced tothird parties, policies andprocedures are instituted tomonitor the third party’sperformance and compliance withsuch servicing activities. **X**                 1122(d)(1)(iii) Any requirements in thetransaction agreements tomaintain a back-up servicer forthe pool assets are maintained.       **X**           1122(d)(1)(iv) A fidelity bond and errors andomissions policy is in effect onthe party participating in theservicing function throughout thereporting period in the amount ofcoverage required by andotherwise in accordance with theterms of the transactionagreements.       **X**             **Cash Collection and Administration**        1122(d)(2)(i) Payments on pool assets aredeposited into the appropriatecustodial bank accounts andrelated bank clearing accounts nomore than two business daysfollowing receipt, or such othernumber of days specified in thetransaction agreements. **X****1**                 1122(d)(2)(ii) Disbursements made via wiretransfer on behalf of an obligoror to an investor are made onlyby authorized personnel.       **X**           1122(d)(2)(iii) Advances of funds or guaranteesregarding collections, cash flowsor distributions, and anyinterest or other fees chargedfor such advances, are made,reviewed and approved asspecified in the transactionagreements.       **X**           1122(d)(2)(iv) The related accounts for thetransaction, such as cash reserveaccounts or accounts establishedas a form ofovercollateralization, areseparately maintained (e.g., withrespect to commingling of cash)as set forth in the transactionagreements. **X****2**       1 ABC disburses payments on pool assets to the indenture trustee nomore than two business days following receipt, or such other number of daysspecified in the transaction agreements and directs the indenture trustee tomake deposits into the appropriate custodial bank accounts and related bankclearing accounts. The indenture trustee (another party participating in theservicing function for which ABC is not the responsible party) deposits thepayments into the appropriate custodial bank accounts and related bank clearingaccounts. 2 The transaction accounts have been established at and maintainedwith the indenture trustee (another party participating in the servicingfunction for which ABC is not the responsible party).

 
                   **INAPPLICABLE**    **APPLICABLE** **SERVICING****SERVICING CRITERIA** **SERVICING CRITERIA** **CRITERIA**        **Performed by**          **subservicer(s)** **NOT**      **Performed by** **or vendor(s)** **performed by**      **Vendor(s)** **for which** **ABC or by**    **Performed** **for which** **ABC is NOT** **subservicer(s)**    **Directly** **ABC is the** **the** **or vendor(s)**    **by** **Responsible** **Responsible** **retained by****Reference** **Criteria** **ABC** **Party** **Party** **ABC**1122(d)(2)(v) Each custodial account ismaintained at a federally insureddepository institution as setforth in the transactionagreements. For purposes of thiscriterion, “federally insureddepository institution” withrespect to a foreign financialinstitution means a foreignfinancial institution that meetsthe requirements of Rule13k-1(b)(1) of the SecuritiesExchange Act. **X****3**                 1122(d)(2)(vi) Unissued checks are safeguardedso as to prevent unauthorizedaccess.       **X**           1122(d)(2)(vii) Reconciliations are prepared on amonthly basis for allasset-backed securities relatedbank accounts, includingcustodial accounts and relatedbank clearing accounts. Thesereconciliations are (A)mathematically accurate; (B)prepared within 30 calendar daysafter the bank statement cutoffdate, or such other number ofdays specified in the transactionagreements; (C) reviewed andapproved by someone other thanthe person who prepared thereconciliation; and (D) containexplanations for reconcilingitems. These reconciling itemsare resolved within 90 calendardays of their originalidentification, or such othernumber of days specified in thetransaction agreements. **X**                   **Investor Remittances and Reporting**        1122(d)(3)(i) Reports to investors, includingthose to be filed with theCommission, are maintained inaccordance with the transactionagreements and applicableCommission requirements.Specifically, such reports (A)are prepared in accordance withtimeframes and other terms setforth in the transactionagreements; (B) provideinformation calculated inaccordance with the termsspecified in the transactionagreements; (C) are filed withthe Commission as required by itsrules and regulations; and (D)agree with investors’ or thetrustee’s records as to the totalunpaid principal balance andnumber of pool assets serviced bythe Servicer. **X**                 1122(d)(3)(ii) Amounts due to investors areallocated and remitted inaccordance with timeframes,distribution priority and otherterms set forth in thetransaction agreements. **X****4**                 1122(d)(3)(iii) Disbursements made to an investorare posted within two businessdays to the Servicer’s investorrecords, or such other number ofdays specified in the transactionagreements.       **X**           1122(d)(3)(iv) Amounts remitted to investors perthe investor reports agree withcancelled checks, or other formof payment, or custodial bankstatements.       **X** 3 The transaction accounts have been established at and maintainedwith the indenture trustee (another party participating in the servicingfunction for which ABC is not the responsible party). 4 ABC allocates amounts to investors and makes authorizeddisbursements to the indenture trustee for disbursement to investors. Theindenture trustee (another party participating in the servicing function forwhich ABC is not the responsible party) makes authorized disbursements toinvestors.
 

 
                   **INAPPLICABLE**    **APPLICABLE** **SERVICING****SERVICING CRITERIA** **SERVICING CRITERIA** **CRITERIA**        **Performed by**          **subservicer(s)** **NOT**      **Performed by** **or vendor(s)** **performed by**      **Vendor(s)** **for which** **ABC or by**    **Performed** **for which** **ABC is NOT** **subservicer(s)**    **Directly** **ABC is the** **the** **or vendor(s)**    **by** **Responsible** **Responsible** **retained by****Reference** **Criteria** **ABC** **Party** **Party** **ABC**  **Pool Asset Administration**        1122(d)(4)(i) Collateral or security on poolassets is maintained as requiredby the transaction agreements orrelated mortgage loan documents.       **X**           1122(d)(4)(ii) Pool asset and related documentsare safeguarded as required bythe transaction agreements **X**                 1122(d)(4)(iii) Any additions, removals orsubstitutions to the asset poolare made, reviewed and approvedin accordance with any conditionsor requirements in thetransaction agreements. **X**                 1122(d)(4)(iv) Payments on pool assets,including any payoffs, made inaccordance with the related poolasset documents are posted to theServicer’s obligor recordsmaintained no more than twobusiness days after receipt, orsuch other number of daysspecified in the transactionagreements, and allocated toprincipal, interest or otheritems (e.g., escrow) inaccordance with the related poolasset documents. **X5** **X6**               1122(d)(4)(v) The Servicer’s records regardingthe pool assets agree with theServicer’s records with respectto an obligor’s unpaid principalbalance. **X**                 1122(d)(4)(vi) Changes with respect to the termsor status of an obligor’s poolassets (e.g., loan modificationsor re-agings) are made, reviewedand approved by authorizedpersonnel in accordance with thetransaction agreements andrelated pool asset documents. **X**                 1122(d)(4)(vii) Loss mitigation or recoveryactions (e.g., forbearance plans,modifications and deeds in lieuof foreclosure, foreclosures andrepossessions, as applicable) areinitiated, conducted andconcluded in accordance with thetimeframes or other requirementsestablished by the transactionagreements. **X**                 1122(d)(4)(viii) Records documenting collectionefforts are maintained during theperiod a pool asset is delinquentin accordance with thetransaction agreements. Suchrecords are maintained on atleast a monthly basis, or suchother period specified in thetransaction agreements, anddescribe the entity’s activitiesin monitoring delinquent poolassets including, for example,phone calls, letters and paymentrescheduling plans in cases wheredelinquency is deemed temporary(e.g., illness or unemployment). **X**       5 ABC performs all of the functions under criterion 1122(d)(4)(iv)except for the lockbox and electronic funds transfer functions, which arespecific, limited activities. Payments are posted to accounts based upon ABC’scriteria on a vendor’s data processing system, which is a specific, limitedactivity. 6 For criterion 1122(d)(4)(iv), vendors perform only specific,limited activities of lockbox and electronic funds transfer functions andposting payments to accounts based upon ABC’s criteria on a vendor’s dataprocessing system.
 

 
                   **INAPPLICABLE**    **APPLICABLE** **SERVICING****SERVICING CRITERIA** **SERVICING CRITERIA** **CRITERIA**        **Performed by**          **subservicer(s)** **NOT**      **Performed by** **or vendor(s)** **performed by**      **Vendor(s)** **for which** **ABC or by**    **Performed** **for which** **ABC is NOT** **subservicer(s)**    **Directly** **ABC is the** **the** **or vendor(s)**    **by** **Responsible** **Responsible** **retained by****Reference** **Criteria** **ABC** **Party** **Party** **ABC**1122(d)(4)(ix) Adjustments to interest rates orrates of return for pool assetswith variable rates are computedbased on the related pool assetdocuments. **X7** **X8**               1122(d)(4)(x) Regarding any funds held in trustfor an obligor (such as escrowaccounts): (A) such funds areanalyzed, in accordance with theobligor’s pool asset documents,on at least an annual basis, orsuch other period specified inthe transaction agreements; (B)interest on such funds is paid,or credited, to obligors inaccordance with applicable poolasset documents and state laws;and (C) such funds are returnedto the obligor within 30 calendardays of full repayment of therelated pool assets, or suchother number of days specified inthe transaction agreements.       **X**           1122(d)(4)(xi) Payments made on behalf of anobligor (such as tax or insurancepayments) are made on or beforethe related penalty or expirationdates, as indicated on theappropriate bills or notices forsuch payments, provided that suchsupport has been received by theServicer at least 30 calendardays prior to these dates, orsuch other number of daysspecified in the transactionagreements.       **X** 1122(d)(4)(xii) Any late payment penalties inconnection with any payment to bemade on behalf of an obligor arepaid from the Servicer’s fundsand not charged to the obligor,unless the late payment was dueto the obligor’s error oromission.       **X**           1122(d)(4)(xiii) Disbursements made on behalf ofan obligor are posted within twobusiness days to the obligor’srecords maintained by theServicer, or such other number ofdays specified in the transactionagreements.       **X**           1122(d)(4)(xiv) Delinquencies, charge-offs anduncollectible accounts arerecognized and recorded inaccordance with the transactionagreements. **X9** **X10**               1122(d)(4)(xv) Any external enhancement or othersupport, identified in Item1114(a)(1) through (3) or Item1115 of Regulation AB, ismaintained as set forth in thetransaction agreements.       **X** 7 ABC performs all of the functions under criterion 1122(d)(4)(ix)except for the specific, limited activity of automated adjustments performedbased upon ABC’s criteria on a vendor’s data processing system. 8 The vendor performs only specific, limited activity of automatedadjustments based upon ABC’s criteria on the vendor’s data processing systemfor criterion 1122(d)(4)(ix). 9 ABC performs all of the functions under criterion 1122(d)(4)(xiv).The specific, limited activity of calculating the number of days an account isdelinquent is calculated based upon ABC’s criteria on a vendor’s dataprocessing system. 10 The vendor performs the specific, limited activity of calculatingthe number of days an account is delinquent based upon ABC’s criteria on thevendor’s data processing system for criterion 1122(d)(4)(xiv).