Managements Assertion on Compliance with Applicable Servicing Criteria
 1.
    
    Advanta Bank Corp. (ABC) 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
twelve months ended December 31, 2008 (the Reporting Period), as set forth in Appendix A
hereto. The transactions covered by this report include all asset-backed securities
transactions conducted by the Advanta Business Card Master Trust backed by revolving business
purpose 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) of
Regulation AB (the Vendors), to perform specific, limited or scripted activities, and ABC
elects to take responsibility for assessing compliance with the servicing criteria or portion
of the servicing criteria applicable to such Vendors activities as set forth in Appendix A
hereto;3.
    
    Except as set forth in paragraph 4 below, ABC used the criteria set forth in paragraph (d) of
Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria;4.
    
    The criteria listed in the column titled Inapplicable Servicing Criteria on Appendix A
hereto are inapplicable to ABC based on the activities it performs, directly or through its
Vendors, with respect to the Platform;5.
    
    ABC has complied, in all material respects, with the applicable servicing criteria as of
December 31, 2008 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 the
Vendors with the applicable servicing criteria as of December 31, 2008 and for the Reporting
Period with respect to the Platform taken as a whole;7.
    
    ABC 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, 2008 and
for the Reporting Period with respect to the Platform taken as a whole; and8.
    
    KPMG LLP, an independent registered public accounting firm, has issued an attestation report
on ABCs assessment of compliance with the applicable servicing criteria as of December 31,
2008 and for the Reporting Period.
 ADVANTA BANK CORP./s/ Michael CocoMichael CocoVice President and TreasurerDate:  March 27, 2009/s/ David B. WeinstockDavid B. WeinstockVice PresidentDate:  March 27, 2009




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##### 



INAPPLICABLEAPPLICABLE
    
    SERVICINGSERVICING CRITERIA
    
    SERVICING CRITERIA
    
    CRITERIAPerformed by
    
    NOT performed byPerformed
    
    Performed by
    
    subservicer(s) or
    
    ABC or byDirectly
    
    Vendor(s) for which
    
    vendor(s) for which
    
    subservicer(s) orby
    
    ABC is the
    
    ABC is NOT the
    
    vendor(s) retainedReference
    
    Criteria
    
    ABC
    
    Responsible Party
    
    Responsible Party
    
    by ABCGeneral Servicing Considerations1122(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.
    
    X1122(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.
    
    X1122(d)(1)(iii)
    
    Any requirements in the
transaction agreements to
maintain a back-up servicer for
the pool assets are maintained.
    
    
    
    
    
    
    
    X1122(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.
    
    
    
    
    
    
    
    XCash Collection and Administration1122(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.
    
    X11122(d)(2)(ii)
    
    Disbursements made via wire
transfer on behalf of an obligor
or to an investor are made only
by authorized personnel.
    
    
    
    
    
    
    
    X1122(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.
    
    
    
    
    
    
    
    X1122(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.
    
    X2
 
 1
    
    ABC disburses payments on pool assets to the indenture trustee no
more than two business days following receipt, or such other number of days
specified in the transaction agreements and directs the indenture trustee to
make deposits into the appropriate custodial bank accounts and related bank
clearing accounts. The indenture trustee (another party participating in the
servicing function for which ABC is not the responsible party) deposits the
payments into the appropriate custodial bank accounts and related bank clearing
accounts.2
    
    The transaction accounts have been established at and maintained
with the indenture trustee (another party participating in the servicing
function for which ABC is not the responsible party).




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##### 



INAPPLICABLEAPPLICABLE
    
    SERVICINGSERVICING CRITERIA
    
    SERVICING CRITERIA
    
    CRITERIAPerformed by
    
    NOT performed byPerformed
    
    Performed by
    
    subservicer(s) or
    
    ABC or byDirectly
    
    Vendor(s) for which
    
    vendor(s) for which
    
    subservicer(s) orby
    
    ABC is the
    
    ABC is NOT the
    
    vendor(s) retainedReference
    
    Criteria
    
    ABC
    
    Responsible Party
    
    Responsible Party
    
    by ABC1122(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.
    
    X31122(d)(2)(vi)
    
    Unissued checks are safeguarded
so as to prevent unauthorized
access.
    
    
    
    
    
    
    
    X1122(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.
    
    XInvestor Remittances and Reporting1122(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.
    
    X1122(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.
    
    X41122(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.
    
    
    
    
    
    
    
    X1122(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
 
 3
    
    The transaction accounts have been established at and maintained
with the indenture trustee (another party participating in the servicing
function for which ABC is not the responsible party).4
    
    ABC allocates amounts to investors and makes authorized
disbursements to the indenture trustee for disbursement to investors. The
indenture trustee (another party participating in the servicing function for
which ABC is not the responsible party) makes authorized disbursements to
investors.




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##### 



INAPPLICABLEAPPLICABLE
    
    SERVICINGSERVICING CRITERIA
    
    SERVICING CRITERIA
    
    CRITERIAPerformed by
    
    NOT performed byPerformed
    
    Performed by
    
    subservicer(s) or
    
    ABC or byDirectly
    
    Vendor(s) for which
    
    vendor(s) for which
    
    subservicer(s) orby
    
    ABC is the
    
    ABC is NOT the
    
    vendor(s) retainedReference
    
    Criteria
    
    ABC
    
    Responsible Party
    
    Responsible Party
    
    by ABCPool Asset Administration1122(d)(4)(i)
    
    Collateral or security on pool
assets is maintained as required
by the transaction agreements or
related mortgage loan documents.
    
    
    
    
    
    
    
    X1122(d)(4)(ii)
    
    Pool asset and related documents
are safeguarded as required by
the transaction agreements.
    
    X1122(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.
    
    X1122(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
    
    X51122(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.
    
    X1122(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.
    
    X1122(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
    
    X61122(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
 
 5
    
    For criterion 1122(d)(4)(iv), vendors perform only specific,
limited activities of lockbox, electronic funds transfer functions and posting
payments to accounts based upon ABCs criteria on a vendors data processing
system.6
    
    For criterion 1122(d)(4)(vii), vendors perform only specific,
limited activities of loss mitigation and recovery actions based upon ABCs
criteria on a vendors data processing system.




---



##### 



INAPPLICABLEAPPLICABLE
    
    SERVICINGSERVICING CRITERIA
    
    SERVICING CRITERIA
    
    CRITERIAPerformed by
    
    NOT performed byPerformed
    
    Performed by
    
    subservicer(s) or
    
    ABC or byDirectly
    
    Vendor(s) for which
    
    vendor(s) for which
    
    subservicer(s) orby
    
    ABC is the
    
    ABC is NOT the
    
    vendor(s) retainedReference
    
    Criteria
    
    ABC
    
    Responsible Party
    
    Responsible Party
    
    by ABC1122(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.
    
    X7
    
    X81122(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.
    
    
    
    
    
    
    
    X1122(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.
    
    
    
    
    
    
    
    X1122(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.
    
    
    
    
    
    
    
    X1122(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.
    
    
    
    
    
    
    
    X1122(d)(4)(xiv)
    
    Delinquencies, charge-offs and
uncollectible accounts are
recognized and recorded in
accordance with the transaction
agreements.
    
    X9
    
    X101122(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
 
 7
    
    ABC performs all of the functions under criterion 1122(d)(4)(ix)
except for the specific, limited activity of automated adjustments performed
based upon ABCs criteria on a vendors data processing system.8
    
    The vendor performs only specific, limited activity of automated
adjustments based upon ABCs criteria on the vendors data processing system
for 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 is
delinquent is calculated based upon ABCs criteria on a vendors data
processing system.10
    
    The vendor performs the specific, limited activity of calculating
the number of days an account is delinquent based upon ABCs criteria on the
vendors data processing system for criterion 1122(d)(4)(xiv).