**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 October 31, 2015 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 Platform****1**** (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 October 31, 2015; 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 October 31, 2015.

 

 
|   | U.S.   BANK NATIONAL ASSOCIATION  |
|--------|-----------------------------------|
|   |                              |
|   |                              |
|   | /s/   Bryan R Calder              |
|   | Name:  Bryan R. Calder       |
|   | Title:   Executive Vice President |

 

Date:  January 13, 2016

 

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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 or paying agent services for (i) publicly issued asset-backed and mortgage-backed transactions 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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|--------------------------------|-----------|

 

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