10-K

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM 10-K

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE

SECURITIES EXCHANGE ACT OF 1934

☒ ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2021

☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from                      to                     

333-205992-02

(Commission File Number of Issuing Entity)

Volkswagen Auto Loan Enhanced Trust 2018-2

(Exact name of Issuing Entity as specified in its charter)

Central Index Key Number of Issuing Entity: 0001756401

Volkswagen Auto Lease/Loan Underwritten Funding, LLC

(Exact name of Depositor as specified in its charter)

Central Index Key Number of Depositor: 0001182534

VW Credit, Inc.

(Exact name of Sponsor as specified in its charter)

Central Index Key Number of Securitizer: 0000833733

State of Delaware	83-6429606
(State or other jurisdiction of incorporation or organization of Registrant)	(I.R.S. Employer Identification No. of Registrant)

2200 Woodland Pointe Avenue Herndon, Virginia	20171 (Zip Code of Registrant)
(Address of principal executive offices of Registrant)

(703) 364-7000

(Registrant’s telephone number, including area code)

Securities registered pursuant to Section 12(b) of the Securities Exchange Act:

Title of each class	Name of each exchange on which registered
None	None

Securities registered pursuant to Section 12(g) of the Securities Exchange Act: None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.    ☐  Yes    ☒  No

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Securities Exchange Act.    ☐   Yes    ☒  No

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.    ☒  Yes    ☐  No

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§ 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such files).    ☒  Yes    ☐  No

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer:	☐	Accelerated filer:	☐
Non-accelerated filer:	☒	Smaller reporting company:	☐
		Emerging growth company:	☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.  ☐

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report.  ☐

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Securities Exchange Act).     Yes  ☐    No  ☒

State the aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the price at which the common equity was last sold, or the average bid and asked price of such common equity, as of the last business day of the registrant’s most recently completed second fiscal quarter. None

Documents incorporated by reference: None

FORM 10-K

PART 1

THE FOLLOWING ITEMS HAVE BEEN OMITTED IN ACCORDANCE WITH GENERAL INSTRUCTION J(1) TO FORM 10-K:

(A) Item 1	Business.
(B) Item 1A	Risk Factors.
(C) Item 2	Properties.
(D) Item 3	Legal Proceedings.

Item 1B. Unresolved Staff Comments.

Not Applicable.

Item 4. Mine Safety Disclosures.

Not Applicable.

PART II

THE FOLLOWING ITEMS HAVE BEEN OMITTED IN ACCORDANCE WITH GENERAL INSTRUCTION J(1) TO FORM 10-K:

(A) Item 5	Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities.
(B) Item 6	Selected Financial Data
(C) Item 7	Management’s Discussion and Analysis of Financial Condition and Results of Operations.
(D) Item 7A	Quantitative and Qualitative Disclosures About Market Risk.
(E) Item 8	Financial Statements and Supplementary Data.
(F) Item 9	Changes in and Disagreements with Accountants on Accounting and Financial Disclosure.
(G) Item 9A	Controls and Procedures.

Item 9B. Other Information.

None.

PART III

THE FOLLOWING ITEMS HAVE BEEN OMITTED IN ACCORDANCE WITH GENERAL INSTRUCTION J(1) TO FORM 10-K:

(A) Item 10	Directors, Executive Officers and Corporate Governance.
(B) Item 11	Executive Compensation.
(C) Item 12	Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters.
(D) Item 13	Certain Relationships and Related Transactions, and Director Independence.
(E) Item 14	Principal Accountant Fees and Services.

PART IV

Item 15. Exhibits and Financial Statement Schedules.

(a) (1) Not applicable.

(2) Not applicable.

(3) The exhibits filed in response to Item 601 of Regulation S-K are listed in the Exhibit Index.

(b) The exhibits filed in response to Item 601 of Regulation S-K are listed in the Exhibit Index.

(c) None.

Item 16. Form 10-K Summary.

Not Applicable.

SUBSTITUTE INFORMATION PROVIDED IN ACCORDANCE WITH GENERAL INSTRUCTION J(2) TO FORM 10-K:

Item 1112(b) of Regulation AB. Significant Obligors of Pool Assets (Financial Information).

Not Applicable.

Item 1114(b)(2) of Regulation AB. Credit Enhancement and Other Support, Except for Certain Derivatives Instruments (Information Regarding Significant Enhancement Providers).

Not Applicable.

Item 1115(b) of Regulation AB. Certain Derivatives Instruments (Financial Information).

Not Applicable.

Item 1117 of Regulation AB. Legal Proceedings.

VW Credit, Inc. (“VW Credit”) and its affiliates (including Volkswagen Aktiengesellschaft (“Volkswagen AG”)) are party to, or are periodically otherwise involved in, reviews, investigations, examinations and proceedings (both formal and informal), and information-gathering requests, by government and self-regulatory agencies, including the CFPB, the U.S. Department of Justice (the “DOJ”), the U.S. Securities and Exchange Commission (the “SEC”), and various state authorities. On September 18, 2015, the U.S. Environmental Protection Agency (“EPA”) publicly announced in a “Notice of Violation” that irregularities in relation to nitrogen oxide (NOx) emissions had been discovered in emissions tests on certain vehicles of the VW Credit’s ultimate parent, Volkswagen AG, with type 2.0 liter diesel engines in the United States. In this context, Volkswagen AG announced that noticeable discrepancies between the figures achieved in testing and in actual road use had been identified in type EA189 diesel engines and that around eleven million vehicles with such engines were sold worldwide. On November 2, 2015, the EPA issued a “Notice of Violation” alleging that irregularities had also been discovered in the software installed in type V6 3.0 liter vehicles sold in the United States (2.0 liter and 3.0 liter vehicles together, “Affected Vehicles”).

Following the Notice of Violation, Volkswagen AG, Volkswagen Group of America, Inc., and certain affiliates (collectively, “Volkswagen”) have been party to or have otherwise been involved in multiple criminal and regulatory investigations and legal actions related to the Affected Vehicles, including lawsuits by the EPA, the DOJ, the Federal Trade Commission (the “FTC”), California Air Resources Board (the “CARB”) and the attorneys general of numerous states, as well as several private civil lawsuits brought by owners and lessees of Affected Vehicles and dealers. Work in respect of the legal proceedings that are still pending in the U.S. and the rest of the world is ongoing, will require considerable efforts and coordination from Volkswagen, may demand significant management resources, and is expected to continue for some time. Ongoing and potential further legal proceedings related to the diesel issue could result in considerable further financial charges.

Volkswagen AG and certain affiliates reached settlement agreements with various government authorities and private plaintiffs, the latter represented by a Plaintiffs’ Steering Committee in a multidistrict litigation in California. These settlement agreements resolved certain civil claims as well as criminal charges under federal law and the laws of certain states in connection with the diesel issue.

Several thousand consumers opted out of the settlement agreements, and many of these consumers filed civil lawsuits seeking monetary damages for fraud and violations of state consumer protection acts. Various subsequent resolutions have eliminated nearly all of the cases brought by the original consumer opt-outs. The first opt-out trial was held February 24, 2020 to March 10, 2020 in the federal MDL; the defendants in that trial were Volkswagen Group of America, Inc. and Volkswagen AG only. In the aggregate, the ten opt-out plaintiffs were awarded $28,735 in damages. The ten trial plaintiffs filed notices of appeal to the U.S. Court of Appeals for the Ninth Circuit (“Ninth Circuit”); briefing was completed

in November 2021, and oral argument occurred on December 10, 2021. Additionally, an action was brought by private plaintiffs purporting to represent a putative class of individuals who purchased or leased TDI vehicles but who no longer owned or leased those vehicles on September 18, 2015 (the “Pre-NOV Action”). The Pre-NOV Action was dismissed on November 12, 2020 after targeted discovery focused only on the question of damages, and the Ninth Circuit affirmed dismissal on January 20, 2022.

Volkswagen AG, AUDI AG and other Volkswagen affiliates have further agreed to pay a combined civil penalty of $1.45 billion to resolve U.S. federal environmental and customs-related claims in the United States. Furthermore, Volkswagen AG and Volkswagen Group of America, Inc. have agreed to pay a smaller civil penalty to the DOJ to settle other potential claims arising under Federal statute. DOJ investigations into the conduct of various individuals who may be responsible for criminal violations relating to the diesel issue remain ongoing. Volkswagen is required to cooperate with these investigations.

In May 2018, the DOJ unsealed charges in Detroit against, among others, former Volkswagen CEO Martin Winterkorn, which had been filed under seal in March 2018. Mr. Winterkorn is charged with a conspiracy to defraud the United States, to commit wire fraud, and to violate the Clean Air Act from at least May 2006 through at least November 2015, as well as three counts of wire fraud. Should these proceedings result in adverse court decisions against the individuals involved, this could have a negative impact on the outcome of other proceedings against Volkswagen and/or could have other material adverse financial consequences.

Investigations by various U.S. regulatory and other government authorities, including in areas relating to securities, tax and financing, are ongoing. On March 14, 2019, the SEC filed a complaint in the U.S. District Court for the Northern District of California, against Volkswagen AG, Volkswagen Group of America Finance, VW Credit and the former Volkswagen CEO, Martin Winterkorn, alleging violations of the antifraud provisions of the federal securities laws in connection with securities sold in the U.S. The SEC complaint seeks permanent injunctions, disgorgement of allegedly ill-gotten gains with prejudgment interest, and civil penalties. On April 10, 2020, Volkswagen and Mr. Winterkorn separately filed motions to dismiss the SEC’s complaint. In August 2020, the court granted in part and denied in part Volkswagen AG, Volkswagen Group of America Finance and VW Credit’s motion to dismiss. The claims dismissed by the court included all claims against VW Credit related to asset-backed securities. In September 2020, the SEC filed an amended complaint that, among other things, removed the dismissed claims.

The attorneys general of Texas and some municipalities have suits pending in state and federal courts against Volkswagen AG, Volkswagen Group of America, Inc. and/or certain affiliates, alleging violations of environmental laws. In February 2021, Texas sought discretionary review by the Texas Supreme Court of a Texas appellate court decision dismissing Texas’s state environmental claims against Volkswagen AG and AUDI AG for lack of personal jurisdiction; some of Texas’s claims against other Volkswagen entities remain pending. In January 2022, the Texas Supreme Court agreed to hear Texas’s appeal. In November 2021, the United States Supreme Court declined to review both a decision by the US Court of Appeals for the Ninth Circuit that had declined to dismiss certain claims brought by Hillsborough and Salt Lake Counties and a decision by the Ohio Supreme Court that had declined to dismiss certain claims brought by Ohio.

A putative class action has also been filed on behalf of purchasers of certain U.S. Dollar-denominated Volkswagen bonds, alleging that these bonds were trading at artificially inflated prices due to Volkswagen’s alleged misstatements and that the value of these bonds declined after the EPA issued its “Notices of Violation”. This lawsuit has been consolidated in the federal multidistrict litigation proceeding in the State of California. On June 25, 2021, the Ninth Circuit granted the Volkswagen defendants’ interlocutory appeal, reversing the district court’s denial of Volkswagen’s motion for summary judgment. In July 2021, plaintiff petitioned the Ninth Circuit for rehearing either before the original panel or en banc. On September 23, 2021, the Ninth Circuit denied the petition for rehearing or rehearing en banc. On October 12, 2021, the Ninth Circuit issued the mandate formally entering its judgment of reversal and remanding to the district court for determination as to whether summary judgment should be granted. No provisions have been recognized. In addition, contingent liabilities have not been disclosed as they currently cannot be measured.

Since November 2016, Volkswagen has been responding to information requests from the EPA and CARB related to automatic transmissions in certain vehicles. In 2020, Dr. Ing. hc F. Porsche AG (“Porsche AG”) discovered potential regulatory irregularities relating to vehicles for various markets worldwide. There are questions as to the permissibility of specific hardware and software components used in type approval measurements. Differences compared with production versions may also have occurred in certain cases. Based on the information presently available, the current production is not affected. The issues are unrelated to the defeat devices that were at the root of the diesel emissions issue. Porsche AG is cooperating with the relevant governmental authorities. Based on the available information, no formal criminal investigation has been opened against the company. Porsche AG’s own internal investigations are still in progress. In January 2021, a consolidated complaint was filed with the U.S. District Court for the Northern District of California alleging that the affected

vehicles used certain software and/or hardware that resulted in increased emissions and/or overstated fuel economy estimates as compared to the results of certification testing. The defendants (Volkswagen AG, Porsche AG, and Porsche Cars North America, Inc.) have moved for dismissal of the action.

In March 2020, the US District Court for the Northern District of California dismissed two amended class action complaints brought by direct and indirect purchasers of German luxury vehicles alleging that several automobile manufacturers, including Volkswagen AG and other Volkswagen Group companies, conspired to unlawfully increase the prices of German luxury vehicles in violation of US antitrust and consumer protection law. The court held that the plaintiffs have not stated a claim for relief because the allegations in the complaints do not plausibly support that the alleged agreements unreasonably restrained competition in violation of U.S. law. The court granted plaintiffs leave to file amended complaints with respect to a limited subset of plaintiffs’ original claims. Plaintiffs filed a second set of amended complaints in June 2020, which defendants moved to dismiss in August 2020. In October 2020, the court granted defendants’ motion and dismissed with prejudice the amended complaints in their entirety. The direct purchaser plaintiffs appealed this ruling, and in October 2021, the US Court of Appeals for the Ninth Circuit affirmed the district court’s ruling. After receiving an extension until December 27, 2021, the direct purchaser plaintiffs filed a motion for rehearing, which the Ninth Circuit denied on January 25, 2022. On December 28, 2021, the direct purchaser plaintiffs filed a motion seeking to set aside the District Court’s October 2020 judgment and to be allowed to file a new amended complaint, which the court denied on February 22, 2022. The indirect purchaser plaintiffs voluntarily dismissed their appeal in August 2021.

Similar proceedings have been initiated in Canada though no steps have been taken by the plaintiffs to advance these claims. They remain at a pre-certification stage. If the claims are in fact pursued they will be opposed in Canada as well.

Additionally, in August 2017, Volkswagen AG and certain of its current and former executives and directors were named as defendants in a putative class action filed in the United States District Court for the Eastern District of New York. The complaint asserts claims under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 and Rule 10b-5 promulgated thereunder, based on allegations relating to statements in Volkswagen AG’s Annual Reports for the years 2012 through 2016 regarding Volkswagen AG’s compliance measures, in particular those relating to competition and antitrust law, as well as allegations in an antitrust litigation against Volkswagen AG in the Northern District of California. In May 2020, the court dismissed with prejudice plaintiffs’ complaint, ruling that none of the statements identified by plaintiffs gave rise to a cause of action under U.S. securities laws. Plaintiffs appealed to the U.S. Court of Appeals for the Second Circuit, which affirmed the District Court’s dismissal with prejudice on March 15, 2022.

On July 22, 2020, an alleged Volkswagen AG shareholder filed in New York state court a derivative lawsuit in New York County Supreme Court purportedly on behalf of Volkswagen AG against current and former members of Volkswagen AG’s Supervisory Board, current and former members of Volkswagen AG’s Management Board, current and former executives of Volkswagen AG and its subsidiaries, four Volkswagen AG subsidiaries, Robert Bosch GmbH, and a Bosch affiliate and executive. The complaint alleges that the individual defendants breached their fiduciary duties to Volkswagen AG under German law by failing to properly supervise Volkswagen AG’s business and thereby permitting the diesel misconduct to occur. On April 28, 2021, a new complaint purporting to assert similar claims was filed by the same alleged Volkswagen AG shareholder which adds an additional plaintiff and also names as defendants Porsche SE and additional executives of Volkswagen AG’s subsidiaries.

Outside the United States, Volkswagen also reached agreements with regard to the implementation of technical measures with numerous authorities. In Canada, which has the same NOx emissions limits as the United States, there have been civil consumer claims and regulatory investigations for vehicles with 2.0 liter and 3.0 liter diesel engines. Volkswagen reached settlements in Canada with consumers relating to 2.0 liter and 3.0 liter diesel vehicles. As to pending matters in Canada, an environmental class action has been authorized on behalf of residents in Quebec. This action was authorized on the sole issue of whether punitive damages could be recovered and on the basis that unresolved questions about the viability of plaintiffs’ damages theory would be a matter for trial. The action has now been settled for an all-inclusive settlement payment of CAD6.7M and is awaiting court approval.

Other class action and joinder lawsuits have also been filed in Canada, including alleged consumer protection and securities claims, asserting damages among other things. While a class action filed in Quebec provincial court was authorized as to claims relating to Volkswagen AG’s shares, ADRs and debt securities, the case was dismissed by the Quebec court on April 16, 2020 for lack of jurisdiction. The plaintiff has appealed the dismissal and Volkswagen AG has cross-appealed on the basis that forum non conveniens is an alternative ground for dismissal; the hearings for both appeal and cross-appeal occurred in October 2021.

In some countries criminal investigations/misdemeanor proceedings (for example, by the public prosecutor’s offices in Braunschweig and Munich, Germany) and/or administrative proceedings (for example, by the German Federal Financial

Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht – “BaFin”) have been opened involving Volkswagen AG. Some of these regulatory offense proceedings against Volkswagen AG were terminated in 2018 and 2019, with the authorities issuing administrative notices imposing fines on Volkswagen Group companies. Volkswagen AG has accepted the fines and will not appeal. The BaFin proceedings have also been finally terminated.

In November 2015, Volkswagen also reported that internal indicators had caused concerns that there might have been irregularities in determining carbon dioxide (“CO2”) figures for type approval of around 800,000 vehicles and, as a result, the CO2 values and therefore the fuel consumption data published for some vehicle models might have been stated incorrectly. Subsequent measurements performed in coordination with the relevant authorities showed that those concerns of possible irregularities in the CO2 figures for type approval proved to be not correct. Hence, the negative impact on Volkswagen’s earnings of EUR 2 billion that had originally been expected in relation to this aspect of the CO2 issue was not confirmed. However the public prosecutor’s office in Braunschweig is investigating these circumstances.

Proceedings are ongoing in relation to current and former employees of Volkswagen. In July 2018, the public prosecutor’s office in Braunschweig formally opened a misdemeanor proceeding in this regard against Volkswagen AG. On September 24, 2019, the Braunschweig public prosecutor brought charges of alleged market manipulation against Volkswagen AG Chief Executive Officer Herbert Diess, Supervisory Board Chairman Hans Dieter Pötsch, and former CEO Martin Winterkorn in relation to the diesel emissions matter. The September 2019 proceedings have been finally dismissed with regard to one current and one former board member and with regard to Volkswagen AG, while the September 2019 proceedings with regard to the former CEO of Volkswagen AG, Martin Winterkorn, have been provisionally terminated. The Stuttgart public prosecutor’s office has commenced a criminal investigation into the diesel issue against one board member and several employees of Porsche AG on suspicion of fraud and illegal advertising. Furthermore, the public prosecutor’s office in Munich II opened a criminal investigation in connection with the alleged anomalies in the NOx emissions of certain Audi vehicles with diesel engines in the United States and Europe. On June 11, 2018, Rupert Stadler, the head of Volkswagen AG’s Audi brand was named as a suspect in the Munich II public prosecutor’s investigation together with Bernd Martens, Audi’s head of purchasing. Both are being investigated for, inter alia, fraud relating to sales of diesel cars. Rupert Stadler was arrested on June 18, 2018, and resigned as CEO of AUDI AG in October 2018. In July 2019, the Munich II public prosecutor brought criminal charges against, among others, former Audi CEO, Rupert Stadler, in relation to alleged crimes tied to the diesel issue. In June 2020, the Munich II Regional Court allowed the prosecution’s charges in respect to four suspects, including the former Audi CEO, and opened the main proceedings. The trial began in September 2020. Should any of these proceedings result in adverse court decisions against the individuals involved, this could have a negative impact on the outcome of other proceedings against Volkswagen and/or could have other material adverse financial consequences.

There are additional regulatory, criminal and/or civil proceedings in several jurisdictions worldwide. Volkswagen continues to cooperate with government authorities. However, there is a risk the criminal administrative proceedings discussed above, or any other further claims that may arise, could ultimately result in further fines for Volkswagen.

Customers, consumer associations, and/or environmental associations in the affected markets have filed civil lawsuits against Volkswagen AG, other Volkswagen Group companies and non-Volkswagen Group importers and dealers involved in the sales process. In addition, it is possible that importers and dealers could assert claims against Volkswagen, for example through recourse claims. Further lawsuits are possible.

Product related class action, collective or mass proceedings against Volkswagen AG and other Volkswagen Group companies are pending in various countries such as Belgium, Brazil, England and Wales, France, Germany, Italy, the Netherlands, Portugal and South Africa. These proceedings are lawsuits aimed among other things at asserting damages, rescission of the purchase contracts or seeking declaratory judgments that customers are entitled to damages. Many of these proceedings are in an early procedural stage and it is difficult to assess their prospects of success or to quantify the exposure. In some proceedings it is even impossible to define the claimants’ precise causes of action or allegations. However, should these actions be resolved in favor of the claimants, they could result in significant civil damages, fines, the imposition of penalties, sanctions, injunctions and other consequences for Volkswagen.

Individual lawsuits and similar proceedings are pending against Volkswagen in various countries, most of which are seeking damages or rescission of purchase contracts. In Germany, there are around 60 thousand such individual lawsuits relating to various diesel engine types are currently pending against Volkswagen AG or other Group companies, with the plaintiffs suing for damages or rescission of the contract in most cases. A total of approximately one thousand additional lawsuits are pending in other countries. At this time, Volkswagen cannot estimate how many customers will choose to file lawsuits in the future in addition to those already pending and what prospect of success such lawsuits might have.

In South Korea various mass proceedings are pending (in some of these individual lawsuits several hundred litigants have been aggregated). These lawsuits have been filed to assert damages and to rescind the purchase contract including repayment of the purchase price. Furthermore, individual lawsuits and similar proceedings are pending against Volkswagen AG and other Volkswagen Group companies in numerous countries, particularly in Germany and the United States, but also including Italy, Spain, France, Ireland and Austria.

Most of these proceedings are in the early stages and it is difficult to assess their prospects of success, the allegations and the claimants’ precise causes of action or to quantify the exposure. However, should these actions be resolved in favor of the claimants, they could result in significant civil damages, fines, the imposition of penalties, sanctions, injunctions and other consequences.

On November 29, 2017, Volkswagen AG was served with an action brought by the U.S. law firm Hausfeld on behalf of Financialright GmbH, asserting allegedly assigned claims by German customers regarding 15,374 affected vehicles. This action seeks payment of around €358 million in damages, while offering the return of the purchased vehicles. In addition, on January 31, 2018, Volkswagen AG was served with a further action filed by the Hausfeld law firm (dated December 29, 2017) on behalf of Financialright GmbH asserting allegedly assigned claims by an additional 2,004 customers. The 2,004 customers are exclusively customers who have concluded their sales or leasing contracts in Switzerland. Financialright GmbH requests a declaratory judgment that Volkswagen AG is obligated to compensate the respective customers for damages resulting from the use of the switching logic and – if applicable – for the damages resulting from “the software update”. The plaintiff quantifies the amount in dispute of the claim (calculated from an alleged average “reduction in value” of the vehicles) at approximately €800,000. On April 25, 2018, Volkswagen AG was served with Hausfeld’s latest action on behalf of Financialright GmbH. This latest action seeks damages based on purportedly assigned claims of approximately 6,000 customers from Slovenia, with a total amount of approximately EUR 48 million. In addition, the Swiss Foundation for Consumer Protection (Stiftung für Konsumentenschutz) filed a claim for damages against Volkswagen AG in December 2017 based on allegedly assigned claims of some 6,000 customers, indicating the amount in dispute at approximately CHF 30 million.

Evaluating known information and making reliable estimates for provisions is a continuous process. Estimating provisions and contingent liabilities and assessing additional legal risks is subject to great uncertainty due to the ongoing nature of the extensive investigations and proceedings, the risk of new or expanded proceedings, and the complexities of the various negotiations and continuing regulatory approval processes with the relevant authorities. As a result, Volkswagen could be subject to further considerable financial charges that exceed its current estimates. Furthermore, new information not known to Volkswagen’s management board at present may surface, requiring further revaluation of the amounts estimated. Considerable further financial charges may be incurred and further substantial provisions may be necessary as the issues and legal risks, fines and penalties crystallize.

In the United States and Canada, where Volkswagen’s planned actions for the four-cylinder and six-cylinder diesel engines must be approved by U.S. regulators, intensive exchanges of information with the authorities have resulted in approval of emissions modifications for these engines in certain vehicles in the markets. Due to NOx limits in the United States and Canada that are considerably stricter than in the EU and much of the rest of the world, it is a greater technical challenge to refit the vehicles so that the emission standards defined in the U.S. settlement agreements for these vehicles can be achieved. In 2017 and 2018, the EPA/CARB issued the outstanding approvals needed for the technical solutions for affected vehicles with 2.0 liter TDI and with V6 3.0 liter TDI engines. In the case of 2.0 liter Generation 2 diesel vehicles with manual transmissions, Volkswagen elected to withdraw the approved emissions modification proposal, whereby owners were given the option of a buyback and lessees were given the option of early lease termination. Further field measures with financial consequences cannot be ruled out completely at this time. On October 31, 2018, after discussions with DOJ, EPA, and CARB, the parties agreed to modify the First and Second Partial Consent Decrees to clarify that Volkswagen may repair certain technical issues with approved emissions modifications through an “AEM Correction” (Approved Emissions Modification Correction). Where emissions modifications have been approved by U.S. regulators, similar emissions recall programs to those in the U.S. have been developed for Canada. Because, as in the United States, no repair will be available in Canada for 2.0 liter Generation 2 manual transmission vehicles, consumers in possession of these vehicles had the option to participate in the Canadian settlement and receive a buyback, trade-in or early lease termination or, if they had not already made a claim or received benefits, opt out of the settlement between June 15, 2018 and August 15, 2018. Volkswagen may be required to repurchase any other 2.0 liter Generation 2 diesel vehicles with manual transmissions and any other diesel vehicles sold in the United States, Canada and elsewhere, even if not covered under a settlement. This could lead to further significant costs. For example, in Canada, as agreed with the federal environmental regulator, any owners or lessees of manual transmission 2.0 liter Generation 2 diesel vehicles who made a claim by the September 1, 2018 settlement deadline could surrender their vehicle, even if they were not eligible under the Canadian settlement. Furthermore, if the technical solutions implemented by Volkswagen in order to rectify the diesel issue are not implemented in a timely or effective manner or have an undisclosed negative effect on the performance, fuel consumption or resale value of the affected vehicles, regulatory proceedings and/or customer claims for damages could be brought in the future.

Alongside coordination with authorities on technical measures, there are ongoing criminal and administrative proceedings in relation to the diesel issue in the U.S., Germany and other countries worldwide.

Following the studies carried out by AUDI AG to check all relevant diesel concepts for possible irregularities and retrofit potentials, measures proposed by AUDI AG have been adopted and mandated by the German Federal Ministry of Transport and the German Federal Motor Transport Authority (Kraftfahrt-Bundesamt, the “KBA”) in various recall orders pertaining to vehicle models with V6 and V8 TDI engines. Currently, AUDI AG assumes that the total cost, including the amount based on recalls, of the ongoing largely software based retrofit program that began in July 2017 will be manageable and has recognized corresponding balance-sheet risk provisions. However, if AUDI AG’s assumptions are incorrect and costs exceed expectations and balance-sheet provisions, AUDI AG and Volkswagen’s results of operations and cash flows may be adversely affected. AUDI AG has in the meantime developed software updates for many of the affected powertrains and, after approval by the KBA, already installed these updates in the vehicles of a large number of affected customers. The few software updates still being developed are expected to be submitted to the KBA for approval early in the second quarter of 2022.

Worldwide, responsible authorities are continuing their review and assessment of the diesel concepts and of the technical solutions. Volkswagen may be required to repurchase vehicles sold in the US, Germany, Canada and elsewhere. This could lead to further significant costs. On April 4, 2018, the Korean Ministry of Environment (the “KME”) ordered a recall after it categorized (i) certain emissions strategies in the engine control software of various AUDI, Volkswagen and Porsche brand diesel vehicles with a V6 or V8 engine, and (ii) the Dynamic Shift Program (DSP) in the gearbox control in some AUDI vehicle models, as prohibited defeat devices. On August 21, 2019, the KME further announced that it has categorized an injection strategy of urea solution as an illegal emission defeat device and (i) revoked the certifications of eight AUDI, Volkswagen and Porsche brand diesel vehicles with V6 engines, (ii) issued a recall order and administrative fines, and (iii) referred the manufacturers to the prosecutors’ office in criminal proceedings.

In addition to ongoing, extensive investigations by governmental authorities in various jurisdictions worldwide (the most significant of which are in Europe, the United States and South Korea), further investigations (including in relation to areas carved out of the Plea Agreement with the U.S. authorities, such as tax and securities laws) could be launched in the future and existing investigations could be expanded. Furthermore, there could be pending or threatened claims against Volkswagen of which Volkswagen’s management is not yet aware. Ongoing and future investigations may result in further legal actions being taken against Volkswagen or some of its employees. These actions could include the following: additional assessments of substantial criminal and civil fines as well as forfeiture of gains; the imposition of penalties, sanctions, injunctions against future conduct; the loss of vehicle type certifications; and sales stops and business restrictions. The timing of the release of new information on the investigations and the maximum amount of penalties that may be imposed cannot be reliably determined at present. New information may arise at any time, including after the offer, sale and delivery of the notes.

Moreover, private and institutional investors from Germany and abroad have filed claims seeking significant damages against Volkswagen AG – in some cases along with Porsche Automobil Holding SE as joint and several debtors – based on purported losses due to alleged misconduct in capital market communications in connection with the diesel issue. The claims relate to Volkswagen AG’s shares and other securities, including bonds, issued by Volkswagen Group companies, as well as third-party securities. The vast majority of these investor lawsuits are currently pending at the Braunschweig Regional Court, with further investor lawsuits filed at the Stuttgart Regional Court. Further investor claims could be brought.

Any of the above-described negative developments could result in substantial additional costs and have a material adverse effect on Volkswagen’s business, financial position, results of operations, and reputation, as well as on the prices of its securities, including the notes, and the proceeds realized from repossessions of any financed vehicles.

Except as described above, no legal proceedings are pending against any of VW Credit, Inc. (in its capacity as the sponsor (the “Sponsor”), in its capacity as an originator contemplated by Item 1110(b) of Regulation AB (the “Originator”), in its capacity as servicer (the “Servicer”) and in its capacity as administrator of Volkswagen Auto Loan Enhanced Trust 2018-2 (the “Issuing Entity”)), Volkswagen Auto Lease/Loan Underwritten Funding, LLC (the “Depositor”), Deutsche Bank Trust Company Americas (the “Indenture Trustee”), Citicorp Trust Delaware, National Association (the “Issuer Delaware Trustee”), Citibank, N.A. (the “Owner Trustee”), or the Issuing Entity or of which any property of the foregoing is the subject that are or would be material to holders of the asset-backed notes (the “Notes”) or the asset-backed certificate (the “Certificate”). No such proceedings are known to be contemplated by governmental authorities.

Item 1119 of Regulation AB. Affiliations and Certain Relationships and Related Transactions.

Information required by Item 1119 of Regulation AB has been omitted from this report on Form 10-K in reliance on the Instruction to Item 1119.

Item 1122 of Regulation AB. Compliance with Applicable Servicing Criteria.

The Servicer and the Indenture Trustee (collectively, the “Servicing Parties”) have each been identified by the Depositor as parties participating in the servicing function with respect to the asset pool held by the Issuing Entity. Each of the Servicing Parties has completed a report on an assessment of compliance with the servicing criteria set forth in paragraph (d) of Item 1122 of Regulation AB applicable to it (each, a “Servicing Assessment Report”), which Servicing Assessment Reports are attached as exhibits to this Form 10-K. In addition, each of the Servicer and the Indenture Trustee has provided an attestation report (each, an “Attestation Report”) by a registered public accounting firm, which reports are also attached as exhibits to this Form 10-K. Neither the Indenture Trustee’s Servicing Assessment Report nor the Indenture Trustee’s Attestation Report has identified any material instance of noncompliance with the servicing criteria applicable to the Indenture Trustee.

The Servicer complied in all material respects with the servicing criteria applicable to it.

Item 1123 of Regulation AB. Servicer Compliance Statement.

The Servicer has completed a statement of compliance with its activities during the reporting period and of its performance under the applicable servicing agreement (a “Compliance Statement”), signed by an authorized officer of the Servicer. The Compliance Statement is attached as Exhibit 35.1 to this Form 10-K.

EXHIBIT INDEX

Exhibit 31.1	Certification of Senior Officer in Charge of the Servicing Function of the Servicer Pursuant to Rule 15d-14(d).
Exhibit 33.1	Report on Assessment of Compliance with Applicable Servicing Criteria of VW Credit, Inc.
Exhibit 33.2	Report on Assessment of Compliance with the Servicing Criteria of Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas.
Exhibit 34.1	Attestation Report on Assessment of Compliance with the Servicing Criteria of Baker Tilly US, LLP, on behalf of VW Credit, Inc.
Exhibit 34.2	Attestation Report on Assessment of Compliance with the Servicing Criteria of Ernst & Young LLP, on behalf of Deutsche Bank Trust Company Americas.
Exhibit 35.1	Annual Servicer Compliance Statement of the Servicer for the year ended December 31, 2021.

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the Depositor has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

March 30, 2022

VOLKSWAGEN AUTO LOAN ENHANCED TRUST 2018-2
By:	VW Credit, Inc., as Servicer
By:	/s/ Garett Miles
	Garett Miles
	Head of Securitization and Assistant Treasurer
	(senior officer in charge of the servicing function)

EX-31.1

EXHIBIT 31.1

CERTIFICATION OF SENIOR OFFICER IN CHARGE OF THE SERVICING FUNCTION OF THE SERVICER PURSUANT TO Rule 15d-14(d)

I, Garett Miles, certify that:

1. I have reviewed this report on Form 10-K, and all reports on Form 10-D required to be filed in respect of the period covered by this report on Form 10-K of Volkswagen Auto Loan Enhanced Trust 2018-2 (the “Exchange Act periodic reports”);

2. Based on my knowledge, the Exchange Act periodic reports, taken as a whole, do not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, all of the distribution, servicing and other information required to be provided under Form 10-D for the period covered by this report is included in the Exchange Act periodic reports;

4. I am responsible for reviewing the activities performed by the servicer and based on my knowledge and the compliance review conducted in preparing the servicer compliance statement required in this report under Item 1123 of Regulation AB, and except as disclosed in the Exchange Act periodic reports, the servicer has fulfilled its obligations under the servicing agreement in all material respects; and

5. All of the reports on assessment of compliance with servicing criteria for asset-backed securities and their related attestation reports on assessment of compliance with servicing criteria for asset-backed securities required to be included in this report in accordance with Item 1122 of Regulation AB and Exchange Act Rules 13a-18 and 15d-18 have been included as an exhibit to this report, except as otherwise disclosed in this report. Any material instances of noncompliance described in such reports have been disclosed in this report on Form 10-K.

In giving the certifications above, I have reasonably relied on information provided to me by the following unaffiliated party: Deutsche Bank Trust Company Americas.

March 30, 2022

/s/ Garett Miles

Garett Miles

Head of Securitization and Assistant Treasurer

(senior officer in charge of the servicing function)

EX-33.1

EXHIBIT 33.1

Report on Assessment of Compliance with Applicable Servicing Criteria of VW Credit, Inc.

March 30, 2022

1.    VW Credit, Inc. (“VCI”) is responsible for assessing compliance with the servicing criteria applicable to it set forth in paragraph (d) of Item 1122 of Regulation AB as of December 31, 2021 and for the period from January 1, 2021 through December 31, 2021 (the “Reporting Period”) as set forth in Exhibit A hereto. This report does not include asset backed securities transactions for which VCI acted as servicer involving retail auto loans consummated prior to the effectiveness of Regulation AB. The sole asset-backed securities transaction covered by this report was the Volkswagen Auto Loan Enhanced Trust 2018-2.

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

3.    VCI has determined that the criteria in the column titled “Inapplicable Servicing Criteria” on Exhibit A hereto (collectively, the “Inapplicable Servicing Criteria”) are not applicable to VCI based on the activities VCI performs with respect to asset backed securities transactions involving retail auto loans other than transactions consummated prior to the effectiveness of Regulation AB. The criteria set forth in paragraph (d) of Item 1122 of Regulation AB other than the Inapplicable Servicing Criteria are referred to as the “Applicable Servicing Criteria”.

4.    VCI has complied, in all material respects, with the Applicable Servicing Criteria as of December 31, 2021 and for the Reporting Period with respect to its asset backed securities transactions involving retail auto loans other than transactions consummated prior to the effectiveness of Regulation AB.

5.    Baker Tilly US, LLP, an independent registered public accounting firm, has issued an attestation report on VCI’s assessment of compliance with the Applicable Servicing Criteria as of December 31, 2021 and for the Reporting Period.

VW CREDIT, INC.

By:	/s/ Garett Miles
	Garett Miles
	Head of Securitization and Assistant Treasurer

EXHIBIT A

SERVICING CRITERIA		APPLICABLE SERVICING CRITERIA			INAPPLICABLE SERVICING CRITERIA
Reference	Criteria	Performed by Servicer	Performed By Trustee
General Servicing Criteria
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	✓
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.	✓ - No material servicing activities outsourced except indentured trustee who is required to provide the certifications and annual reports concerning criteria 1122 (d) (2) (iii), (iv) & (v)
1122(d)(1)(iii)	Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.	✓ - Transaction documents do not require a back-up servicer
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.					✓
1122(d)(1)(v)	Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.	✓
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.	✓
1122(d)(2)(ii)	Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.	✓		✓
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.					✓
1122(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.	✓
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.	✓
1122(d)(2)(vi)	Unissued checks are safeguarded so as to prevent unauthorized access.					✓
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.	✓
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 Trustsee’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 allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.	✓ - except with respect to remittances	✓
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.		✓
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.		✓
Pool Asset Administration
1122(d)(4)(i)	Collateral or security on pool assets is maintained as required by the transaction agreements or related asset pool 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 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 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 asset pool documents.	✓
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.	✓
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 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 Trusts 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.			✓
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.			✓
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 and uncollectible 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.	✓ - No escrow accounts managed for obligors

EX-33.2

Exhibit 33.2

MANAGEMENT’S ASSERTION OF COMPLIANCE

Management of the Trust & Agency Services department of Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas (collectively the “Company”) is responsible for assessing the servicing criteria set forth in Item 1122(d) of Regulation AB promulgated by the Securities and Exchange Commission to determine which criteria are applicable to the Company in respect of the servicing platform described below. Management has determined that the servicing criteria are applicable in regard to the servicing platform as of and for the period as follows:

Platform: Publicly-issued (i.e., transaction-level reporting required under the Securities Exchange Act of 1934, as amended) and certain privately-issued (i.e., for which transaction-level reporting is required pursuant to contractual obligation) residential mortgage-backed securities, commercial mortgage-backed securities and other asset-backed securities issued on or after January 1, 2006, for which the Company provides trustee, certificate administrator, securities administration, paying agent or custodian services, as defined in the transaction agreements, excluding publicly-issued securities sponsored or issued by any government sponsored entity (the “Platform”) (see Appendix A).

Applicable Servicing Criteria: All servicing criteria set forth in Item 1122(d), to the extent required by Item 1122(d) servicing criteria in regards to the activities performed by the Company with respect to the Platform as to any transaction, except for the following criteria: 1122(d)(4)(iv) – 1122(d)(4)(xiv), which management has determined are not applicable to the activities the Company performs with respect to the Platform (the “Applicable Servicing Criteria”). With respect to Applicable Servicing Criteria 1122(d)(1)(ii), 1122(d)(1)(iii), 1122(d)(2)(iii) and 1122(d)(4)(iii) there were no activities performed during the year ended December 31, 2021 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.

Period: Year ended December 31, 2021 (the “Period”).

Management’s interpretation of Applicable Servicing Criteria: The Company’s management has determined that servicing criterion 1122(d)(1)(iii) is applicable only with respect to its continuing obligation to act as, or locate a, successor servicer under the circumstances referred to in certain transaction agreements. It is management’s interpretation that the Company has no other active back-up servicing responsibilities in regards to servicing criterion 1122(d)(1)(iii) as of and for the Period. The Company’s management has determined that servicing criterion 1122(d)(1)(v) is applicable only to the activities the Company performs related to the mathematically accurate aggregation of information received from servicers and the accurate conveyance of such information within reports to investors. The Company’s management has determined that servicing criterion 1122(d)(4)(iii) is applicable to the activities the Company performs with respect to the Platform only as it relates to the Company’s obligation to report additions, removals or substitutions on reports to investors in accordance with the transaction agreements.

With respect to the Platform as of and for the Period, the Company’s management provides the following assertion of compliance with respect to the Applicable Servicing Criteria:

• The Company’s management is responsible for assessing the Company’s compliance with the Applicable Servicing Criteria.

• The Company’s management has assessed compliance with the Applicable Servicing Criteria. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.

• Based on such assessment, the Company has complied, in all material respects with the Applicable Servicing Criteria.

Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report with respect to management’s assertion of compliance with the Applicable Servicing Criteria as of and for the Period.

DEUTSCHE BANK NATIONAL TRUST COMPANY
By:	/s/ Matt Bowen
	Name: Matt Bowen
	Its: Managing Director
By:	/s/ Christopher Corcoran
	Name: Christopher Corcoran
	Its: Directors
By:	/s/ Ronaldo Reyes
	Name: Ronaldo Reyes
	Its: Vice President
DEUTSCHE BANK TRUST COMPANY AMERICAS
By:	/s/ Ronaldo Reyes
	Name: Ronaldo Reyes
	Its: Vice President
By:	/s/ Christopher Corcoran
	Name: Christopher Corcoran
	Its: Director

Dated: February 28, 2022

Appendix A

I - Asset-backed transactions and securities constituting the platform - MBS deals

Deal ID	Deal Name	Series
AA0601	Aames Mortgage Investment Trust	2006-1
AB07O1	Alliance Bancorp Trust	2007-OA1
AC0601	Accredited Mortgage Loan Trust	2006-1
AC0602	Accredited Mortgage Loan Trust	2006-2
AC0701	Accredited Home Loan Trust	2007-1
AG0601	Aegis	2006-1
AH0601	American Home Mortgage Investment Trust	2006-1
AH0602	American Home Mortgage Investment Trust	2006-2
AH0603	American Home Mortgage Investment Trust	2006-3
AH06A1	American Home Mortgage Assets Trust	2006-1
AH06A2	American Home Mortgage Assets Trust	2006-2
AH06A5	American Home Mortgage Assets Trust	2006-5
AH06A6	American Home Mortgage Assets Trust	2006-6
AH0701	American Home Mortgage Investment Trust	2007-1
AH0702	American Home Mortgage Investment Trust	2007-2
AH07A1	American Home Mortgage Assets Trust	2007-1
AH07A2	American Home Mortgage Assets Trust	2007-2
AH07A3	American Home Mortgage Assets Trust	2007-3
AH07A4	American Home Mortgage Assets Trust	2007-4
AH07A5	American Home Mortgage Assets Trust	2007-5
AQ0601	Ameriquest Mortgage Securities, Inc.	2006-R1
AQ0602	Ameriquest Mortgage Securities, Inc.	2006-R2
AQ06M3	Ameriquest Mortgage Securities	2006-M3
AR0601	Argent	2006-1
AR0602	Ameriquest / Argent	2006-2
AR0603	Argent Securities Inc	2006-W3
AR0604	Argent Securities Inc	2006-W4
AR0605	Argent Securities Inc	2006-W5
AR06M1	Ameriquest / Argent	2006-M1
AR06M2	Argent Securities Trust	2006-M2
BA15SK	SFAVE	2015-5AVE
BC0601	Securitized Asset Backed Receivables (SABR)	2006-WM3
BC06F4	Securitized Asset Backed Receivables (SABR)	2006-FR4
BC06W4	Securitized Asset Backed Receivables (SABR)	2006-WM4
BC0701	BCAP LLC trust	2007-AA1
BC0702	BCAP LLC trust	2007-AA2
BC0703	BCAP LLC trust	2007-AA3
BC0704	BCAP LLC trust	2007-AA4
BC0705	BCAPB LLC Trust	2007-AB1
BC07B1	Securitized Asset Backed Receivables (SABR)	2007-BR1
BC07B2	Securitized Asset Backed Receivables (SABR)	2007-BR2
BC07B3	Securitized Asset Backed Receivables LLC Trust (SABR)	2007-BR3
BC07B4	Securitized Asset Backed Receivables LLC Trust (SABR)	2007-BR4
BC07B5	Securitized Asset Backed Receivables LLC Trust (SABR)	2007-BR5
BC07C1	Securitized Asset Backed Receivables (SABR)	2007-NC1
BC07C2	Securitized Asset Backed Receivables (SABR)	2007-NC2
BC07E1	EquiFirst Loan Securitization Trust	2007-1

BC07H1	Securitized Asset Backed Receivables (SABR)	2007-HE1
CD07C5	CD Mortgage Trust	2007-CD5
CI1423	CGCMT	2014-GC23
CI1425	CGCMT	2014-GC25
CI14F1	CG-CCRE	2014-FL1
CI14F2	CG-CCRE	2014-FL2
CI1527	CGCMT	2015-GC27
CI1529	CGCMT	2015-GC29
CI1531	CGCMT	2015-GC31
CI1533	CGCMT	2015-GC33
CI1535	Citigroup Commercial	2015-GC35
CI15P1	CGCMT	2015-P1
CI15SM	GCBAM	2015-SMRT
CI1637	CGCMT	2016-GC37
CI16C1	Citigroup Commercial Mortgage Trust	2016-C1
CI16C2	Citigroup Commercial Mortgage Trust	2016-C2
CI16C3	CGCMT	2016-C3
CI16P4	CGCMT	2016-P4
CI16P5	CGCMT	2016-P5
CI16P6	CGCMT	2016-P6
CI17B1	CGCMT	2017-B1
CI17P7	Citigroup Commercial Mortgage Trust	2017-P7
DB06G1	DB / ACE Securities Corp.	2006-GP1
DB07C9	COMM Mortgage Trust	2007-C9
DB11L2	DBUBS Mortgage Trust	2011-LC2
DB12C3	COMM Mortgage Trust	2012-CCRE3
DB12L4	COMM Mortgage Trust	2012-LC4
DB12LT	COMM Mortgage Trust	2012-LTRT
DB12VT	VNDO	2012-6AVE
DB1311	COMM Mortgage Trust	2013-CCRE11
DB1313	COMM Mortgage Trust	2013-LC13
DB133P	COMM Mortgage Trust	2013-300P
DB13BW	BWAY Mortgage Trust	2013-1515
DB13C6	COMM Mortgage Trust	2013-CCRE6
DB13C8	COMM Mortgage Trust	2013-CCRE8
DB13C9	COMM Mortgage Trust	2013-CCRE9
DB13CC	COMM Mortgage Trust	2013-CCRE13
DB13SF	COMM Mortgage Trust	2013-SFS
DB1414	COMM Mortgage Trust	2014-CCRE14
DB1417	COMM Mortgage Trust	2014-CCRE17
DB14AR	DBCCRE	2014-ARCP
DB14U2	COMM Mortgage Trust	2014-UBS2
DB14U4	COMM Mortgage Trust	2014-UBS4
DB1521	COMM Mortgage Trust	2015-LC21
DB1522	COMM Mortgage Trust	2015-CCRE22
DB1525	COMM Mortgage Trust	2015-CCRE25
DB15LC	DBWF	2015-LCM
DB1678	COMM Mortgage Trust	2016-787S
DB1685	DBWF	2016-85T
DB16D2	COMM Mortgage Trust	2016-DC2
DB16SF	DBJPM Mortgage Trust	2016-SFC
FF0603	Goldman / First Franklin	2006-FF3
FF0604	Goldman / FFMLT	2006-FF4

FF0606	Goldman / FFMLT	2006-FF6
FF0613	FFMLT Trust	2006-FF13
FF06F1	HSBC / First Franklin	2006-FF1
FF06F5	HSBC / FFMLT	2006-FF5
FF06F7	HSBC / FFMLT	2006-FF7
FF06FB	HSBC / First Franklin	2006-FF11
FF07S1	FFMLT	2007-FFB-SS
GC0613	Harborview Mortgage Loan Trust	2006-13
GC0614	Harborview Mortgage Loan Trust	2006-14
GC06B1	Greenwich / Harborview Trust MPTC	2006-BU1
GC06D1	Greenwich / DSLA MTGE Pass-Thru Certs	2006-AR1
GC06D2	DSLA Mortgage Loan Trust	2006-AR2
GC06E1	Soundview Home Loan Trust	2006-EQ1
GC06E2	Soundview Home Loan Trust	2006-EQ2
GC06F1	Greenwich / Fremont Home Loan Trust	2006-1
GC06F2	Fremont Home Loan Trust	2006-2
GC06F3	Fremont Home Loan Trust	2006-3
GC06H2	Greenwich / Harborview Trust MPTC	2006-2
GC06H3	Greenwich / Harborview Mortgage Loan Trust	2006-3
GC06H5	Greenwich / Harborview	2006-5
GC06H6	Greenwich / Harborview	2006-6
GC06H7	Greenwich / Harborview Mortgage Loan Trust	2006-7
GC06H8	Greenwich / Harborview Mortgage Loan Trust	2006-8
GC06H9	Harborview Mortgage Loan Trust	2006-9
GC06O1	Greenwich / Soundview Home Loan Trust	2006-OPT1
GC06O2	Greenwich / Soundview Home Loan Trust	2006-OPT2
GC06O3	Greenwich / Soundview Home Loan Trust	2006-OPT3
GC06O4	Greenwich / Soundview Home Loan Trust	2006-OPT4
GC06O5	Greenwich / Soundview HEL	2006-OPT5
GC06S1	Greenwich / Soundview HEL	2006-1
GC06S2	Greenwich / Soundview Home Loan Trust	2006-2
GC06S3	Greenwich / Soundview Home Loan Trust	2006-3
GC06SA	Greenwich / Soundview Home Loan Trust	2006-A
GC06W1	Soundview Home Loan Trust	2006-WF1
GC06W2	Soundview Home Loan Trust	2006-WF2
GC06X1	Harborview Mortgage Loan Trust	2006-SB1
GC06Z8	Greenwich / First Franklin	2006-FF8
GC06ZA	First Franklin	2006-FF16
GC070A	RBSGC Mortgage Loan Trust	2007-A
GC070B	RBSGC Mortgage Loan Trust	2007-B
GC071W	Soundview Home Loan Trust	2007-WMC1
GC07D1	DSLA Mortgage Loan Trust	2007-AR1
GC07H2	Harborview Mortgage Loan Trust	2007-2
GC07H4	Harborview Mortgage Loan Trust	2007-4
GC07H5	Harborview Mortgage Loan Trust	2007-5
GC07H6	Harborview Mortgage Loan Trust	2007-6
GC07H7	Harborview Mortgage Loan Trust	2007-7
GC07S1	Soundview Home Loan Trust	2007-1
GC07V1	Soundview Home Loan Trust	2007-NS1
GS0602	Goldman GSAA	2006-2
GS0604	GSAA Trust	2006-4
GS0607	GSAA Home Equity Trust	2006-7
GS0608	GSAA Home Equity Trust	2006-8

GS0610	Goldman / GSAA	2006-10
GS0611	Goldman / GSAA	2006-11
GS0613	Goldman / GSAA Home Equity Trust	2006-13
GS0615	GSAA	2006-15
GS0616	GSAA	2006-16
GS0617	GSAA	2006-17
GS0618	GSAA	2006-18
GS061S	GSAA Home Equity Trust	2006-S1
GS062S	Goldman / GSAMP	2006-S2
GS063S	GSAMP Trust	2006-S3
GS064S	Goldman / GSAMP	2006-S4
GS065S	Goldman / GSAMP Trust	2006-S5
GS066S	GSAMP Trust	2006-S6
GS06C2	Goldman / GSAMP Trust	2006-NC2
GS06F1	GSAMP Trust	2006-FM1
GS06F2	GSAMP Trust	2006-FM2
GS06F3	GSAMP	2006-FM3
GS06G1	Greenpoint Mortgage Funding Trust	2006-OH1
GS06H1	Goldman / GSAMP	2006-HE1
GS06L1	Goldman / GSAMP Trust	2006-S1
GS06O1	Goldman / GSR Mortgage Loan Trust	2006-OA1
GS0702	GSAA Trust	2007-2
GS0704	GSAA Trust	2007-4
GS0705	GSAA Home Equity Trust	2007-5
GS0706	GSAA Trust	2007-6
GS071H	GSAMP Trust	2007-HSBC1
GS071S	GSAA Home Equity Trust	2007-S1
GS07A1	GSR	2007-AR1
GS07A2	GSR Mortgage Loan Trust	2007-AR2
GS07F1	GSAMP	2007-FM1
GS07F2	GSAMP Trust	2007-FM2
GS07H1	GSR Trust	2007-HEL1
GS07O1	GSR Trust	2007-OA1
GS07O2	GSR Mortgage Loan Trust	2007-QA2
GS07T1	STARM Mortgage Loan Trust	2007-1
GS07T4	STARM	2007-4
GS11C5	GS Mortgage Securities Trust	2011-GC5
GS12C7	GS Mortgage Securities Corporation II	2012-GCJ7
GS1312	GS Mortgage Securities Corp Commercial Mtg	2013-GCJ12
GS1314	GS Mortgage Securities Trust	2013-GCJ14
GS1418	GS Mortgage Securities	2014-GC18
GS1422	GSMS	2014-GC22
HB0601	HSBC / HASCO	2006-OPT1
HB0602	HSBC / HASCO	2006-OPT2
HB0603	HSI Asset Securitization Trust	2006-OPT3
HB0604	HSI Asset Securitization Trust	2006-OPT4
HB06C1	HASCO	2006-NC1
HB06H1	HASCO	2006-HE1
HB06H2	HASCO	2006-HE2
HB06L2	HALO	2006-2
HB06W1	HSI Asset Securitization Trust	2006-WMC1
HB0701	HASCO	2007-OPT1
HB07A1	HALO	2007-1

HB07A2	HSI Asset Loan Obligations	2007-2
HB07C1	HSI Asset Securitization Trust	2007-NC1
HB07F1	HSIAsset Securitization Corporation Trust	2007-WF1
HB07H1	HASCO	2007-HE1
HB07H2	HASCO	2007-HE2
HB07L1	HALO	2007-AR1
HB07L2	HSIAsset Loan Obligation Trusts	2007-AR2
HB07W1	HALO	2007-WF1
IM06S1	IMPAC Secured Assets	2006-1
IM06S2	IMPAC Secured Assets Corp	2006-2
IM06S3	IMPAC Secured Assets	2006-3
IM06S4	IMPAC Secured Assets	2006-4
IM06S5	IMPAC Secured Assets	2006-5
IM07S1	IMPAC Secured Assets	2007-1
IM07S2	IMPAC Secured Assets	2007-2
IM07S3	IMPAC Secured Assets	2007-3
IN0601	IndyMac Bank RAST	2006-A1
IN0602	IndyMac RAST	2006-A2
IN0603	IndyMac RAST	2006-A3CB
IN0605	IndyMac RAST	2006-A5CB
IN0606	IndyMac RAST	2006-A6
IN0607	IndyMac RAST	2006-A7CB
IN0608	IndyMac RAST	2006-A8
IN0609	IndyMac RAST	2006-A9CB
IN060A	IndyMac INDS Mortgage Loan Asset-Backed Trust	2006-A
IN0610	IndyMac RAST	2006-A10
IN0611	IndyMac RAST	2006-A11
IN0612	IndyMac RAST	2006-A12
IN0613	IndyMac RAST	2006-A13
IN0614	IndyMac Residential Asset Securitization Trust	2006-A14CB
IN0615	IndyMac RAST	2006-A15
IN0616	IndyMac RAST	2006-A16
IN06A2	IndyMac Bank INDX	2006-AR2
IN06A3	IndyMac Bank INDX	2006-AR3
IN06A4	IndyMac INDX Mortgage Loan Trust	2006-AR4
IN06A5	IndyMac INDX Mortgage Loan Trust	2006-AR5
IN06A6	IndyMac INDX Mortgage Loan Trust	2006-AR6
IN06A7	IndyMac INDX Mortgage Loan Trust	2006-AR7
IN06A8	IndyMac INDX Mortgage Loan Trust	2006-AR8
IN06A9	IndyMac INDX Mortgage Loan Trust	2006-AR9
IN06AB	IndyMac INDX Mortgage Loan Trust	2006-AR11
IN06AC	IndyMac INDX	2006-AR12
IN06AD	IndyMac INDX Mortgage Loan Trust	2006-AR13
IN06AE	IndyMac INDX	2006-AR14
IN06AF	IndyMac INDX Mortgage Loan Trust	2006-AR15
IN06AJ	IndyMac INDX	2006-AR19
IN06AL	IndyMac INDX	2006-AR21
IN06AN	IndyMac INDX	2006-AR23
IN06AP	IndyMac INDX	2006-AR25
IN06AR	IndyMac INDX	2006-AR27
IN06AT	IndyMac INDX	2006-AR29
IN06AV	IndyMac INDX Mortgage Loan Trust	2006-AR31
IN06AX	IndyMac INDX Mortgage Loan Trust	2006-AR33

IN06AZ	IndyMac INDX Mortgage Loan Trust	2006-AR35
IN06B1	IndyMac INDB	2006-1
IN06D1	IndyMac INDA	2006-AR1
IN06D2	IndyMac INDA	2006-AR2
IN06D3	IndyMac INDA	2006-AR3
IN06F1	IndyMac INDX	2006-FLX1
IN06G1	IndyMac INDX Mortgage Loan Trust	2006-1
IN06G2	IndyMac INDS	2006-2B
IN06G3	Home Equity Mortgage Loan Asset-Backed Trust INDS	2006-3
IN06H1	IndyMac Home Equity Mortgage Loan Trust	2006-H1
IN06H2	IndyMac INABS	2006-H2
IN06H3	IndyMac Home Equity Mortgage Loan Asset-Backed Trust	2006-H3
IN06L1	IndyMac Loan Trust	2006-L1
IN06L2	IndyMac Loan Trust	2006-L2
IN06L3	IndyMac Lot Loan	2006-L3
IN06L4	IndyMac Residential Mortgage Backed Trust	2006-L4
IN06P4	IndyMac RAST	2006-A4
IN06R1	IndyMac RAST	2006-R1
IN06R2	IndyMac INDX	2006-R1
IN06S1	IndyMac Bank INABS	2006-A
IN06S2	IndyMac INABS	2006-B
IN06S3	IndyMac INABS	2006-C
IN06S4	IndyMac INABS	2006-D
IN06S5	Home Equity Mortgage Loan Asset-Backed Trust INABS	2006-E
IN06Z1	IndyMac INDX	2006-AR37
IN06Z2	IndyMac INDX	2006-AR39
IN06Z3	IndyMac INDX	2006-AR41
IN0701	IndyMac Residential Asset Securitization Trust	2007-A1
IN0702	IndyMac RAST	2007-A2
IN0703	IndyMac RAST	2007-A3
IN0705	IndyMac Residential Asset Securitization Trust	2007-A5
IN0706	Residential Asset Securitization Trust	2007-A6
IN0707	IndyMac RAST	2007-A7
IN0708	IndyMac RAST	2007-A8
IN0709	Residential Asset Securitization Trust	2007-A9
IN07A1	IndyMac INDX MORTGAGE LOAN TRUST	2007-AR1
IN07A5	IndyMac MBS, Inc.	2007-AR5
IN07A7	IndyMac INDX Mortgage Loan Trust	2007-AR7
IN07A9	IndyMac INDX Mortgage Loan Trust	2007-AR9
IN07AB	IndyMac INDX Mortgage Loan Trust	2007-AR11
IN07AD	IndyMac INDX Mortgage Loan Trust	2007-AR13
IN07AF	IndyMac INDX Mortgage Loan Trust	2007-AR15
IN07AH	IndyMac INDX Mortgage Loan Trust	2007-AR17
IN07AJ	IndyMac INDX Mortgage Loan Trust	2007-AR19
IN07AL	IndyMac INDX Mortgage Loan Trust	2007-AR21IP
IN07C1	IndyMac IMSC Mortgage Loan Trust	2007-AR1
IN07D1	IndyMac INDA Mortgage Loan Trust	2007-AR1
IN07D2	IndyMac INDA Mortgage Loan Trust	2007-AR2
IN07D3	IndyMac INDA Mortgage Loan Trust	2007-AR3
IN07D4	IndyMac INDA Mortgage Loan Trust	2007-AR4
IN07D5	IndyMac INDA Mortgage Loan Trust	2007-AR5
IN07D6	IndyMac INDA Mortgage Loan Trust	2007-AR6
IN07D7	IndyMac INDA Mortgage Loan Trust	2007-AR7

IN07D8	IndyMac INDA Mortgage Loan Trust	2007-AR8
IN07D9	IndyMac INDA Mortgage Loan Trust	2007-AR9
IN07F1	IndyMac INDX Mortgage Loan Trust	2007-FLX1
IN07F2	IndyMac INDX Mortgage Loan Trust	2007-FLX2
IN07F3	IndyMac INDX Mortgage Loan Trust	2007-FLX3
IN07F4	IndyMac INDX Mortgage Loan Trust	2007-FLX4
IN07F5	IndyMac INDX Mortgage Loan Trust	2007-FLX5
IN07F6	IndyMac INDX Mortgage Loan Trust	2007-FLX6
IN07J1	IndyMac IMJA Mortgage Loan Trust	2007-A1
IN07J2	IndyMac IMJA Mortgage Loan Trust	2007-A2
IN07J3	IndyMac IMJA Mortgage Loan Trust	2007-A3
IN07J4	IndyMac IMJA Mortgage Loan Trust	2007-A4
IN07L1	IndyMac RMBT	2007-L1
IN07M1	IndyMac IMSC Mortgage Loan Trust	2007-F1
IN07M2	IndyMac IMSC Mortgage Loan Trust	2007-F2
IN07M3	IndyMac IMSC Mortgage Loan Trust	2007-AR2
IN07M4	IndyMac IMSC Mortgage Loan Trust	2007-F3
IN07MH	IndyMac IMSC Mortgage Loan Trust	2007-HOA-1
IN07R1	Residential Asset Securitization Trust	2007-R1
IN07S1	IndyMac Home Equity Trust INABS	2007-A
IN07S2	IndyMac INABS	2007-B
IX0601	IXIS Real Estate Capital Trust	2006-HE1
IX0602	IXIS Real Estate Capital Trust	2006-HE2
IX0603	IXIS Real Estate Capital Trust	2006-HE3
IX0701	IXIS Real Estate Capital Trust	2007-HE1
IX0702	Morgan Stanley ABS Capital I Inc	2007-HE2
JP07C1	J.P. Morgan Mortgage Acquisition Trust	2007-CH1
JP07C2	J.P. Morgan Mortgage Acquisition Trust	2007-CH2
JP07C3	J.P. Morgan Mortgage Acquisition Trust	2007-CH3
JP07C4	J.P. Morgan Mortgage Acquisition Trust	2007-CH4
JP07C5	J.P. Morgan Mortgage Acquisition Trust	2007-CH5
JP07H1	J.P. Morgan Mortgage Acquisition Trust	2007-HE1
JP1317	JPMBB Commercial Mortgage Securities Trust	2013-C17
JP1420	J.P. Morgan Chase Commercial Mortgage Securities Trust	2014-C20
LB0601	Long Beach	2006-1
LB0602	Long Beach Mortgage Loan Trust	2006-2
LB0603	Long Beach Mortgage Loan Trust	2006-3
LB0604	Long Beach Mortgage Loan Trust	2006-4
LB0605	Long Beach Mortgage Loan Trust	2006-5
LB0606	Long Beach Mortgage Loan Trust	2006-6
LB0607	Long Beach Mortgage Loan Trust	2006-7
LB0608	Long Beach Mortgage Loan Trust	2006-8
LB0609	Long Beach Mortgage Loan Trust	2006-9
LB060A	Long Beach Mortgage Trust	2006-A
LB0610	Long Beach Mortgage Loan Trust	2006-10
LB0611	Long Beach Mortgage Loan Trust	2006-11
LB06W1	Long Beach	2006-WL1
LB06W2	Long Beach	2006-WL2
LB06W3	Long Beach	2006-WL3
ML07M1	Merrill Lynch Mortgage Investors Trust	2007-MLN1
MS06C1	Morgan Stanley	2006-NC1
MS06C2	Morgan Stanley Capital I Inc. Trust	2006-NC2
MS06C3	Morgan Stanley ABS Capital I Inc. Trust	2006-NC3

MS06C4	Morgan Stanley ABS Capital	2006-NC4
MS06C5	Morgan Stanley ABS Capital I Inc. Trust	2006-NC5
MS06H2	Morgan Stanley ABS Capital I Inc. Trust	2006-HE2
MS06H3	Morgan Stanley ABS Capital I Inc. Trust	2006-HE3
MS06H4	Morgan Stanley ABS Capital	2006-HE4
MS06H5	Morgan Stanley ABS Capital Trust	2006-HE5
MS06H6	Morgan Stanley ABS Capital I Inc. Trust	2006-HE6
MS06H7	Morgan Stanley ABS Capital I Inc. Trust	2006-HE7
MS06H8	Morgan Stanley ABS Capital I Inc. Trust	2006-HE8
MS06I1	Morgan Stanley IXIS Real Estate Capital	2006-1
MS06I2	Morgan Stanley IXIS Real Estate Capital Trust	2006-2
MS06R2	IndyMac RAST	2006-R2
MS06W2	Morgan Stanley ABS Capital Trust	2006-WMC2
MS06X2	Morgan Stanley Home Equity LoanTrust (HEL line)	2006-2
MS06X3	Morgan Stanley Home Equity LoanTrust (HEL line)	2006-3
MS07B1	Morgan Stanley Structured Trust I	2007-1
MS07C1	Morgan Stanley ABS Capital I Inc. Trust	2007-NC1
MS07C2	Morgan Stanley ABS Capital I Inc	2007-2
MS07C3	Morgan Stanley ABS Capital I Inc	2007-3
MS07C4	Morgan Stanley ABS Capital I Inc	2007-NC4
MS07H1	Morgan Stanley ABS Capital I Inc. Trust	2007-HE1
MS07H2	Morgan Stanley ABS Capital I Inc. Trust	2007-HE2
MS07H3	Morgan Stanley ABS Capital I Inc. Trust	2007-HE3
MS07H5	Morgan Stanley ABS Capital I Inc	2007-HE5
MS07H6	Morgan Stanley ABS Capital I Inc	2007-6
MS07H7	Morgan Stanley ABS Capital I Inc	2007-HE7
MS07X1	Morgan Stanley Home Equity Loan Trust	2007-1
MS07X2	Morgan Stanley Home Equity Loan Trust	2007-2
MS1311	MSBAM	2013-C11
MS1415	MSBAM	2014-C15
NC0601	New Century HEL Trust	2006-1
NC0602	New Century HEL Trust	2006-2
NC06A1	New Century Alternative Mortgage Trust	2006-ALT1
NC06S1	New Century HEL	2006-S1
NS0604	Novastar Mortgage Funding Trust	2006-4
NS0605	Novastar Mortgage Funding Trust	2006-5
NS0606	Novastar Mortgage Funding Trust	2006-6
NS0701	Novastar Mortgage Funding Trust	2007-1
NS0702	Novastar Mortgage Funding Trust	2007-2
PO0701	Popular	2007-A
RB13GS	RBS Commercial Funding Inc. Trust	2013-GSP
RF06A1	RFC RALI	2006-QA1
RF06A3	Residential Accredit Loans, Inc.	2006-QA3
RF06A4	Residential Accredit Loans, Inc.	2006-QA4
RF06A5	RFC RALI	2006-QA5
RF06A6	Residential Accredit Loans, Inc.	2006-QA6
RF06A7	Residential Accredit Loans, Inc.	2006-QA7
RF06A8	Residential Accredit Loans, Inc.	2006-QA8
RF06A9	Residential Accredit Loans, Inc.	2006-QA9
RF06AA	Residential Accredit Loans, Inc.	2006-QA10
RF06AB	Residential Accredit Loans, Inc.	2006-QA11
RF06H1	Residential Accredit Loans, Inc.	2006-QH1
RF06O1	RFC RALI	2006-QO1

RF06O3	RFC / Residential Accredit Loans, Inc.	2006-QO3
RF06O4	Residential Accredit Loans, Inc.	2006-QO4
RF06O5	Residential Accredit Loans, Inc.	2006-QO5
RF06O6	RFC RALI	2006-QO6
RF06O7	Residential Accredit Loans, Inc.	2006-QO7
RF06O8	Residential Accredit Loans, Inc.	2006-QO8
RF06O9	Residential Accredit Loans, Inc.	2006-QO9
RF06OA	Residential Accredit Loans, Inc.	2006-QO10
RF06Q1	RFC RALI	2006-QS1
RF06Q3	RFC / Residential Accredit Loans, Inc.	2006-QS3
RF06Q4	Residential Accredit Loans, Inc.	2006-QS4
RF06Q5	Residential Accredit Loans, Inc.	2006-QS5
RF06Q6	RFC RALI	2006-QS6
RF06Q7	RFC RALI	2006-QS7
RF06Q8	Residential Accredit Loans, Inc.	2006-QS8
RF06Q9	Residential Accredit Loans, Inc.	2006-QS9
RF06QA	Residential Accredit Loans, Inc.	2006-QS10
RF06QB	Residential Accredit Loans, Inc.	2006-QS11
RF06QC	Residential Accredit Loans, Inc.	2006-QS12
RF06QD	Residential Accredit Loans, Inc.	2006-QS13
RF06QE	Residential Accredit Loans, Inc.	2006-QS14
RF06QF	Residential Accredit Loans, Inc.	2006-QS15
RF06QG	Residential Accredit Loans, Inc.	2006-QS16
RF06QH	Residential Accredit Loans, Inc.	2006-QS17
RF06QI	Residential Accredit Loans, Inc.	2006-QS18
RF07A1	Residential Accredit Loans, Inc.	2007-QA1
RF07A2	Residential Accredit Loans, Inc.	2007-QA2
RF07A3	Residential Accredit Loans, Inc.	2007-QA3
RF07A4	Residential Accredit Loans, Inc.	2007-QA4
RF07A5	Residential Accredit Loans, Inc.	2007-QA5
RF07H1	Residential Accredit Loans, Inc.	2007-QH1
RF07H2	Residential Accredit Loans, Inc.	2007-QH2
RF07H3	Residential Accredit Loans, Inc.	2007-QH3
RF07H4	Residential Accredit Loans, Inc.	2007-QH4
RF07H5	Residential Accredit Loans, Inc.	2007-QH5
RF07H6	Residential Accredit Loans, Inc.	2007-QH6
RF07H7	Residential Accredit Loans, Inc.	2007-QH7
RF07H8	Residential Accredit Loans, Inc.	2007-QH8
RF07H9	Residential Accredit Loans, Inc.	2007-QH9
RF07O1	Residential Accredit Loans, Inc.	2007-QO1
RF07O2	Residential Accredit Loans, Inc.	2007-QO2
RF07O3	Residential Accredit Loans, Inc.	2007-QO3
RF07O4	Residential Accredit Loans, Inc.	2007-QO4
RF07O5	Residential Accredit Loans, Inc.	2007-QO5
RF07Q1	Residential Accredit Loans, Inc.	2007-QS1
RF07Q2	Residential Accredit Loans, Inc.	2007-QS2
RF07Q3	Residential Accredit Loans, Inc.	2007-QS3
RF07Q4	Residential Accredit Loans, Inc.	2007-QS4
RF07Q5	Residential Accredit Loans, Inc.	2007-QS5
RF07Q6	Residential Accredit Loans, Inc.	2007-QS6
RF07Q7	Residential Accredit Loans, Inc.	2007-QS7
RF07Q8	Residential Accredit Loans, Inc.	2007-QS8
RF07Q9	Residential Accredit Loans, Inc.	2007-QS9

RF07QA	Residential Accredit Loans, Inc.	2007-QS10
RF07QB	Residential Accredit Loans, Inc.	2007-QS11
RF07S4	Residential Funding Mortgage Securities I	2007-S4
RF07S5	Residential Funding Mortgage Securities I	2007-S5
RF08R1	RFC RALI	2008-QR1
SX0601	Saxon	2006-1
SX0602	Saxon	2006-2
SX0603	Saxon Asset Trust	2006-3
SX0701	Saxon Asset Securities Company	2007-1
SX0702	Saxon Asset Securities Company	2007-2
SX0703	Saxon Asset Securities Company	2007-3
UB11C1	UBS-Citigroup Commercial Mortgage Trust	2011-C1
UB12C1	UBS Commercial Mortgage Trust	2012-C1
UB12C3	UBS-Barclays Commercial Mortgage Trust	2012-C3
UB13C5	UBS-Barclays Commercial Mortgage Trust	2013-C5
WA06A1	Washington Mutual	2006-AR1
WA06A3	Washington Mutual	2006-AR3
WA06A4	Washington Mutual	2006-AR4
WA06A5	Washington Mutual Acceptance Corp.	2006-AR5
WA07H1	Wamu	2007-HE1
WF11C5	WF RBS Commercial Trust	2011-C5
WF12C6	WFRBS CMT	2012-C6
WF12C7	WFRBS CMT	2012-C7
WF12C8	WFRBS CMT	2012-C8
WF1318	WFRBS Commercial Mtg Loan Trust	2013-C18
WF13U1	WFRBS Commercial Mtg Loan Trust	2013-UBS1
WF1414	WFRBS	2014-LC14
WF1419	WFRBS	2014-C19

II - Asset-backed transactions and securities constituting the platform - ABS deals

Deal ID	Deal Name	Series
GM1703	Ally Auto Receivables Trust	2017-3
GM1704	Ally Auto Receivables Trust	2017-4
GM1802	Ally Auto Receivables Trust	2018-2
GM1803	Ally Auto Receivables Trust	2018-3
GM1903	Ally Auto Receivables Trust	2019-3
GM1904	Ally Auto Receivables Trust	2019-4
GM1705	Ally Auto Receivables Trust	2017-5
GM1801	Ally Auto Receivables Trust	2018-1
GM1901	Ally Auto Receivables Trust	2019-1
GM1902	Ally Auto Receivables Trust	2019-2
BW171T	Bank of the West	2017-1
BW181T	Bank of the West	2018-1
BW191T	Bank of the West	2019-1
GM16CT01	Capital Auto Receivables Asset Trust	2016-1
GM17CT01	Capital Auto Receivables Asset Trust	2017-1
GM18CT01	Capital Auto Receivables Asset Trust	2018-1
GM18CT02	Capital Auto Receivables Asset Trust	2018-2

CPERB9	Centerpoint Energy Restoration Bond Company LLC
CTBCIV	Centerpoint Energy Transition Bond Company IV, LLC
CFS07A	Chase Education Loan Trust	2007-A
MCITICCIT2000	Citibank Credit Card Issuance Trust
CCC7A3	Citibank Credit Card Issuance Trust	2007-A3
CCC7A4	Citibank Credit Card Issuance Trust	2007-A4
CCIT13A9	Citibank Credit Card Issuance Trust	2013-A9
CCIT4A1	Citibank Credit Card Issuance Trust	2014-A1
CCIT4A5	Citibank Credit Card Issuance Trust	2014-A5
CCIT16A2	Citibank Credit Card Issuance Trust	2016-A2
CCIT16A3	Citibank Credit Card Issuance Trust	2016-A3
CCIT17A5	Citibank Credit Card Issuance Trust	2017-A5
CCIT17A6	Citibank Credit Card Issuance Trust	2017-A6
CCIT17A7	Citibank Credit Card Issuance Trust	2017-A7
CCIT18A1	Citibank Credit Card Issuance Trust	2018-A1
CCIT18A2	Citibank Credit Card Issuance Trust	2018-A2
CCIT18A3	Citibank Credit Card Issuance Trust	2018-A3
CCIT18A4	Citibank Credit Card Issuance Trust	2018-A4
CCIT18A5	Citibank Credit Card Issuance Trust	2018-A5
CCIT18A6	Citibank Credit Card Issuance Trust	2018-A6
CCIT18A7	Citibank Credit Card Issuance Trust	2018-A7
CNH17B	CNH Equipment Trust	2017-B
CLC071	College Loan Corp Trust I	2007-1
CLC072	College Loan Corp Trust II	2007-2
CLC061	College Loan Corporation Trust I	2006-1
GMI110191	Juniper Receivables DAC	2019-1
GMI110192	Juniper Receivables DAC	2019-2
GMI110201	Juniper Receivables DAC	2020-1
GMI110	Juniper Receivables DAC	2019-1
KSL06A	KeyCorp Student Loan Trust	2006-A
MAEN16A	Navient Private Education Loan Trust	2016-A
MAEN18B	Navient Private Education Loan Trust	2018-B
MAEN18D	Navient Private Education Loan Trust	2018-D
MAEN19E	Navient Private Education LoanTrust	2019-E
MAEN19D	Navient Private Education LoanTrust	2019-D
MAEN19F	Navient Private Education REFI LoanTrust	2019-F
MAEN19PTA	Navient Private Education REFI LoanTrust	2019-PT-A
MAEN19C	Navient Private Education REFI LoanTrust	2019-C
MAEN141	Navient Student Loan Trust	2014-1
MAEN142	Navient Student Loan Trust	2014-2
MAEN143	Navient Student Loan Trust	2014-3
MAEN144	Navient Student Loan Trust	2014-4
MAEN145	Navient Student Loan Trust	2014-5
MAEN146	Navient Student Loan Trust	2014-6
MAEN147	Navient Student Loan Trust	2014-7
MAEN148	Navient Student Loan Trust	2014-8
SLC061	SLC Student Loan Trust	2006-1
SLC062	SLC Student Loan Trust	2006-2
SLC071	SLC Student Loan Trust	2007-1
SLC072	SLC Student Loan Trust	2007-2
SLC081	SLC Student Loan Trust	2008-1
SLC082	SLC Student Loan Trust	2008-2
SLC091	SLC Student Loan Trust	2009-1

SLC092	SLC Student Loan Trust	2009-2
SLC093	SLC Student Loan Trust	2009-3
SLC101	SLC Student Loan Trust	2010-1
MAE610	SLC Student Loan Trust	2006-10
MAE062	SLC Student Loan Trust	2006-2
MAE064	SLC Student Loan Trust	2006-4
MAE065	SLC Student Loan Trust	2006-5
MAE066	SLC Student Loan Trust	2006-6
MAE067	SLC Student Loan Trust	2006-7
MAE068	SLC Student Loan Trust	2006-8
MAE069	SLC Student Loan Trust	2006-9
MAE071	SLC Student Loan Trust	2007-1
MAE072	SLC Student Loan Trust	2007-2
MAE073	SLC Student Loan Trust	2007-3
MAE074	SLC Student Loan Trust	2007-4
MAE075	SLC Student Loan Trust	2007-5
MAE076	SLC Student Loan Trust	2007-6
MAE077	SLC Student Loan Trust	2007-7
MAE078	SLC Student Loan Trust	2007-8
MAE081	SLC Student Loan Trust	2008-1
MAE082	SLC Student Loan Trust	2008-2
MAE083	SLC Student Loan Trust	2008-3
MAE084	SLC Student Loan Trust	2008-4
MAE085	SLC Student Loan Trust	2008-5
MAE086	SLC Student Loan Trust	2008-6
MAE087	SLC Student Loan Trust	2008-7
MAE088	SLC Student Loan Trust	2008-8
MAE089	SLC Student Loan Trust	2008-9
MAE901	SLC Student Loan Trust	2009-1
MAE902	SLC Student Loan Trust	2009-2
MAE101	SLC Student Loan Trust	2010-1
MAE102	SLC Student Loan Trust	2010-2
MAE111	SLC Student Loan Trust	2011-1
MAE112	SLC Student Loan Trust	2011-2
MAE113	SLC Student Loan Trust	2011-3
MAE121	SLC Student Loan Trust	2012-1
MAE122	SLC Student Loan Trust	2012-2
MAE123	SLC Student Loan Trust	2012-3
MAE124	SLC Student Loan Trust	2012-4
MAE125	SLC Student Loan Trust	2012-5
MAE126	SLC Student Loan Trust	2012-6
MAE127	SLC Student Loan Trust	2012-7
MAE128	SLC Student Loan Trust	2012-8
MAE131	SLC Student Loan Trust	2013-1
MAE132	SLC Student Loan Trust	2013-2
MAE133	SLC Student Loan Trust	2013-3
MAE134	SLC Student Loan Trust	2013-4
MAE135	SLC Student Loan Trust	2013-5
MAE136	SLC Student Loan Trust	2013-6
MAE041	SLC Student Loan Trust	2014-1
MAE142	SLC Student Loan Trust	2014-2
MAEB14A	SMB Private Education Loan Trust	2014-A
MAEB15A	SMB Private Education Loan Trust	2015-A

MAEB15B	SMB Private Education Loan Trust	2015-B
MAEB15C	SMB Private Education Loan Trust	2015-C
MAEB16A	SMB Private Education Loan Trust	2016-A
MAEB16B	SMB Private Education Loan Trust	2016-B
MAEB16C	SMB Private Education Loan Trust	2016-C
MAEB17A	SMB Private Education Loan Trust	2017-A
MAEB17B	SMB Private Education Loan Trust	2017-B
MAEB18A	SMB Private Education Loan Trust	2018-A
MAEB18B	SMB Private Education Loan Trust	2018-B
MAEB18C	SMB Private Education Loan Trust	2018-C
MAEB19A	SMB Private Education Loan Trust	2019-A
MAEB19B	SMB Private Education Loan Trust	2019-B
SYNMNT172	Synchrony Credit Card Issuance Trust	2017-2
SYNMN181	Synchrony Credit Card Issuance Trust	2018-1
GEMN143	Synchrony Credit Card Master Note Trust	2014-VFN3
GEMN144	Synchrony Credit Card Master Note Trust	2014-VFN4
GEMN145	Synchrony Credit Card Master Note Trust	2014-VFN5
SYNMN182	Synchrony Credit Card Master Note Trust	2018-2
SYNMN20VF1	Synchrony Credit Card Master Note Trust	2020-VFN1
SYNMN21VF1	Synchrony Credit Card Master Note Trust	2021-VFN1
SYNMNT162	Synchrony Credit Card Master Trust	2016-2
SYNSFT15A	Synchrony Sales Finance Master Note Trust	2015-A
SYNMN19VF1	Synchrony Sales Finance Master Note Trust	2019-VFN1
GES12A	Synchrony Sales Finance Master Trust	2012-A
GES12C	Synchrony Sales Finance Master Trust	2012-C
GES12D	Synchrony Sales Finance Master Trust	2012-D
GESFM14C	Synchrony Sales Finance Master Trust	2014-C
SYNSFT15B	Synchrony Sales Finance Master Trust	2015-B
SYNSFT16B	Synchrony Sales Finance Master Trust	2016-B
SYNSFT20A	Synchrony Sales Finance Master Trust	2020-A
VART211	Veros Auto Receivables Trust	2021-1
VALET182	Volkswagen Auto Loan Enhanced Trust	2018-2
VALET201	Volkswagen Auto Loan Enhanced Trust	2020-1
GEF201	Wells Fargo Dealer Floorplan Master Note Trust	2020-VFN-1

III - Asset-backed transactions and securities constituting the platform - document custody only deals

Deal ID	Deal Name	Series
AH066C	Citi/ Wells Fargo American Home Mortgage Assets	2006-4
BC061C	Wells Fargo/ SABR	2006-NC2
BC062C	Wells Fargo/ SABR	2006-NC3
BC081C	BCAP	2008-IND1
BC083C	BCAP	2008-IND2
CA061C	Carrington	2006-NC1
CA062C	Wells Fargo/ Carrington Mortgage Loan Trust	2006-NC2
CA063C	Wells Fargo/ Carrington Mortgage Loan Trust	2006-NC3
CA064C	Wells Fargo/ Carrington Mortgage Loan Trust	2006-NC4
DB061C	ACE	2006-NC1

DB061Z	DBALT Wells Fargo/ Deutsche Bank custody	2006-AR6
DB062C	ACE HSBC/WELLS FARGO/DB	2006 ASAP1
DB062Z	DBALT Wells Fargo/ Deutsche Bank custody	2006-OA1
DB063C	ACE	2006-SL1
DB064C	DBALT /WELLS FARGO/DB	2006-AB1
DB065C	DBALT HSBC/ Wells Fargo/Deutsche Bank	2006-AR1
DB066C	DB ACE	2006_HE1
DB067C	ACE HSBC/ Wells Fargo/ Deutsche	2006-SD1
DB068C	DB ACE Securities	2006-ASAP2
DB069C	DBALT	2006-AF1
DB06AC	DB ACE	2006-SL2
DB06CC	Ace HSBC/ Wells Fargo/ Deutsche Bank custody	2006-HE2
DB06DC	Ace HSBC/ Wells Fargo/ Deutsche Bank custody	2006-ASL1
DB06EC	DBALT HSBC/ Wells Fargo/ Deutsche Bank custody	2006-AB2
DB06FC	Ace HSBC/ Wells Fargo/ Deutsche Bank custody	2006-ASAP3
DB06HC	Ace HSBC/ Wells Fargo/ Deutsche Bank custody	2006-HE3
DB06JC	Ace HSBC/ Wells Fargo/ Deutsche Bank custody	2006-SD2
DB06LC	DBALT HSBC/ Wells Fargo/ Deutsche Bank custody	2006-AB3
DB06MC	DBALT HSBC/ Wells Fargo/ Deutsche Bank custody	2006-AR2
DB06PC	ACE HSBC/ Wells Fargo/ Deutsche Bank custody	2006-SL4
DB06QC	ACE HSBC/ Wells Fargo/ Deutsche Bank custody	2006-NC2
DB06SC	DBALT HSBC/ Wells Fargo/ Deutsche Bank custody	2006-AB4
DB06TC	Ace HSBC/ Wells Fargo/ Deutsche Bank custody	2006-ASAP5
DB06UC	DBALT HSBC/ Wells Fargo/ Deutsche Bank custody	2006-AR4
DB06WC	DBALT Wells Fargo/ Deutsche Bank custody	2006-AR5
DB06XC	Ace Wells Fargo/ Deutsche Bank custody	2006-NC3
DB06YC	Ace Wells Fargo/ Deutsche Bank custody	2006-ASAP6
DB06ZC	Ace Wells Fargo/ Deutsche Bank custody	2006-SD3
DB071C	DBALT Wells Fargo/ Deutsche Bank custody	2007-AR1
DB073C	Ace Wells Fargo/ Deutsche Bank custody	2007-ASL1
DB074C	DBALT Wells Fargo/ Deutsche Bank custody	2007-AR2
DB075C	DBALT Wells Fargo/ Deutsche Bank custody	2007-BAR1
DB077C	ACE Wells Fargo/ Deutsche Bank custody	2007-SL1
DB078C	ACE Wells Fargo/ Deutsche Bank custody	2007-HE2
DB07AC	ACE Wells Fargo/ Deutsche Bank custody	2007-ASAP1
DB07CC	DBALT Wells Fargo/ Deutsche Bank custody	2007-OA2
DB07DC	DBALT Wells Fargo/ Deutsche Bank custody	2007-AB1
DB07EC	Ace Wells Fargo/ Deutsche Bank custody	2007-HE4
DB07FC	DBALT Wells Fargo/ Deutsche Bank custody	2007-AR3
DB07GC	ACE Wells Fargo/ Deutsche Bank custody	2007-ASAP2
DB07HC	Wells Fargo/ Deutsche Alt-A Securities	2007-OA3
DB07JC	Ace / Wells Fargo	2007-HE5
DB07LC	DBALT / Wells Fargo	2007-OA4
DB07MC	DBALT / Wells Fargo	2007-1
DB07NC	DBALT / Wells Fargo	2007-OA5
DB07PC	Ace / Wells Fargo	2007-SL2
DB07QC	DBALT / Wells Fargo	2007-2
DB07TC	DBALT / Wells Fargo	2007-3
FB061C	ABSC	2006-AG1
FB071C	CSMC /Wells Fargo custody	2007-5
FB072C	CSMC custody	2007-NC1
FB073C	CSMC custody	2007-6
FB075C	CSMC custody	2007-7

GC069C	HarborView Mortgage Loan Trust	2006-10
GC07AC	HarborView Mortgage Loan Trust	2007-3
GS061C	US Bank/Wells Fargo GSR custody	2006-1
GS062C	Wells Fargo /GSR custody	2006-AR1
GS063C	JP Morgan/ US Bank GSAA custody	2006-1
GS066C	GSAA	2006-3
GS067C	GSR	2006-2F
GS068C	Wells Fargo/US BankGSR	2006-3
GS069C	JP Morgan/ US Bank GSAA	2006-5
GS06AC	JP Morgan/ US Bank GSAA custody	2006-6
GS06BC	Wells Fargo/ US Bank GSR custody	2006-AR2
GS06CC	JP Morgan/ US Bank GSR custody	2006-4
GS06DC	Wells Fargo/ US Bank GSAMP custody	2006-HE3
GS06EC	JP Morgan/ US Bank GSAA custody	2006-9
GS06FC	Wells Fargo/ US Bank GSR custody	2006-5
GS06GC	Wells Fargo/ GSAMP custody	2006-HE4
GS06HC	Wells Fargo/ GSR custody	2006-6
GS06JC	Wells Fargo/ GSR custody	2006-7
GS06KC	Wells Fargo/ GSAA custody	2006-12
GS06LC	Wells Fargo/ GSAMP custody	2006-HE5
GS06MC	Wells Fargo/ GSR custody	2006-8
GS06OC	Wells Fargo/ GSAA custody	2006-14
GS06PC	Goldman Sachs/ US Bank/NCAMLT	2006-ALT2
GS06QC	GSAMP Goldman Sachs/ LaSalle/ Wells Fargo	2006-HE7
GS06RC	GSR Goldman Sachs/ US Bank/ Wells Fargo	2006-9F
GS06SC	GSAA Goldman Sachs/ US Bank/ Wells Fargo	2006-19
GS06TC	GSR Goldman Sachs/ US Bank/ Wells Fargo	2006-10F
GS06UC	GSAA Goldman Sachs/ US Bank/ Wells Fargo	2006-20
GS06VC	GSAMP Goldman Sachs/ LaSalle/ Wells Fargo	2006-HE8
GS072C	GSAA Goldman Sachs/ US Bank/ Wells Fargo	2007-1
GS073C	GSAMP Goldman Sachs/ LaSalle/Wells Fargo custody	2007-H1
GS074C	GSR Goldman Sachs/ Wells Fargo custody	2007-1F
GS075C	GSAMP Goldman Sachs/ Wells Fargo custody	2007-NC1
GS076C	GSAA Goldman Sachs/ Wells Fargo custody	2007-3
GS077C	GSAMP Goldman Sachs/ Wells Fargo custody	2007-HE1
GS078C	GSR Goldman Sachs/ Wells Fargo custody	2007-2F
GS07AC	GSAMP Goldman Sachs/ Wells Fargo custody	2007-HE2
GS07BC	GSR Goldman Sachs/ Wells Fargo custody	2007-3F
GS07DC	GSAA / Wells Fargo	2007-7
GS07EC	GSR / Wells Fargo	2007-4F
GS07FC	GSAA / Wells Fargo	2007-8
GS07GC	GSAA / Wells Fargo	2007-9
GS07HC	GSAA / Wells Fargo	2007-10
GS07KC	GSR / Wells Fargo	2007-5F
LH061Z	SASCO custody only	2006-BC2
LH062Z	LXS custody only	2006-13
LH063C	Lehman SAIL	2006-1
LH063Z	SAIL custody only	2006-BNC3
LH064C	Lehman LXS	2006-2N
LH064Z	LXS DB custody only	2006-14N
LH065C	Lehman SARM	2006-1
LH065Z	Lehman mortgage trust custody only	2006-5
LH066Z	Greenpoint DB custody only	2006-HE1

LH067C	Lehman SASCO	2006-BNC1
LH067Z	LXS DB custody only	2006-15
LH068C	Lehman SARM	2006-2
LH068Z	LXS DB custody only	2006-16H
LH069C	Lehman SAIL	2006-2
LH069Z	SARM DB custody only	2006-9
LH06AC	Lehman SARM	2006-3
LH06AZ	BNC DB custody only	2006-1
LH06BC	Lehman LXS	2006-5
LH06BZ	LMT DB custody only	2006-6
LH06CZ	SASCO DB custody only	2006-BC3
LH06DC	SAIL	2006-BNC2
LH06DZ	LMT custody only	2006-7
LH06EC	SASCO	2006-BC1
LH06FC	SASCO	2006-AM1
LH06FZ	LXS DB custody only	2006-17
LH06GC	SARM	2006-4
LH06GZ	BNC DB custody only	2006-10
LH06HC	LXS	2006-7
LH06IZ	SASCO DB custody only	2006-BC4
LH06JZ	LXS custody only	2006-19
LH06KC	SAIL custody only	2006-3
LH06KZ	LXS	2006-18N
LH06LC	LXS	2006-8
LH06MC	SARM custody only	2006-5
LH06MZ	SASCO custody only	2006-BC5
LH06NC	SASCO custody only	2006-NC1
LH06NZ	LMT custody only	2006-8
LH06PC	SAIL custody only	2006-4
LH06QC	SASCO custody only	2006-ARS1
LH06QZ	SASCO custody only	2006-BC6
LH06RC	LXS custody only	2006-10N
LH06RZ	LMT custody only	2006-9
LH06SC	LXS custody only	2006-9
LH06SZ	SARM custody only	2006-12
LH06UC	SARM custody only	2006-7
LH06UZ	LXS custody only	2006-20
LH06WC	LMT custody only	2006-4
LH06XC	LXS custody only	2006-11
LH06YC	LXS custody only	2006-12N
LH06ZC	SARM custody only	2006-8
LH071C	SASCO custody only	2007-BC1
LH071Z	LXS custody only	2007-18N
LH072Z	SARM custody only	2007-10
LH073C	LMT custody only	2007-1
LH074C	LXS custody only	2007-2N
LH074Z	SASCO custody only	2007-BNC1
LH075C	LXS custody only	2007-1
LH075Z	LMT custody only	2007-10
LH076C	LMT custody only	2007-2
LH076Z	LXS custody only	2007-20N
LH077C	BNC custody only	2007-1
LH077Z	SARM custody only	2007-11

LH078C	LXS custody only	2007-3
LH079C	LXS custody only	2007-4
LH079Z	SASCO custody only	2007-BC4
LH07AZ	BNC custody only	2007-4
LH07BC	SARM custody only	2007-3
LH07CC	LMT custody only	2007-4
LH07DC	LXS custody only	2007-5H
LH07FC	BNC custody only	2007-2
LH07GC	LXS custody only	2007-6
LH07JC	LMT custody only	2007-5
LH07KC	SASCO custody only	2007-BC3
LH07LC	LXS custody only	2007-9
LH07MC	LXS custody only	2007-8H
LH07NC	SASCO custody only	2007-OS1
LH07RC	LXS custody only	2007-12N
LH07SC	LXS custody only	2007-11
LH07TC	BNC custody only	2007-3
LH07WC	LMT custody only	2007-7
LH07XC	LXS custody only	2007-15N
LH07ZC	SARM custody only	2007-8
MG071C	MHL /Wells custody only	2007-1
MG072C	MHL /Wells custody only	2007-2
ML061C	MLMI	2006-AR1
ML072C	MANA /Wells Fargo custody only	2007-A3
ML073C	MANA /Wells Fargo custody only	2007-AF1
MS064C	MSM custody only	2006-11
SG071C	SG Mortgage Securities Trust	2007-NC1
SU071C	STICS /Wells Fargo custody only	2007-1
UB061C	UBS MASTR	2006-AM1
UB062C	UBS MASTR	2006-NC1
UB063C	Wells Fargo/ UBS MASTR	2006 HE-2
UB064C	MABS custody only	2006-AM2
UB065C	Wells Fargo/ UBS MASTR	2006-NC2
UB066C	Wells Fargo/ US Bank UBS MASTR custody only	2006-AM3
UB067C	Wells Fargo/ UBS MASTR	2006-NC3
UB068C	Wells Fargo/ UBS MASTR	2006-HE5
WA071C	WaMu / Citi custody	2007-HE2
WA072C	WaMu / Citi custody	2007-HE3
WA073C	WaMu / Citi custody	2007-HE4

EX-34.1

Exhibit 34.1

Report of Independent Registered Public Accounting Firm

To the Board of Directors of

VW Credit, Inc.

We have examined management’s assertion, included in the accompanying Report on Assessment of Compliance with Applicable Servicing Criteria, that VW Credit, Inc. (the Company) complied with the servicing criteria set forth in Title 17, Section 229.1122(d) of the Securities and Exchange Commission’s Regulation AB for the asset-backed securities transactions involving retail automotive loans registered with the Securities Exchange Commission for which the Company acted as servicer (the Regulation AB Platform), as of December 31, 2021, as well as the period ended December 31, 2021 for Volkswagen Auto Loan Enhanced Trust 2018-2 and Volkswagen Auto Loan Enhanced Trust 2020-1, and for the period from December 13, 2021 (the date of issuance) through December 31, 2021 for Volkswagen Auto Loan Enhanced Trust 2021-1, except for the servicing criteria set forth in Sections 229.1122(d)(1)(iv), 229.1122(d)(2)(iii), 229.1122(d)(2)(vi), 229.1122(d)(3)(ii) with respect to remittances, 229.1122(d)(3)(iii)-(iv), 229.1122(d)(4)(ix)-(xiii) and 229.112(d)(4)(xv), which the Company has determined are not applicable to the activities it performs with respect to the Regulation AB Platform. With respect to applicable servicing criteria 1122(d)(2)(iii), the Company has determined that there were no activities performed during the year ended December 31, 2021 with the respect to the Regulation AB Platform, because there were no occurrences of events that would require the Company to perform such activities. Appendix A to the Report on Assessment of Compliance with Applicable Servicing Criteria identifies the individual asset-backed transactions and securities defined by management as constituting the Regulation AB Platform. The management of VW Credit, Inc. is responsible for its assertion and for the Company’s compliance with those servicing criteria. Our responsibility is to express an opinion on the Company’s compliance based on our examination.

Our examination was conducted in accordance with attestation standards of the Public Company Accounting Oversight Board (United States) and in accordance with the attestation standards established by the American Institute of Certified Public Accountants. Those standards require that we plan and perform the examination to obtain reasonable assurance about whether management’s assertion regarding the Company’s compliance with the servicing criteria specified above is fairly stated, in all material respects, and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing of selected asset-backed transactions and securities that comprise the Regulation AB Platform, testing selected servicing activities related to the Regulation AB Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the applicable servicing criteria. Our procedures were limited to the selected transactions and servicing activities performed by the Company during the periods covered by this report. Our procedures were not designed to detect noncompliance arising from errors that may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report. We believe that our examination provides, and that the evidence we obtained is sufficient and appropriate to provide, a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the servicing criteria.

1

In our opinion, management’s assertion that VW Credit, Inc. complied with the aforementioned servicing criteria as of December 31, 2021 and for the year ended December 31, 2021 noted above, for asset-backed securities transactions involving automotive loan transactions completed and registered with the Securities Exchange Commission for which the Company acted as servicer is fairly stated, in all material respects.

/s/ Baker Tilly US, LLP

Tysons Corner, Virginia

March 25, 2022

2

EX-34.2

Exhibit 34.2

Report of Independent Registered Public Accounting Firm

We have examined management’s assertion, included in the accompanying Management’s Assertion of Compliance, that Trust & Agency Services department of Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas (collectively the “Company”) complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB for the publicly-issued (i.e., transaction-level reporting required under the Securities Exchange Act of 1934, as amended) and certain privately-issued (i.e., for which transaction-level reporting is required pursuant to contractual obligation) residential mortgage-backed securities, commercial mortgage-backed securities and other asset- backed securities issued on or after January 1, 2006, for which the Company provides trustee, certificate administrator, securities administration, paying agent or custodian services, as defined in the transaction agreements, excluding publicly-issued securities sponsored or issued by any government sponsored entity (the “Platform”), as of and for the year ended December 31, 2021, except for criteria 1122(d)(4)(iv) – 1122(d)(4)(xiv), which the Company has determined are not applicable to the activities it performs with respect to the servicing platform covered by this report. Refer to Appendix A of Management’s Assertion of Compliance for the asset backed transactions covered by this platform. Management is responsible for the Company’s compliance with those servicing criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance with the servicing criteria based on our examination.

Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing of less than all of the individual asset backed transactions and securities that comprise the platform, testing of less than all of the servicing activities related to the Platform and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the servicing criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. Although the Company is responsible for assessing compliance with criteria 1122(d)(1)(ii), 1122(d)(1)(iii), 1122(d)(2)(iii) and 1122(d)(4)(iii) of Regulation AB, there were no occurrences of events that would require the Company to perform such activities during the year ended December 31, 2021. We believe that the evidence we obtained is sufficient and appropriate to provide a reasonable basis for our opinion.

Our examination does not provide a legal determination on the Company’s compliance with the servicing criteria.

In our opinion, management’s assertion that the Company complied with the aforementioned servicing criteria as of and for the year ended December 31, 2021 for the Platform is fairly stated, in all material respects.

/s/ Ernst & Young LLP

February 28, 2022

EX-35.1

EXHIBIT 35.1

VW Credit, Inc. Servicer Compliance Statement Under Section 3.9 of the Sale and Servicing

Agreement and Item 1123 of Regulation AB

VOLKSWAGEN AUTO LOAN ENHANCED TRUST 2018-2

The undersigned, a duly authorized officer of VW Credit, Inc. (“VCI”), as Servicer under the Sale and Servicing Agreement dated as of November 21, 2018 (as amended and supplemented, or otherwise modified and in effect from time to time, the “Sale and Servicing Agreement”), by and among Volkswagen Auto Loan Enhanced Trust 2018-2, as Issuer, Volkswagen Auto Lease/Loan Underwritten Funding, LLC, as Seller, VW Credit, Inc., as Servicer, and Deutsche Bank Trust Company America, as Indenture Trustee, does hereby certify that:

1. A review of the activities of the Servicer during the period from January 1, 2021 through December 31, 2021, and of its performance under the Sale and Servicing Agreement, was conducted under my supervision.

2. To the best of my knowledge, based on such review, the Servicer has fulfilled all of its obligations under the Sale and Servicing Agreement in all material respects throughout such period.

IN WITNESS WHEREOF, the undersigned has duly executed this Certificate on behalf of the Servicer this 30th day of March, 2022.

/s/ Garett Miles

Garett Miles

Head of Securitization and Assistant Treasurer