EX-33.2 4 d163739dex332.htm EX-33.2 EX-33.2

Exhibit 33.2

 

LOGO       Corporate Trust Services
    Asset Backed Securities
   

MAC N9300-061

600 S. 4th Street

   

Minneapolis, MN 55479

 

    Tel: 612 667 8058
    Fax: 612 667 3464

ASSESSMENT OF COMPLIANCE WITH THE APPLICABLE SERVICING CRITERIA

The management (“Management”) of the Corporate Trust Services division of Wells Fargo Bank, National Association (the “Company”) is responsible for assessing the Company’s compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission. Management has determined that the servicing criteria are applicable in regard to the servicing platform for the period as follows:

Period: As of and for the twelve months ended December 31, 2020 (the “Period”).

Platform: The platform consists of asset-backed securities (“ABS”) transactions for which the Company provides trustee (except Delaware trustee or owner trustee) and/or paying agent services and for which either (i) some or all of the issued securities for such ABS transactions were publicly offered pursuant to a registration statement delivered under the Securities Act of 1933, as amended, or (ii) the issued securities for such ABS transactions were privately offered pursuant to an exemption from registration and the Company has an obligation under the transaction agreements to deliver an assessment of compliance with the applicable servicing criteria under Item 1122(d) of Regulation AB; provided however that, the platform excludes (a) any transactions for which the securities issued are mortgage-backed securities or mortgage-related asset-backed securities and (b) certain transactions for which the issuing entity has a fiscal year that ends on a date other than the end of the calendar year (the “ABS Platform”). Appendix A identifies the individual transactions defined by Management as constituting the ABS Platform for the Period.

Applicable Servicing Criteria: All servicing criteria set forth in Item 1122(d) applicable to the Company’s obligations in the related transaction agreements with respect to the ABS Platform for the Period, except for the following servicing criteria: 1122(d)(1)(v), 1122(d)(2)(iii), 1122(d)(3)(i)(B), 1122(d)(3)(i)(C), 1122(d)(3)(i)(D), 1122(d)(4)(ii), 1122(d)(4)(iv), 1122(d)(4)(v), 1122(d)(4)(vi), 1122(d)(4)(vii), 1122(d)(4)(viii), 1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii) and 1122(d)(4)(xiv), which Management has determined are not applicable to the Company’s obligations in the related transaction agreements with respect to the ABS Platform for the Period; provided however that, with respect to the ABS Platform (a) servicing criterion 1122(d)(3)(i)(A) is applicable only as it relates to the Company’s obligation to distribute or make available to investors, in accordance with the timeframes set forth in the transaction agreements, the relevant investor reports received by the Company from the entity preparing such reports; (b) servicing criterion 1122(d)(3)(ii) is applicable only as it relates to the Company’s obligation to make remittances to investors in accordance with the transaction agreements; and (c) servicing criterion 1122(d)(4)(iii) is applicable only as it relates to the Company’s obligation to obtain an Officer’s Certificate from the servicer and report any additions, removals and substitutions to investors on the relevant investor report, in each case, in accordance with the transaction agreements (the “Applicable Servicing Criteria”).

With respect to the ABS Platform and the Period, Management provides the following assessment of the Company’s compliance with respect to the Applicable Servicing Criteria:

1. Management is responsible for assessing the Company’s compliance with the Applicable Servicing Criteria.

 

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

3. With respect to Applicable Servicing Criteria 1122(d)(1)(ii), 1122(d)(4)(i), and 1122(d)(4)(xv), Management has determined that there were no activities performed during the Period with respect to the ABS Platform, because there were no occurrences of events that would require the Company to perform such activities.

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

KPMG LLP, an independent registered public accounting firm, has issued an attestation report with respect to Management’s assessment of the Company’s compliance with the Applicable Servicing Criteria for the Period.

 

WELLS FARGO BANK, National Association
By:  

/s/ Bruce C. Wandersee

  Bruce C. Wandersee
Title:   Senior Vice President
Dated:   February 16, 2021

 

2


Appendix A to the Company’s Assessment of Compliance with the Applicable Servicing Criteria

ABS Platform Transactions

 

Wells Fargo Deal Identifier

  

Long Name

AMOT173    Ally Master Owner Trust 2017-3
AMOT181    Ally Master Owner Trust 2018-1
AMOT182    Ally Master Owner Trust 2018-2
AMOT183    Ally Master Owner Trust 2018-3
AMOT184    Ally Master Owner Trust 2018-4
BANKONESER1    Chase Issuance Trust
CARVANA2020P1    Carvana Auto Receivables Trust 2020-P1
CITEL051    CIT Education Loan Trust 2005-1
EART203    Exeter Automobile Receivables Trust 2020-3
GMALT172    GM Financial Automobile Leasing Trust 2017-2
GMALT173    GM Financial Automobile Leasing Trust 2017-3
GMALT181    GM Financial Automobile Leasing Trust 2018-1
GMALT182    GM Financial Automobile Leasing Trust 2018-2
GMALT183    GM Financial Automobile Leasing Trust 2018-3
GMALT191    GM Financial Automobile Leasing Trust 2019-1
GMALT192    GM Financial Automobile Leasing Trust 2019-2
GMALT193    GM Financial Automobile Leasing Trust 2019-3
GMALT201    GM Financial Automobile Leasing Trust 2020-1
GMALT202    GM Financial Automobile Leasing Trust 2020-2
GMALT203    GM Financial Automobile Leasing Trust 2020-3
GMCAR181    GM Financial Consumer Automobile Receivables Trust 2018-1
GMCAR182    GM Financial Consumer Automobile Receivables Trust 2018-2
GMCAR193    GM Financial Consumer Automobile Receivables Trust 2019-3
GMCAR194    GM Financial Consumer Automobile Receivables Trust 2019-4
GMCAR203    GM Financial Consumer Automobile Receivables Trust 2020-3
GMCAR204    GM Financial Consumer Automobile Receivables Trust 2020-4
GREENTREE961    Green Tree Manufactured Housing Contract Senior/Subordinate Pass-Through Certificates, Series 1996-1
GREENTREE962    Green Tree Manufactured Housing Contract Senior/Subordinate Pass-Through Certificates, Series 1996-2
HUNT2016-1    Huntington Auto Trust 2016-1
NAVIENT151    Navient Student Loan Trust 2015-1
NAVIENT152    Navient Student Loan Trust 2015-2
NAVIENT153    Navient Student Loan Trust 2015-3
NSLT043    Nelnet Student Loan Trust Student Loan Asset Backed Notes Series 2004-3
NSLT044    Nelnet Student Loan Trust Student Loan Asset Backed Notes Series 2004-4
NSLT051    Nelnet Student Loan Trust Student Loan Asset Backed Notes Series 2005-1
NSLT052    Nelnet Student Loan Trust Student Loan Asset Backed Notes Series 2005-2
NSLT053    Nelnet Student Loan Trust Student Loan Asset Backed Notes Series 2005-3
NSLT054    Nelnet Student Loan Trust Student Loan Asset Backed Notes Series 2005-4
NSLT061    Nelnet Student Loan Trust Student Loan Asset Backed Notes Series 2006-1
NSLT062    Nelnet Student Loan Trust Student Loan Asset Backed Notes Series 2006-2
NSLT063    Nelnet Student Loan Trust Student Loan Asset Backed Notes Series 2006-3
NSLT071    Nelnet Student Loan Trust Student Loan Asset Backed Notes Series 2007-1
OAKWOOD2000C    Oakwood Mortgage Investors 2000-C Senior/Subordinate Pass-Through Certificates
OAKWOOD2000D    Oakwood Mortgage Investors Series 2000-D Senior/Subordinate Pass-Through Certificates
SDART154    Santander Drive Auto Receivables Trust 2015-4
SDART155    Santander Drive Auto Receivables Trust 2015-5
SDART161    Santander Drive Auto Receivables Trust 2016-1
SDART162    Santander Drive Auto Receivables Trust 2016-2
SDART163    Santander Drive Auto Receivables Trust 2016-3
SDART171    Santander Drive Auto Receivables Trust 2017-1
SDART172    Santander Drive Auto Receivables Trust 2017-2
SDART173    Santander Drive Auto Receivables Trust 2017-3
SDART181    Santander Drive Auto Receivables Trust 2018-1
SDART182    Santander Drive Auto Receivables Trust 2018-2
SDART183    Santander Drive Auto Receivables Trust 2018-3
SDART184    Santander Drive Auto Receivables Trust 2018-4
SDART185    Santander Drive Auto Receivables Trust 2018-5
SDART191    Santander Drive Auto Receivables Trust 2019-1
SDART192    Santander Drive Auto Receivables Trust 2019-2
SDART193    Santander Drive Auto Receivables Trust 2019-3
SDART201    Santander Drive Auto Receivables Trust 2020-1
SDART202    Santander Drive Auto Receivables Trust 2020-2
SDART203    Santander Drive Auto Receivables Trust 2020-3
SDART204    Santander Drive Auto Receivables Trust 2020-4

 

Appendix A-1