Exhibit 33.6
MANAGEMENT’S ASSERTION OF COMPLIANCE
Management of the Agency and Trust division of Citibank, N.A. (or “Company”) is responsible for assessing compliance with the servicing criteria set forth in Item 1122(d) of Regulation AB promulgated by the Securities and Exchange Commission.
Management has determined that the servicing criteria set forth in Item 1122(d) of Regulation AB are applicable in regard to the servicing platform as of and for the period as follows:
Platform: Publicly-issued (i.e., transaction-level reporting initially 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 issued on or after January 1, 2006, as listed in Appendix A, for which the Company provides the following servicing functions:
● | paying agent, securities administration and trustee; or |
● | securities administration and paying agent; or |
● | paying agent and trustee; or |
● | paying agent |
The Platform also includes the transactions listed in Appendix B for which the Company is not a party to the transaction agreements, but for which securities administration servicing functions have been outsourced to the Company by a party to the transaction agreements.
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 servicing criteria: 1122(d)(1)(iii)-1122(d)(1)(iv), 1122(d)(2)(iii), 1122(d)(4)(i)-1122(d)(4)(ii) and 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”). 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. 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 servicing criterion 1122(d)(1)(ii), there were no activities performed during the twelve months ended December 31, 2018 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.
Period: Twelve months ended December 31, 2018 (the “Period”).
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. |
KPMG 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.
CITIBANK, N.A. | ||
By: | /s/ Karen Montbach | |
Its: | Managing Director |
Dated: February 28, 2019
Appendix A
Mortgage-backed Transactions and Securities Constituting the Platform
Deal Name | Deal Name | Deal Name | ||
AHMA2006-3 | CMLTI 2006-WFHE1 | CMLTI07-AR7 Mtge pass-thru | ||
American Home MtgeAssets06-4 | CMLTI 2006-WFHE3 | CMLTI07-AR8, Mtge pass-thru | ||
BAFC2007-6 | CMLTI 2006-WFHE4 | CMS07-1 | ||
CMALT2006-A1 | CMLTI 2006-WMC1 | CMS07-2 | ||
CMALT2006-A2 | CMLTI2007-10 | CMS07-3 | ||
CMALT2006-A3 | CMLTI 2007-AHL1 | CMSI06-1 | ||
CMALT2006-A4 | CMLTI 2007-AHL2 | CMSI06-2 | ||
CMALT2006-A5 | CMLTI 2007-AMC1 | CMSI06-3 | ||
CMALT2006-A6 | CMLTI 2007-AMC3 | CMSI06-4 | ||
CMALT2006-A7 | CMLTI 2007-WFHE1 | CMSI06-5 | ||
CMALT2007-A1 | CMLTI 2007-WFHE2 | CMSI06-6 | ||
CMALT2007-A2 | CMLTI 2007-WFHE3 | CMSI06-7 | ||
CMALT2007-A3 | CMLTI 2007-WFHE4 | CMSI07-4 | ||
CMALT2007-A4 | CMLTI2008-2 | CMSI07-5 | ||
CMALT2007-A5 | CMLTI HELOC Tr,06-NCB1 | CMSI07-6 | ||
CMALT2007-A6 | CMLTI06-4 Mtge pass-thru | CMSI07-7 | ||
CMALT2007-A7 | CMLTI06-AR1 MBNts | CMSI07-8 | ||
CMALT2007-A8 | CMLTI06-AR2 MBCerts | CMSI07-9 | ||
CMLTI 2006-WFHE2 | CMLTI06-AR3 Mtge pass-thru | CMSI2008-1 | ||
CMLTI07-AHL3 | CMLTI06-AR5 Mtge pass-thru | CMSI2008-2 | ||
CMLTI 2006-AMC1 | CMLTI06-AR6 Mtge Pass -Through Certs | CRMSI2006-1 | ||
CMLTI2006-HE1 | CMLTI06-AR7 Mtge pass-thru | CRMSI2006-2 | ||
CMLTI2006-HE2 | CMLTI06-AR9 Mtge pass-thru | CRMSI2006-3 | ||
CMLTI2006-HE3 | CMLTI-07-2 Mtge Pass Thru Cert | CRMSI2007-1 | ||
CMLTI2006-NC1 | CMLTI07-6, Mtge pass-thru | CRMSI2007-2 | ||
CMLTI2006-NC2 | CMLTI07-AR1 Mtge pass-thru | CSMC Trust2012-9 | ||
CMLTI2006-WF1 | CMLTI07-AR4 Mtge pass-thru | HALO07-1 | ||
CMLTI2006-WF2 | CMLTI07-AR5 Mtge pass-thru | HALO2006-2 |
Deal Name | Deal Name | Deal Name | ||
HALO2007-AR1 | SASCO Mtgepass-thru,06-S4 | SEMT2016-1 | ||
HALO2007-WF1 | SASCO Mtgepass-thru06-S3 | SEMT2016-2 | ||
HASCO06-HE2 HSI Asset SecuTr06-HE2 | SEMT2012-1 | SEMT2016-3 | ||
HASCO07-OPT1 Mtge pass-thru | SEMT2012-2 | SEMT2017-1 | ||
LMT2006-1 | SEMT2012-3 | SEMT2017-2 | ||
LMT2006-3 | SEMT2012-4 | SEMT2017-3 | ||
LMT2006-4 | SEMT2012-5 | SEMT2017-4 | ||
LXS2007-11 | SEMT2012-6 | SEMT2017-5 | ||
PHH Mtge2006-1 RMBS | SEMT2013-1 | SEMT2017-6 | ||
PHH Mtge2006-2 RMBS | SEMT2013-10 | SEMT2017-7 | ||
PHH Mtge2006-3 RMBS | SEMT2013-11 | SEMT2017-CH1 | ||
PHH Mtge2006-4 RMBS | SEMT2013-12 | SEMT2017-CH2 | ||
PHH Mtge2007-1 RMBS | SEMT2013-2 | SEMT2018-1 | ||
PHH Mtge2007-2 RMBS | SEMT2013-3 | SEMT2018-2 | ||
PHH Mtge2007-3 RMBS | SEMT2013-4 | SEMT2018-3 | ||
PHH Mtge2007-4 RMBS | SEMT2013-6 | SEMT2018-4 | ||
PHH Mtge2007-5 RMBS | SEMT2013-7 | SEMT2018-5 | ||
PHH Mtge2007-6 RMBS | SEMT2013-8 | SEMT2018-6 | ||
PMT2013-J1 | SEMT2013-9 | SEMT2018-7 | ||
SASCO BNC07-3 | SEMT2014-1 | SEMT2018-8 | ||
SASCO Lehman XS2006-1 | SEMT2014-2 | SEMT2018-CH1 | ||
SASCO Lehman XS2006-13 | SEMT2014-3 | SEMT2018-CH2 | ||
SASCO Lehman XS2006-17 | SEMT2014-4 | SEMT2018-CH3 | ||
SASCO Lehman XS2006-5 | SEMT2015-1 | SEMT2018-CH4 | ||
SASCO Lehman XS2006-7 | SEMT2015-2 | WAMU2007-HE2 | ||
SASCO Lehman XS2006-9 | SEMT2015-3 | WAMU2007-HE3 | ||
SASCO Mtgepass-thru,06-3H | SEMT2015-4 | WAMU2007-HE4 | ||
SASCO Mtgepass-thru,06-S2 |
Appendix B
Mortgage-backed Transactions and Securities Constituting the Platform1
Deal Name
RALI06QH1
RALI06QO1
RALI06QO10
RALI06QO2
RALI06QO3
RALI06QO4
RALI06QO5
RALI06QO6
RALI06QO7
RALI06QO8
RALI06QO9
RALI07QH1
RALI07QH2
RALI07QH3
RALI07QH4
RALI07QH5
RALI07QH6
RALI07QH7
RALI07QH8
RALI07QH9
RALI07QO1
RALI07QO2
RALI07QO3
RALI07QO4
RALI07QO5
1The transactions listed consist of certain transactions for which the Company is not a party to the transaction agreements, but for which securities administration servicing functions have been outsourced to the Company by a party to the transaction agreements with respect to servicing criteria 1122(d)(1)(v), 1122(d)(3)(i)(A), 1122(d)(3)(i)(B) and 1122(d)(3)(i)(D), as well as 1122(d)(3)(ii), but only as it relates to the allocation of amounts due to investors in accordance with the distribution priority and other terms set forth in the transaction agreements.