Exhibit 99.3
Report on Assessment of Compliance with SEC Regulation AB Servicing Criteria
(i) ADS Alliance Data Systems, Inc. (“ADS”) is responsible for assessing compliance with the servicing criteria applicable to it under Item 1122(d) of Regulation AB as of and for the twelve month period ending December 31, 2006. Appendix A to this assertion identifies the individual asset-backed transactions covered by this report, which include asset-backed securities transactions for which the ADS acted as servicer involving credit card receivables (the “Platform”).
(ii) Except as described in the following sentence, ADS used the criteria in paragraph (d) of Item 1122 of Regulation AB to assess compliance with the applicable servicing criteria. The servicing criteria described in Items 1122(d)(1)(i) through 1122(d)(1)(iii), 1122(d)(2)(iii) through 1122(d)(2)(vi), 1122(d)(3)(i)(D), 1122(d)(3)(iii), 1122(d)(4)(i), 1122(d)(4)(iii) and 1122(d)(4)(x) through 1122(d)(4)(xiii) of Regulation AB are not applicable to the activities ADS performs as servicer for the Platform.
(iii) ADS has complied, in all material respects, with the applicable servicing criteria as of and for the twelve months ended December 31, 2006 with respect to the Platform taken as a whole.
(iv) Deloitte & Touche LLP, an independent registered public accounting firm, has issued an attestation report on ADS’s assessment of compliance with the applicable servicing criteria as of December 31, 2006 and for the twelve months ended December 31, 2006.
| | | | | | | |
| | | ADS ALLIANCE DATA SYSTEMS, INC. | | |
| | | | | | | |
| | | By:
Name: | | /s/ Michael D. Kubic Michael D. Kubic | | |
| | | Title: | | SVP, Corporate Controller and Chief Accounting Officer | | |
| | | Date: | | March 23, 2007 | | |
Appendix A
ADS has assessed its compliance with the Applicable Servicing Criteria for the following asset-backed transactions constituting the platform.
| | | |
| Series Name | | Issuer |
| | | |
| 2000-VFC | | World Financial Network Credit Card Master Trust III |
| 2002-A | | World Financial Network Credit Card Master Note Trust |
| 2002-VFN | | World Financial Network Credit Card Master Note Trust |
| 2003-A | | World Financial Network Credit Card Master Note Trust |
| 2004-A | | World Financial Network Credit Card Master Note Trust |
| 2004-C | | World Financial Network Credit Card Master Note Trust |
| 2006-A | | World Financial Network Credit Card Master Note Trust |
