Exhibit 33.1
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 in Item 1122(d) of Regulation AB are applicable in regard to the servicing platform for the period as follows:
Platform: Publicly-issued (i.e., transaction-level reporting initially required under the Securities Exchange Act of 1934, as amended) securities backed by insurance-related funding agreements issued on or after January 1, 2006, for which the Company provides the following servicing functions (the “Platform”): paying agent, calculation agent, trustee and registrar services.
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)(ii)-1122(d)(1)(iv), 1122(d)(2)(iii),1122(d)(2)(iv), 1122(d)(2)(vi), 1122(d)(2)(vii), 1122(d)(3)(i) and 1122(d)(4)(i)-1122(d)(4)(xv), which management has determined are not applicable to the activities the Company performs with respect to the Platform (the “Applicable Servicing Criteria”).
Period: Twelve months ended December 31, 2007 (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. |
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| | • | | The Company’s management has assessed compliance with the Applicable Servicing Criteria as of and for the Period. 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. |
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| | • | | Based on such assessment, other than as set forth onAppendix A hereto, the Company has complied, in all material respects, with the Applicable Servicing Criteria. |
KPMG LLP, a registered public accounting firm, has issued an attestation report with respect to the Company’s compliance with the Applicable Servicing Criteria as of and for the Period.
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| | CITIBANK, N.A.
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| | By: | /s/ Karen Montbach | |
| | | Karen Montbach | |
| | Its: Managing Director
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Dated: February 29, 2008
Appendix A
Material Instances of Noncompliance
| 1. | | 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. With respect to certain remittances during the reporting period, amounts due to investors were not allocated and remitted in accordance with the timeframes, distribution priority and other terms set forth in the transaction agreements. |
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| 2. | | 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. With respect to certain disbursements during the reporting period, the disbursements were not posted to the investor records within two business days. |
