Exhibit 33.1
P.O. Box 77400 • Ewing, NJ 08628 • 609-883-3900
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Management Assessment
Management of the Cenlar FSB (the Company) is responsible for assessing compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of residential mortgage loans (the Platform) except for servicing criteria 1122(d)(1)(iii) Backup Servicer, as of and for the year ended December 31, 2014. This criterion is not applicable to the Company because the Company does not perform activities with respect to the Platform relating to this criterion. Appendix A identifies the individual asset-backed transactions and securities defined by management as constituting the Platform. With respect to servicing criteria 1122 (d)(2)(vi) and 1122(d)(4)(xi), management has engaged various vendors to perform the activities required by these servicing criteria and has determined that these vendors are not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Company has elected to take responsibility for assessing compliance with the applicable servicing criteria applicable to each vendor as permitted by Regulation AB Compliance and Disclosure Interpretations of the Division of Corporation Finance, Section 200.06, “Vendors Engaged by Servicers” (C&DI 200.06). As permitted by C &DI 200.06, the Company asserts that it has policies and procedures in place, designed and operating effectively to provide reasonable assurance that the vendors’ activities comply in all material respects with servicing criteria applicable to each vendor.
The Company’s management has assessed the Company’s compliance with the applicable servicing criteria as of and for the year ended December 31, 2014. 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, management has concluded that, as of and for the year ended December 31, 2014, the Company has complied in all material respects with the servicing criteria, except for the servicing criteria 1122(d)(1)(iii) Backup Servicer, set forth in item 1122(d) of Regulation AB of the Securities and Exchange Commission relating to the servicing of the Platform.
Ernst & Young LLP an independent registered public accounting firm, has issued an attestation report with respect to management’s assessment of compliance with the applicable servicing criteria as of and for the year ended December 31, 2014.
/s/ Gregory S. Tornquist | ||||
Gregory S. Tornquist | ||||
Chairman, President & CEO | ||||
/s/ Stephen W. Gozdan | /s/ Michael Blair | |||
Stephen W. Gozdan | Michael Blair | |||
Chief Financial Officer | Sr. Vice President |
February 27, 2015
Overnight Mail: Cenler FSB • 425 Phillips Boulevard • Ewing, NJ 08618 |
Appendix A
Securities Covered in Cenlar FSB’s REG AB Attestation:
Investor | Servicer | Security | Period Subserviced by Cenlar FSB | |||
A54 | New York Mortgage Company | NYMC 06-1 | 1/1 to 12/31/14 | |||
G52 | Opteum Financial Services, LLC | OMAC 06-1 | 1/1 to 12/31/14 | |||
H52 | Opteum Financial Services, LLC | OMAC 06-2 | 1/1 to 12/31/14 | |||
J52 | Opteum Financial Services, LLC | BAFC 2006-11 | 1/1 to 12/31/14 | |||
K52 | Opteum Financial Services, LLC | CMLTI 06-FX1 | 1/1 to 12/31/14 | |||
P52 | Opteum Financial Services, LLC | CMLTI 07-OPX1 | 1/1 to 12/31/14 | |||
G43 | Thornburg Mortgage Home Loans (RBS Financial) | TMST 2007-3 | 1/1 to 12/31/14 | |||
WF3 | Lydian Bank/Wells Fargo | GSR 2006 AR1 | 1/1 to 12/31/14 | |||
WF4 | Lydian Bank/Wells Fargo | GSR 2006 AR2 | 1/1 to 12/31/14 | |||
S06/T06 | Morgan Stanley Private Bank, NA | Sequoia Mortgage Trust 2007-2 | 1/1 to 05/02/14 | |||
S06/T06 | Morgan Stanley Private Bank, NA | Sequoia Mortgage Trust 2007-3 | 1/1 to 05/02/14 | |||
S06/T06 | Morgan Stanley Private Bank, NA | Sequoia Mortgage Trust 2007-4 | 1/1 to 05/02/14 | |||
N06 | Morgan Stanley Private Bank, NA | MSM 2007-15AR | 1/1 to 05/02/14 | |||
H06 | Redwood Residential Acquisition Corp | SEMT 2012-1 | 1/1 to 12/31/14 | |||
K06 | Redwood Residential Acquisition Corp | SEMT 2012-2 | 1/1 to 12/31/14 | |||
L06 | Redwood Residential Acquisition Corp | SEMT 2012-3 | 1/1 to 12/31/14 | |||
Z06 | Redwood Residential Acquisition Corp | SEMT 2012-4 | 1/1 to 12/31/14 | |||
Y06 | Redwood Residential Acquisition Corp | SEMT 2012-5 | 1/1 to 12/31/14 | |||
RWO | Redwood Residential Acquisition Corp | SEMT 2012-6 | 1/1 to 12/31/14 |
RW1 | Redwood Residential Acquisition Corp | SEMT 2013-1 | 1/1 to 12/31/14 | |||
RW2/S11 | Redwood Residential Acquisition Corp | SEMT 2013-2 | 1/1 to 12/31/14 | |||
RW3 | Redwood Residential Acquisition Corp | SEMT 2013-3 | 1/1 to 12/31/14 | |||
RW4 | Redwood Residential Acquisition Corp | SEMT 2013-4 | 1/1 to 12/31/14 | |||
RW5 | Redwood Residential Acquisition Corp | SEMT 2013-5 | 1/1 to 12/31/14 | |||
RW6 | Redwood Residential Acquisition Corp | SEMT 2013-6 | 1/1 to 12/31/14 | |||
RW7 | Redwood Residential Acquisition Corp | SEMT 2013-7 | 1/1 to 12/31/14 | |||
RW8 | Redwood Residential Acquisition Corp | SEMT 2013-8 | 1/01/14 to 12/31/14 | |||
RX0 | Redwood Residential Acquisition Corp | SEMT 2013-9 | 1/01/14 to 12/31/14 | |||
RX1/T11 | Redwood Residential Acquisition Corp | SEMT 2013-10 | 1/01/14 to 12/31/14 | |||
RX2/R11 | Redwood Residential Acquisition Corp | SEMT 2013-11 | 1/01/14 to 12/31/14 | |||
RX3 | Redwood Residential Acquisition Corp | SEMT 2013-12 | 1/01/14 to 12/31/14 | |||
RX8 | Redwood Residential Acquisition Corp | SEMT 2014-1 | 04/01/14 to 12/31/14 | |||
RT4 | Redwood Residential Acquisition Corp | SEMT 2014-2 | 09/01/14 to 12/31/14 | |||
RT5 | Redwood Residential Acquisition Corp | SEMT 2014-3 | 10/01/14 to 12/31/14 | |||
RD0 | Redwood Residential Acquisition Corp | SEMT 2014-4 | 11/01/14 to 12/31/14 | |||
TH6 | Matrix Financial Services Corporation-Two Harbors | AMBT 2013-1 | 1/1 to 12/31/14 | |||
TH5 | Matrix Financial Services Corporation-Two Harbors | AMBT 2014-1 | 08/01/14 to 12/31/14 | |||
TH4 | Matrix Financial Services Corporation-Two Harbors | AMBT 2014-2 | 09/01/14 to 12/31/14 | |||
TH3 | Matrix Financial Services Corporation-Two Harbors | AMBT 2014-3 | 10/01/14 to 12/31/14 | |||
GP1/PN9/SQ0 | Pingora Loan Servicing, LLC | JPMMT 2014-OAK4 | 10/01/14 to 12/31/14 | |||
GP0/PN7/U23 | Pingora Loan Servicing, LLC | JPMMT 2014-IVR3 | 09/01/14 to 12/31/14 | |||
GP2 | Pingora Loan Servicing, LLC | JPMMT 2014-5 | 11/01/14 to 12/31/14 |
FK3 | FirstKey Mortgage, LLC | FKM 2014-1 | 11/01/14 to 12/31/14 | |||
WW8 | WINWater Residential Acquisition Corp. | WIN 2014-1 | 06/01/14 to 12/31/14 | |||
WW7 | WINWater Residential Acquisition Corp. | WIN 2014-2 | 11/01/14 to 12/31/14 | |||
WW6 | WINWater Residential Acquisition Corp. | WIN 2014-3 | 12/01/14 to 12/31/14 |