Consumers 2014 Securitization Funding LLC
| General Offices: | Tel: (517) 788 2100 |
| One Energy Plaza | Fax: (517) 788 7290 |
| Jackson, MI 49201 |
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| Glenn P. Barba |
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| Vice President and Controller |
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| August 30, 2017 |
Mr. M. Hughes Bates
Special Counsel
Office of Structured Finance
United States Securities and Exchange Commission
Washington, D.C. 20549
Re: Consumers 2014 Securitization Funding LLC (Issuing Entity and Registrant)
Form 10-K for Fiscal Year Ended December 31, 2016
Filed March 9, 2017
File No. 333-195654-01
Dear Mr. Bates:
On behalf of Consumers 2014 Securitization Funding LLC (“Consumers 2014 Funding”) and Consumers Energy Company (“Consumers”), we thank you for your review of our filing and for your comment. We take very seriously our responsibility for the completeness and accuracy of the disclosures in our filings with the Commission, and we appreciate having the opportunity to improve their quality and to enhance our compliance with all applicable requirements.
Exhibits 33.1 and 33.2
1Q. With respect to the reports on assessment of compliance with applicable servicing criteria attached as Exhibits 33.1 and 33.2, we note that none of the servicing participants identified by the registrant has taken responsibility for assessing compliance with the servicing criterion specified in Item 1122(d)(1)(v), which requires that “[a]ggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.” Please advise why no servicing party took responsibility for the aggregation of information.
1A. Consumers confirms that it was responsible for the aggregation of information for the year ended December 31, 2016, that the aggregation of information was mathematically accurate, and that the information conveyed accurately reflected the information. In its report on assessment of compliance, Consumers specified that Item 1122(d)(1)(v) of Regulation AB was an inapplicable servicing criterion because Consumers believed that its activities as the single servicer did not include those contemplated by Item 1122(d)(1)(v), as illustrated in the example given in footnote 1353 of SEC Release No. 33-9638.
Upon further review of SEC Release No. 33-9638, Consumers has determined that Item 1122(d)(1)(v) is in fact applicable to its servicing assessment, given that Consumers aggregates and conveys payment information to The Bank of New York Mellon in its capacity as Trustee and Indenture Trustee, in order for The Bank of New York Mellon to make debt service payments. Consumers confirms that in future filings of Consumers 2014 Funding, Consumers will assess its compliance with the servicing criterion specified in Item 1122(d)(1)(v).
Mr. M. Hughes Bates
August 30, 2017
Should you have any questions or comments regarding our response to your letter, please contact me at (517) 788-2100 or at glenn.barba@cmsenergy.com.
Sincerely,
/s/ Glenn P. Barba
Glenn P. Barba
Vice President, Controller and Chief Accounting Officer
of Consumers Energy Company, as Servicer
