Exhibit 99.2
Management's Assertion Concerning Compliance
with USAP Minimum Servicing Standards, to the extent the procedures in such are
applicable to the servicing obligations set forth in the Servicing Agreement
March 26, 2003
As of and for the year ended December 31, 2002, CIT Financial USA, Inc. (the
"Company"), a wholly owned subsidiary of CIT Group Inc., has complied in all
material respects with the minimum servicing standards set forth in the Mortgage
Bankers Association of America's Uniform Single Attestation Program for Mortgage
Bankers ("USAP"), to the extent the procedures in such are applicable to the
servicing obligations set forth in the Servicing Agreements. During the year
ended December 31, 2002, certain instances of noncompliance with the standards
occurred as noted below:
Custodial Bank Accounts
Standard: Reconciliations shall be prepared on a monthly basis for all custodial
bank accounts and related bank clearing accounts. These reconciliations shall:
o Be mathematically accurate;
o Be prepared within forty-five (45) calendar days after the cutoff date;
o Be reviewed and approved by someone other than the person who prepared the
reconciliation; and
o Document explanations for reconciling items. These reconciling items shall
be resolved within ninety (90) calendar days of their original
identification.
The preparation of certain bank account reconciliations during the year were
completed and contained unreconciled variances. Certain reconciling items and
unreconciled variances were not resolved within 90 days of identification. The
approval of certain bank account reconciliations was not evidenced. Management
is in the process of revising and implementing standards and policies
surrounding this bank account to require formal evidence of approval and has
assigned appropriate personnel to ensure resolution of all reconciling items and
unreconciled variances.
Payments
Standard: Payments made in accordance with the lease/loan documents shall be
posted to the applicable records accurately and on a timely basis.
Certain reconciling items were not cleared within 90 days of their original
identification. Management has reviewed all significant reconciling items and
management does not believe that these items have a material impact on the
lease/loan records and has assigned appropriate personnel to ensure the proper
resolution of all items.
Standard: Payments shall be deposited into the custodial bank accounts and
related bank clearing accounts on a timely basis.
Cash receipts received directly at the subservicer's (Dell Financial Services)
servicing center were not tracked from date of receipt to the date of deposit
from January 2002 to July 2002. The Company and Dell Financial Services have
developed a tracking process for checks received at the sub-servicing center
to ensure controls and to expedite deposit into the custodial bank account.
These controls were put into place in August 2002.
Delinquencies
Standard: Records documenting collection efforts shall be maintained during the
period a loan is in default and shall be updated at least monthly. Such records
shall describe the entity's activities in monitoring delinquent loans including,
for example, phone calls, letters and payment rescheduling plans in cases where
the delinquency is deemed temporary (e.g., illness or unemployment).
There were certain instances whereby account collection efforts were not
performed or maintained at least monthly due to the resignation of certain
employees. However, in all instances, where applicable, the accounts were
treated with system generated dunning notices in accordance with the collection
policies. Management believes that the systemic collection process & strategies
it employs provides maximum coverage of delinquent accounts and has implemented
additional procedures to review documentation regarding collection efforts.
In addition, Management has reviewed its staffing resource needs and has
implemented a variety of retention strategies aimed at stabilizing turnover
rates.
As of and for this same period, CIT Group Inc. had in effect a financial
institution bond, computer crime policy, and errors and omissions policy in the
following amounts:
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Insurance Type Coverage Effective period
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Financial institution bond $60mm 09/30/98 to 09/15/02
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$60mm 09/30/02 to 09/30/03
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Computer crime policy $60mm 09/30/98 to 09/15/02
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$60mm 09/30/02 to 09/30/03
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Errors and omissions $25mm 12/30/01 to 12/30/02
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$10mm 12/30/02 to 12/30/03
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/s/ Thomas B. Hallman
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Thomas B. Hallman
Chief Executive Officer
CIT Financial USA, Inc.
/s/ Kenneth P. Reynolds
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Kenneth P. Reynolds
Senior Vice President and Controller
CIT Financial USA, Inc.
/s/ Frank Garcia
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Frank Garcia
Senior Vice President
CIT Financial USA, Inc.