INDEPENDENT ACCOUNTANTS' REPORT
To the Board of Directors of E*TRADE Consumer Finance:
We have examined management's assertion that E*TRADE Consumer Finance, formerly
Ganis Credit Corporation (the "Company") has complied as of and for the year
ended December 31, 2003, with its established minimum servicing standards for
retail recreational vehicle and marine loans as described in the accompanying
Management's Assertion dated March 9, 2004, as it relates to RV Trust 1999-1,
Marine Trust 1999-2, RV Trust 1999-3, and RV/Marine Trust 2001-1. Management is
responsible for the Company's compliance with those minimum servicing standards.
Our responsibility is to express an opinion on management's assertion about the
Company's compliance based on our examination.
Our examination was conducted in accordance with attestation standards
established by the American Institute of Certified Public Accountants and,
accordingly, included examining, on a test basis, evidence about the Company's
compliance with the minimum servicing standards and performing such other
procedures as we considered necessary in the circumstances. We believe that our
examination provides a reasonable basis for our opinion. Our examination does
not provide a legal determination on the Company's compliance with its minimum
servicing standards.
In our opinion, management's assertion that the Company complied with the
aforementioned minimum servicing standards as of and for the year ended December
31, 2003, is fairly stated, in all material respects based on the criteria set
forth in the Appendix.
/s/ DELOITTE & TOUCHE LLP
McLean, Virginia
March 9, 2004
APPENDIX: MINIMUM SERVICING STANDARDS
I. CUSTODIAL BANK ACCOUNTS
1. 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.
2. Funds of the servicing entity shall be advanced in cases where there is an
overdraft in an investor's or a borrower's account.
3. Each custodial account shall be maintained at a federally insured depository
institution in trust for the applicable investor.
II. PAYMENTS
1. Payments shall be deposited into the custodial bank accounts and related bank
clearing accounts within two business days of receipt.
2. Payments made in accordance with the borrower's loan documents shall be
posted to the applicable borrower records within two business days of receipt.
3. Payments shall be allocated to principal, interest, insurance, taxes or other
escrow items in accordance with the borrower's loan documents.
4. Payments identified as loan payoffs shall be allocated in accordance with the
borrower's loan documents.
III. DISBURSEMENTS
1. Disbursements made via wire transfer on behalf of a borrower or investor
shall be made only by authorized personnel.
2. Disbursements made on behalf of a borrower or investor shall be sent to the
trustee on the 14th day of the calendar month as stated in the servicing
agreements.
3. Amounts remitted to investors per the servicer's investor reports shall agree
with cancelled checks, or other form of payment, or custodial bank statements.
IV. INVESTOR ACCOUNTING AND REPORTING
1. The servicing entity's investor reports shall agree with, or reconcile to,
investors' records on a monthly basis as to the total unpaid principal balance
and number of loans serviced by the servicing entity.
V. LOAN ACCOUNTING
1. The servicing entity's loan records shall agree with, or reconcile to, the
records of the borrower with respect to the unpaid principal balance on a
monthly basis.
2. Adjustments on step loans shall be computed based on the related borrower
note and any rider.
VI. DELINQUENCIES
1. 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 mortgage payment rescheduling plans in cases
where the delinquency is deemed temporary (e.g., illness or unemployment).
VII. INSURANCE POLICIES
1. A fidelity bond and errors and omissions policy shall be in effect on the
servicing entity throughout the reporting period in the amount of coverage
represented to investors in management's assertion.
Exhibit 2
E*TRADE Consumer Finance Corporation
Park Place
3353 Michelson Drive--2nd Floor
Irvine, CA 92612
Telephone 949-224-7700 etrade.com
MANAGEMENT'S ASSERTION
----------------------
March 9, 2004
As of and for the year ended December 31, 2003, E*TRADE Consumer Finance,
formerly Ganis Credit Corporation (the "Company") has complied, in all material
respects, with the Company's minimum servicing standards for retail recreational
vehicle and marine loans as set forth in the attached Appendix (the "Standards")
relating to RV Trust 1999-1, Marine Trust 1999-2, RV Trust 1999-3, and RV/Marine
Trust 2001-1. The Standards are based on the Mortgage Banker's Association of
America's Uniform Single Attestation Program for Mortgage Bankers, modified to
address the unique characteristics of the servicing of retail recreational
vehicle and marine loans. As of and for this same period, the Company was
covered by a fidelity bond and an errors and omissions policy in the amount of
$50 million.
/s/ Edward J. Arienti
- --------------------------------
Edward J. Arienti
President
/s/ Greg G. Gabriel
- --------------------------------
Greg G. Gabriel
Senior Vice President, Credit
/s/ Matthew Pechulis
- --------------------------------
Matthew Pechulis
Controller
APPENDIX: MINIMUM SERVICING STANDARDS
I. CUSTODIAL BANK ACCOUNTS
1. 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.
2. Funds of the servicing entity shall be advanced in cases where there is an
overdraft in an investor's or a borrower's account.
3. Each custodial account shall be maintained at a federally insured
depository institution in trust for the applicable investor.
II. PAYMENTS
1. Payments shall be deposited into the custodial bank accounts and related
bank clearing accounts within two business days of receipt.
2. Payments made in accordance with the borrower's loan documents shall be
posted to the applicable borrower records within two business days of receipt.
3. Payments shall be allocated to principal, interest, insurance, taxes or
other escrow items in accordance with the borrower's loan documents.
4. Payments identified as loan payoffs shall be allocated in accordance with
the borrower's loan documents.
III. DISBURSEMENTS
1. Disbursements made via wire transfer on behalf of a borrower or investor
shall be made only by authorized personnel.
2. Disbursements made on behalf of a borrower or investor shall be sent to the
trustee on the 14th day of the calendar month as stated in the servicing
agreements.
3. Amounts remitted to investors per the servicer's investor reports shall
agree with cancelled checks, or other form of payment, or custodial bank
statements.
IV. INVESTOR ACCOUNTING AND REPORTING
1. The servicing entity's investor reports shall agree with, or reconcile to,
investors' records on a monthly basis as to the total unpaid principal balance
and number of loans serviced by the servicing entity.
V. LOAN ACCOUNTING
1. The servicing entity's loan records shall agree with, or reconcile to, the
records of the borrower with respect to the unpaid principal balance on a
monthly basis.
2. Adjustments on step loans shall be computed based on the related borrower
note and any rider.
VI. DELINQUENCIES
1. 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 mortgage payment rescheduling plans in
cases where the delinquency is deemed temporary (e.g., illness or unemployment).
VII. INSURANCE POLICIES
1. A fidelity bond and errors and omissions policy shall be in effect on the
servicing entity throughout the reporting period in the amount of coverage
represented to investors in management's assertion.