Attached files
Report of Independent Registered Public Accounting Firm
The Board of Directors
The Trust & Securities Services department of Deutsche Bank National Trust Company and
Deutsche Bank Trust Company Americas:
We have examined management's assertion, included in the accompanying Management's Assertion of
Compliance, that the Trust & Securities Services department of Deutsche Bank National Trust Company
and Deutsche Bank Trust Company Americas (collectively the "Company") complied with the servicing
criteria set forth in Item 1122(d) of the Securities and Exchange Commission's Regulation AB for
publicly-issued (i.e., transaction-level reporting required under the Securities Exchange Act of 1934, as
amended) and certain privately-issued (i.e., for which transaction-level reporting is required pursuant to
contractual obligation) residential mortgage-backed securities, commercial mortgage-backed securities and
other asset-backed securities issued on or after January 1, 2006, for which the Company provides trustee,
certificate administrator, securities administration, paying agent or custodian services, as defined in the
transaction agreements, excluding publicly-issued securities sponsored or issued by any government
sponsored entity (the "Platform"), except for servicing criteria 1122(d)(4)(iv) – 1122(d)(4)(xiv), which the
Company has determined are not applicable to the activities it performs with respect to the Platform, as of
and for the year ended December 31, 2015. With respect to servicing criteria 1122(d)(1)(ii), 1122(d)(1)(iii),
1122(d)(2)(iii) and 1122(d)(4)(iii), Management's Assertion of Compliance indicates that there were no
activities performed during the year ended December 31, 2015 with respect to the Platform, because there
were no occurrences of events that would require the Company to perform such activities. The Company
has determined the following servicing criteria to be applicable only to the activities the Company
performs with respect to the Platform as described below:
Servicing criterion 1122(d)(1)(iii) is applicable only with respect to the Company's continuing
obligation to act as, or locate a, successor servicer under the circumstances referred to in certain
transaction agreements. It is management's interpretation that the Company has no other active
back-up servicing responsibilities in regards to servicing criterion 1122(d)(1)(iii) as of and for the year
ended December 31, 2015.
Servicing criterion 1122(d)(1)(v) is applicable to the activities the Company performs with respect to
the Platform for all transactions in the Platform, including those issued on or before November 23,
2015 for which compliance was previously assessed under other servicing criteria in accordance with
the SEC Division of Corporation Finance's Manual of Publicly Available Interpretations on Regulation
AB and Related Rules, Interpretation 11.03, as applicable, as of and for the year ended December 31,
2015; provided further that, Management has determined that servicing criterion 1122(d)(1)(v) is
applicable only to the activities the Company performs related to the mathematically accurate
aggregation of information received from servicers and the accurate conveyance of such information
within reports to investors.
Servicing criterion 1122(d)(4)(iii) is applicable to the activities the Company performs with respect to
the Platform only as it relates to the Company's obligation to report additions, removals or
substitutions on reports to investors in accordance with the transaction agreements.
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Management is responsible for the Company's compliance with the servicing criteria. 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 the attestation standards of the Public Company
Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis,
evidence about the Company's compliance with the servicing criteria specified above and performing such
other procedures as we considered necessary in the circumstances. Our examination included testing
selected asset-backed transactions and securities that comprise the Platform, testing selected servicing
activities related to the Platform, and determining whether the Company processed those selected
transactions and performed those selected activities in compliance with the servicing criteria. Furthermore,
our procedures were limited to the selected transactions and servicing activities performed by the Company
during the period covered by this report. Our procedures were not designed to determine whether errors
may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts
calculated or reported by the Company during the period covered by this report for the selected
transactions or any other transactions. 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 the
servicing criteria.
In our opinion, management's assertion that the Company complied with the aforementioned servicing
criteria, as of and for the year ended December 31, 2015, is fairly stated, in all material respects.
/s/KPMG LLP
Chicago, Illinois
February 26, 2016