Exhibit 33.10

MANAGEMENT’S ASSERTION ON

COMPLIANCE WITH REGULATION AB SERVICING CRITERIA

KeyBank National Association, as successor by merger to KeyCorp Real Estate Capital Markets, Inc. (the “Asserting Party”) is responsible for assessing compliance for the transactions listed on Appendix A for the period January 1, 2016 through December 31, 2016 (the “Reporting Period”), with the servicing criteria set forth in Title 17, Section 229.1122(d) of the Code of Federal Regulations (the “CFR”), except for the servicing criteria which the Asserting Party has concluded are not applicable, as indicated on Appendix B attached hereto (the “Applicable Servicing Criteria”), to the servicing of the transactions listed on Appendix A, backed by commercial real estate mortgage loans and serviced by the Asserting Party. Although the Asserting Party is responsible for assessing compliance with Section 229.1122 (d)(1)(iii) of Regulation AB, there were no servicing activities performed by the Asserting Party during the year ended December 31, 2016 that required this servicing criteria to be complied with.

The Asserting Party has assessed compliance with the Applicable Servicing Criteria for the Reporting Period and has concluded that the Asserting Party has complied, in all material respects, with the applicable servicing criteria for the transactions listed on Appendix A backed by commercial real estate mortgage loans serviced by the Asserting Party.

The Asserting Party has engaged a vendor to perform the activities required by the servicing criteria as set forth in Appendix B. The Asserting Party has determined that this vendor is not considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Asserting Party has elected to take responsibility for assessing compliance with the applicable servicing criteria applicable to the vendor as permitted by C&DI 200.06. As permitted by C&DI 200.06, the Asserting Party has asserted that it has policies and procedures in place designed to provide reasonable assurance that the vendors’ activities comply in all material respects with servicing criteria applicable to the vendor. The Asserting Party is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendor and related criteria.

Ernst & Young LLP, an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the Applicable Servicing Criteria for the Reporting Period as set forth in this assertion.

KeyBank National Association

February 24, 2017

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

KeyBank National Association – Asset Backed Transactions Covered by Platform

For the period of January 1 through December 31, 2016 -Appendix A

Appendix B

Servicing Criteria to Be Addressed In Assessment of Compliance

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