Exhibit 33.9

Management’s Assessment of Compliance with Applicable Servicing Criteria

Pursuant to Item 1122(d) of Regulation AB

Management of Walker & Dunlop, LLC (the Company) is responsible for assessing compliance with the applicable servicing criteria set forth in Items 1122(d)(1)(i), 1122(d)(1)(ii) and 1122(d)(1)(v) of Regulation AB of the Securities and Exchange Commission relating to the servicing of asset backed securities transactions conducted by the Company (the Platform) as of and for the year ended December 31, 2016. Appendix A identifies the individual asset-backed transactions and securities defined by management as constituting the Platform.

The Company’s management has assessed the Company’s compliance with the applicable servicing criteria as of and for the year ended December 31, 2016. In making this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation AB. Based on such assessment, management believes that, as of and for the year ended December 31, 2016, the Company has complied in all material respects with the servicing criteria set forth in Items 1122(d)(1)(i), 1122(d)(1)(ii) and 1122(d)(1)(v) of Regulation AB of the Securities and Exchange Commission relating to the servicing of the Platform.

KPMG LLP, an independent registered public accounting firm, has issued an attestation report with respect to management’s assessment of compliance with the applicable servicing criteria as of and for the year ended December 31, 2016.

February 27, 2017

James Schroeder

Senior Vice President — Servicing

Apendix A to Management Assertion

Apendix A to Management Assertion