Exhibit 33.1

Management’s Assessment

Management of Wells Fargo Commercial Mortgage Servicing (“CMS”), a division of Wells Fargo Bank, National Association, (the “Company”), is responsible for assessing compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission (“SEC”) relating to the servicing of commercial mortgage loans by CMS (the “Platform”), except for servicing criteria 1122(d)(1)(iii), 1122(d)(3)(i)(B-D), 1122(d)(3)(ii-iv) and 1122(d)(4)(xv), 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, 2011. Appendix A to this letter identifies the commercial mortgage pools and other structures involving the commercial mortgage loans constituting the Platform.

With respect to servicing criteria 1122(d)(1)(i), 1122(d)(3)(i)(A), 1122 (d)(4)(i) and 1122(d)(4)(vi), the Company has engaged various vendors to perform certain activities covered by these servicing criteria. The Company has determined that none of these vendors is a “servicer” as defined in Item 1101(j) of Regulation AB, and the Company’s management has elected to take responsibility for assessing compliance with these servicing criteria to the extent they apply to these vendors as permitted by Interpretation 17.06 of the SEC Division of Corporation Finance Manual bf Publicly Available Telephone Interpretations (“Interpretation 17.06”). As permitted by Interpretation 1’7.06, the Company has policies and procedures in place designed to provide reasonable assurance that such vendors’ activities comply in all material respects with servicing criteria 1122(d)(1)(i), 1122(d)(3)(i)(A), 1122 (d)(4)(i) and 1122(d)(4)(vi) to the extent they apply. The Company is solely responsible for determining. that the requirements of Interpretation 17.06 have been satisfied with respect to these vendors and their performance of activities covered by servicing criteria 1122(d)(1)(i), 1122(d)(3)(i)(A), 1122 (d)(4)(i) and 1122(d)(4)(vi).

With respect to applicable servicing criterion 1122(d)(4)(iii), there were no activities performed during the year ended December 31, 2011 with respect to the Platform, because there were no occurrences of events that would require the Company to perform such activities.

The Company’s management has assessed the Company’s compliance with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB with respect to the Platform as of and for the year ended December 31, 2011. 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, the Company’s management believes that as of and for the year ended December 31, 2011, the Company has complied in all material respects with the applicable servicing criteria set forth in Item 1122(d) of Regulation AB with respect to the Platform, except for the following material noncompliance with servicing criterion 1122(d)(4)(i):

With respect to certain commercial mortgage loans, the Company failed to timely file continuation statements for certain Uniform Commercial Code (“UCC”) financing statements as required by the transaction agreements, thereby causing such UCC financing statements to lapse.

As a result of the non-compliance described above, certain non-possessory security interests in certain types of personal property collateral for these loans became unperfected and, as a result, subject to a possible loss of priority.

Remediation

Promptly following the Company’s discovery of such omissions as part of its normal internal compliance review process, the Company filed new UCC financing statements in all cases. In order to reduce the possibility of similar occurrences in the future, the Company has provided enhanced training to the responsible personnel, improved the quality of the relevant computer data feeds and generally tightened its procedures for the filing of continuation statements.

KPMG LLP, an independent registered public accounting firm, has issued an attestation report with respect to the Company’s compliance with the applicable servicing criteria as of and for the year ended December 31, 2011.

March 12, 2012

Appendix A – Commercial Mortgage Pools and Other Structures