Much has been written regarding Item 1122 of Regulation AB, however, an element of uncertainty still exists regarding the terms "assessment, assertion, and attestation". Discussed below are these terms and their overall relevance regarding Item 1122. In short, it is the servicer's responsibility to conduct an assessment and assert on that assessment, while it is the CPA firm's responsibility to conduct an attest engagement on the servicer's assertion. Thus;
The term assessment is referring to servicers or any party participating in the servicing function and that they have performed an assessment of compliance applicable to Regulation AB Item 1122 servicing criteria.
The term assertion implies that servicers or any party participating in the servicing function has conducted an assessment applicable to Item 1122 servicing criteria and has now made an assertion on that very assessment.
The term attestation is referring to the report that evaluates the servicer's assertion that was made regarding the servicers assessment of compliance with Regulation AB Item 1122 servicing criteria. This attestation function is conducted by a PCAOB CPA firm only.