EX-33.2
Report on Assessment of Compliance with SEC Regulation AB
Servicing Criteria as Primary Servicer


Berkadia Commercial Mortgage LLC ("Berkadia") is responsible for assessing
compliance, as of and for the year ended December 31, 2012 (the "Reporting
Period"), with the Servicing Criteria set forth in Item 1122(d) of Regulation
AB of the Securities and Exchange Commission for asset-backed securities
transactions. This assertion includes all commercial mortgage loans sold in
public securitizations from the period January 1, 2006 through December 31,
2012 for which Berkadia served as primary servicer (the "Platform").

Berkadia has concluded that the criteria are applicable as shown below
(indicated by x) to the primary servicing of the loans in the Platform:

Regulation AB Criteria 1122(d)                                    Primary
(1) General servicing considerations.

(i) Policies and procedures are instituted to monitor any            X
performance or other triggers and events of default in
accordance with the transaction agreements.

(ii) If any material servicing activities are outsourced             X
to third parties, policies and procedures are instituted
to monitor the third party's performance and compliance
with such servicing activities.

(iii) Any requirements in the transaction agreements to         Not Applicable
maintain a back-up servicer for the pool assets are
maintained.

(iv) A fidelity bond and errors and omissions policy is              X
in effect on the party participating in the servicing
function throughout the reporting period in the amount of
coverage required by and otherwise in accordance with
the terms of the transaction agreements.

(2) Cash collection and administration.

(i) Payments on pool assets are deposited into the                   X
custodial bank accounts and related bank clearing
accounts no more than two business days of receipt, or
such other number of days specified in the transaction
agreements.

(ii) Disbursements made via wire transfer on behalf of an            X
obligor or to an investor are made only by authorized
personnel.

(iii) Advances of funds or guarantees regarding                      X
collections, cash flows or distributions, and any
interest or other fees charged for such advances, are
made, reviewed and approved as specified in the
transaction agreements.

(iv) The related accounts for the transaction, such as               X
cash reserve accounts or accounts established as a form
of overcollateralization, are separately maintained
(e.g., with respect to commingling of cash) as set forth
in the transaction agreements.

(v) Each custodial account is maintained at a federally              X
insured depository institution as set forth in the
transaction agreements. For purposes of this criterion,
"federally insured depository institution" with respect
to a foreign financial institution means a foreign
financial institution that meets the requirements of
Section 240.13k-1(b)(1) of this chapter.

(vi) Unissued checks are safeguarded so as to prevent                X
unauthorized access.

(vii) Reconciliations are prepared on a monthly basis for
all asset-backed securities related bank accounts,
including custodial accounts and related bank clearing
accounts. These reconciliations:
(A) Are mathematically accurate;                                     X
(B) Are prepared within 30 calendar days after the bank              X
statement cutoff date, or such other number of days
specified in the transaction agreements;

(page)

Regulation AB Criteria 1122(d)                                    Primary
(C) Are reviewed and approved by someone other than the              X
person who prepared the reconciliation; and
(D) Contain explanations for reconciling items. These                X
reconciling items are resolved within 90 calendar days of
their original identification, or such other number of
days specified in the transaction agreements.

(3) Investor remittances and reporting.

(i) Reports to investors, including those to be filed
with the Commission, are maintained in accordance with
the transaction agreements and applicable Commission
requirements. Specifically, such reports:
(A) Are prepared in accordance with timeframes and other             X
terms set forth in the transaction agreements;
(B) Provide information calculated in accordance with the            X
terms specified in the transaction agreements;
(C) Are filed with the Commission as required by its            Not Applicable
rules and regulations; and
(D) Agree with investors' or the trustee's records as to             X
the total unpaid principal balance and number of pool
assets serviced by the servicer.

(ii) Amounts due to investors are allocated and remitted             X
in accordance with timeframes, distribution priority and
other terms set forth in the transaction agreements.

(iii) Disbursements made to an investor are posted within            X
two business days to the servicer's investor records, or
such other number of days specified in the transaction
agreements.

(iv) Amounts remitted to investors per the investor                  X
reports agree with cancelled checks, or other form
of payment, or custodial bank statements.

(4) Pool asset administration.

(i) Collateral or security on pool assets is maintained              X
as required by the transaction agreements or related pool
asset documents.

(ii) Pool assets and related documents are safeguarded as       Not Applicable
required by the transaction agreements.

(iii) Any additions, removals or substitutions to the                X
asset pool are made, reviewed and approved in accordance
with any conditions or requirements in the transaction
agreements.

(iv) Payments on pool assets, including any payoffs, made            X
in accordance with the related pool asset documents are
posted to the applicable servicer's obligor records
maintained no more than two business days after receipt,
or such other number of days specified in the transaction
agreements, and allocated to principal, interest or other
items (e.g., escrow) in accordance with the related pool
asset documents.

(v) The servicer's records regarding the pool assets                 X
agree with the servicer's records with respect to an
obligor's unpaid principal balance.

(vi) Changes with respect to the terms or status of an               X
obligor's pool asset (e.g., loan modifications or
re-agings) are made, reviewed and approved by authorized
personnel in accordance with the transaction agreements
and related pool asset documents.

(vii) Loss mitigation or recovery actions (e.g.,                Not Applicable
forbearance plans, modifications and deeds in lieu of
foreclosure, foreclosures and repossessions, as
applicable) are initiated, conducted and concluded in
accordance with the timeframes or other requirements
established by the transaction agreements.

(page)

Regulation AB Criteria 1122(d)                                    Primary
(viii) Records documenting collection efforts are                    X
maintained during the, period a pool asset is delinquent
in accordance with the transaction agreements. Such
records are maintained on at least a monthly basis, or
such other period specified in the transaction
agreements, and describe the entity's activities in
monitoring delinquent pool assets including, for example,
phone calls, letters and payment rescheduling plans in
cases where delinquency is deemed temporary (e.g.,
illness or unemployment).

(ix) Adjustments to interest rates or rates of return for            X
pool assets with variable rates are computed based on
the related pool asset documents.

(x) Regarding any funds held in trust for an obligor
(such as escrow accounts):
(A) Such funds are analyzed, in accordance with the                  X
obligor's pool asset documents, on at least an annual
basis, or such other period specified in the transaction
agreements;
(B) Interest on such funds is paid, or credited, to                  X
obligors in accordance with applicable pool asset
documents and state laws; and
(C) Such funds are returned to the obligor within 30                 X
calendar days of full repayment of the related pool
asset, or such other number of days specified in the
transaction agreements.

(xi) Payments made on behalf of an obligor (such as tax              X
or insurance payments) are made on or before the related
penalty or expiration dates, as indicated on the
appropriate bills or notices for such payments, provided
that such support has been received by the servicer at
least 30 calendar days prior to these dates, or such
other number of days specified in the transaction
agreements.

(xii) Any late payment penalties in connection with any              X
payment to be made on behalf of an obligor are paid from
the servicer's funds and not charged to the obligor,
unless the late payment was due to the obligor's error
or omission.

(xiii) Disbursements made on behalf of an obligor are                X
posted within two business days to the obligor's records
maintained by the servicer, or such other number of days
specified in the transaction agreements.

(xiv) Delinquencies, charge-offs and uncollectible                   X
accounts are recognized and recorded in accordance with
the transaction agreements.

(xv) Any external enhancement or other support,                 Not Applicable
identified in Item 1114(a) (1) through (3) or Item 1115
of this Regulation AB, is maintained as set forth in the
transaction agreements.

(page)

The Servicing Criteria, after giving effect to the foregoing exclusions, are
referred to as the "Applicable Servicing Criteria".

The Company utilizes vendors to support its servicing operations, including the
use of a commercial tax service which supports our assertions under
1122(d)(4)(xi) through (xiii) and the use of a lien filing firm to support our
assertion under 1122(d)(4)(i). This vendor activity contributes to the
servicing activities to which we are asserting. In all cases, the vendors'
activities are limited, and the Company assumes responsibility for the 1122
assessment for these vendor activities. These vendors do not fit the definition
of servicer under Item 1101(j), and the Company employs policies and procedures
designed to provide assurance that the vendors' activities comply with the
Applicable Servicing Criteria to such vendors.

For the Reporting Period, Berkadia has assessed its compliance with the
Applicable Servicing Criteria for the transactions and has concluded that its
servicing operation has complied, in all material respects, with the Applicable
Servicing Criteria.

Grant Thornton LLP, an independent registered public accounting firm, has
issued an attestation report on management's assertion of compliance with the
Applicable Servicing Criteria.


Berkadia Commercial Mortgage LLC

February 28,2013

/s/ Mark E. McCool
Mark E. McCool
Executive Vice President
Head of Servicing
Berkadia Commercial Mortgage LLC