DELOITTE

                       Deloitte & Touche LLP
                       First National Tower            Wells Fargo Center
                       1601 Dodge Street, Ste. 3100    1248 O Street, Ste 716
                       Omaha, NE 68102-9706            Lincoln, NE 68508-1424

                         Tel: +1 402 346 7788            Tel: +1 402 474 1776
                         Fax: +1 402 342 1820            Fax: +1 402 474 0365
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REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors
Commercial Federal Bank
Omaha, Nebraska

We have examined management's assertion that Commercial Federal Bank (the
"Company") has complied as of July 15, 2005 and for the period from
January 1, 2005 to July 15, 2005, with its established minimum servicing
standards described in the accompanying Management's Assertion dated November
21, 2005. Management is responsible for the Company's compliance with those
minimum servicing standards. Our responsibility is to express an opinion on
management's assertion about the Company's compliance based on our
examination.

Our examination was conducted in accordance with attestation standards
established by the American Institute of Certified Public Accountants as
adopted by the Public Company Accounting Oversight Board and accordingly,
included examining, on a test basis, evidence about the Company's compliance
with its minimum servicing standards and performing such other procedures as
we considered necessary in the circumstances. We believe that our examination
provides a reasonable basis for our opinion. Our examination does not provide
a legal determination on the Company's compliance with its minimum servicing
standards.

In our opinion, management's assertion that the Company complied with the
aforementioned minimum servicing standards as of July 15, 2005 and for the
period from January 1, 2005 to July 15, 2005, is fairly stated in all
material respects based on the criteria set forth in Appendix I.


/s/ Deloitte & Touche
---------------------
Deloitte & Touche

November 21, 2005




                                                    Member of
                                                    Deloitte Touche Tohmatsu







COMMERCIAL
FEDERAL BANK



Management's Assertion

November 21, 2005

As of July 15, 2005 and for the period from January 1, 2005 to July 15, 2005,
Commercial Federal Bank (the "Company") has complied, in all material
respects, with the Company's established minimum servicing standards for
residential mortgage loans as set forth in Appendix I (the "Standards"). The
Standards are based on the Mortgage Banker's Association of America's
Uniform Single Attestation Program for Mortgage Bankers. As of July 15, 2005
and for the period from January I, 2005 to July 15, 2005, the Company had in
effect a fidelity bond and errors and omissions policy in the amount of
$20,000,000.


/S/ Caren Cantrell
-------------------
Caren Cantrell,
Senior Vice President, Mortgage Operations
November 21, 2005

David Fisher
Executive Vice President and Chief Financial Officer
November 21, 2005


Corporate Headquarters
P.O. Box 1103
13220 California Street
Omaha, Nebraska 68154

























Appendix 1
MINIMUM SERVICING STANDARDS AS SET FORTH IN THE MORTGAGE BANKERS
ASSOCIATION OF AMERICA'S UNIFORM SINGLE ATTESTATION PROGRAM FOR
MORTGAGE BANKERS


I.  Custodial Bank Accounts

    1.  Reconciliations shall be prepared on a monthly basis for all
        custodial bank accounts and related bank clearing accounts. These
        reconciliations shall:

        o   be mathematically accurate;

        o   be prepared within forty-five (45) calendar days after the cutoff
            date;

        o   be reviewed and approved by someone other than the person who
            prepared the reconciliation; and

        o   document explanations for reconciling items. These reconciling
            items shall be resolved within ninety (90) calendar days of their
            original identification.

    2.  Funds of the servicing entity shall be advanced in cases where there
        is an overdraft in an investor's or a mortgagor's account.

    3.  Each custodial account shall be maintained at a federally insured
        depository institution in trust for the applicable investor.

    4.  Escrow funds held in trust for a mortgagor shall be returned to the
        mortgagor within thirty (30) calendar days of payoff of the mortgage
        loan.

II. Mortgage Payments

    1.  Mortgage payments shall be deposited into the custodial bank accounts
        and related bank clearing accounts within two business days of
        receipt.

    2.  Mortgage payments made in accordance with the mortgagor's loan
        documents shall be posted to the applicable mortgagor records within
        two business days of receipt.

    3.  Mortgage payments shall be allocated to principal, interest,
        insurance, taxes or other escrow items in accordance with the
        mortgagor's loan documents.

    4.  Mortgage payments identified as loan payoffs shall be allocated in
        accordance with the mortgagor's loan documents.

III.Disbursements

    1.  Disbursements made via wire transfer on behalf of a mortgagor or
        investor shall be made only by authorized personnel.

    2.  Disbursements made on behalf of a mortgagor or investor shall be
        posted within two business days to the mortgagor's or investor's
        records maintained by the servicing entity.

    3.  Tax and insurance payments shall be made on or before the penalty or
        insurance policy expiration dates, as indicated on tax bills and
        insurance premium notices, respectively, provided that such support
        has been received by the servicing entity at least thirty (30)
        calendar days prior to these dates.

    4.  Any late payment penalties paid in conjunction with the payment of
        any tax bill or insurance premium notice shall be paid from the
        servicing entity's funds and not charged to the mortgagor, unless the
        late payment was due to the mortgagor's error or omission.

    5.  Amounts remitted to investors per the servicer's investor reports
        shall agree with cancelled checks, or other form of payment, or
        custodial bank statements.

    6.  Unused checks shall be safeguarded so as to prevent unauthorized
        access.

IV. Investor Accounting and Reporting

    1.  The servicing entity's investor reports shall agree with, or
        reconcile to, investors' records on a monthly basis as to the total
        unpaid principal balance and number of loans serviced by the
        servicing entity.

V.  Mortgagor Loan Accounting

    1.  The servicing entity's mortgage loan records shall agree with, or
        reconcile to, the records of mortgagors with respect to the unpaid
        principal balance on a monthly basis.

    2.  Adjustments on adjustable rate mortgage loans shall be
        computed based on the related mortgage note and any ARM rider.

    3.  Escrow accounts shall be analyzed, in accordance with the
        mortgagor's loan documents, on at least an annual basis.

    4.  Interest on escrow accounts shall be paid, or credited, to
        mortgagors in accordance with the applicable state laws.

VI. Delinquencies

    1.  Records documenting collection efforts shall be maintained during
        the period a loan is in default and shall be updated at least
        monthly. Such records shall describe the entity's activities in
        monitoring delinquent loans including, for example, phone calls,
        letters and mortgage payment rescheduling plans in cases where the
        delinquency is deemed temporary (i.e., illness or unemployment).

VII.Insurance Policies

    1.  A fidelity bond and errors and omissions policy shall be in effect on
        the servicing entity throughout the reporting period in the amount of
        coverage represented to investors in management's assertion.