[LETTERHEAD OF ZC STERLING]





          REPORT ON ASSESSMENT OF COMPLIANCE WITH SECURITIES AND EXCHANGE
                   COMMISSION'S REGULATION AB SERVICING CRITERIA

For the  calendar  year  ending  December  31,  2006,  or portion  thereof  (the
"Period"), ZC Sterling Insurance Agency, Inc. ("ZCSIA") has been a subcontractor
for Servicers identified in Appendix A.

The undersigned are Senior Vice Presidents of ZCSIA,  have sufficient  authority
to make the  statements  contained in this  Assertion  and are  responsible  for
assessing  compliance with the servicing criteria applicable to ZCSIA. ZCSIA has
used the  servicing  criteria  communicated  to ZCSIA by the  Servicer to assess
compliance  with  the  applicable  servicing  criteria.  Accordingly,  servicing
criteria 1122 (d) 1(iv), 1122 (d) 2(vi),  1122 (d) 4(xi),  1122 (d) 4(xii),  and
1122 (d)  4(xiii)  are  applicable  to the  activities  performed  by ZCSIA with
respect  to the  Platforms  covered  by this  report.  The  remaining  servicing
criteria set forth in Item 1122 (d) of the Securities and Exchange  Commission's
Regulation  AB are not  applicable  to the  activities  performed  by ZCSIA with
respect to the Platform covered by this report. As a subcontractor for Servicer,
ZCSIA  has  determined  that it  complied  in all  material  respects  with  the
servicing  criteria listed below.  ZCSIA engaged Ernst & Young,  LLP ("E&Y"),  a
registered  public  accounting firm, to review ZCSIA's  assessment,  and E&Y has
issued an  attestation  report on  ZCSIA's  assessment  of  compliance  with the
applicable servicing criteria for the Period.

1. ZCSIA  maintained a fidelity bond and errors & omissions  policy in effect on
ZCSIA throughout the reporting period in the amount of coverage  required by the
transaction agreements between the Servicer and ZCSIA (1122(d)((1)(iv)).

2. To the extent  that  ZCSIA  prints  checks  for  Servicer  or  otherwise  has
Servicer's  checks or check  stock,  unissued  checks are  safeguarded  so as to
prevent  unauthorized  access  (1122(d)(2)(vi)).  [AS OF DECEMBER 31, 2006, THIS
PROVISION WILL APPLY ONLY FOR THE FOLLOWING SERVICERS:  ABN Amro Mortgage Group,
Inc, Option One Mortgage Corporation,  Sun Trust Mortgage, Inc., HomEq Servicing
Corporation, Wachovia Insurance Corporation, Wells Fargo Home Mortgage.

3. Payments made on behalf of Servicer's obligor for insurance premiums 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 thirty (30) calendar days prior to these
dates,  or such other  number of days  specified in the  transaction  agreements
between Servicer and ZCSIA (1122(d)(4)(xi)).

4. Any late payment penalties in connection with any payment for insurance to be
made on behalf of  Servicer's  obligor  are paid  from the  Servicer's  funds or
ZCSIA's funds and not charged to Servicer's obligor, unless the late payment was
due to the obligor's error or omission (1122(d)(4)(xii)).

5. File(s) provided to Servicer from which Servicer may make  disbursements made
on behalf of  Servicer's  obligor are  provided  to Servicer on an accurate  and
timely  basis and the  information  thereon is subject to such  controls  as are
specified   in  the   transaction   agreements   between   Servicer   and  ZCSIA
(1122(d)(4)(xiii)).


Sincerely,
ZC STERLING INSURANCE AGENCY, INC.

By:     /s/ Arthur J. Castner
        Arthur J. Castner

Title:  Senior Vice President - Hazard Operations

Date:   February 20, 2007

By:     /s/ James P. Novak
   --------------------------
        James P. Novak
Title:  Senior Vice President & General Counsel
Date:   February 20, 2007












APPENDIX A
The  following  is a list of  Clients  serviced  on the ZC  Sterling  Integrated
Product Solution (ZIPS) Platform:

    1.  ABN Amro Mortgage Group,  Inc. 2.  Dovenmuehle  Mortgage,  Inc. 3. HomEq
        Servicing  Corporation  4. Option One Mortgage  Corporation  5. People's
        Choice Home Loan, Inc. 6. Sun Trust Mortgage, Inc.
    7.  Wachovia  Insurance  Agency  (and  its  affiliates,  including  Wachovia
        Mortgage Corporation)
    8.  Wells Fargo Home Mortgage