Exhibit
      33 a)




RESTATED
        REPORT ON ASSESSMENT OF COMPLIANCE WITH


§1122(d)(2)(vi),
        §1122(d)(4)(xi) and §1122(d)(4)(xii)


of
        REGULATION AB SERVICING CRITERIA


FOR
        THE
        REPORTING PERIOD


JANUARY
        1, 2006 TO DECEMBER 31, 2006




American
        Security Insurance Company, Standard Guaranty Insurance Company and TrackSure
        Insurance Agency, Inc. (formerly, “Safeco Financial Institution Solutions,
        Inc.”) (collectively, the “Asserting Party”) is responsible for assessing
        compliance as of December 31, 2006 and for the period of January 1, 2006
        through
        December 31, 2006 (the “Reporting Period”) with the servicing criteria set forth
        in §1122(d)(2)(vi), §1122(d)(4)(xi) and §1122(d)(4)(xii) of Title 17,
§229.1122(d) of the Code of Federal Regulations, (the “Applicable Servicing
        Criteria”) which the Asserting Party has concluded are applicable to the
        insurance escrow servicing activities it performs with respect to all mortgage
        loan-tracking transactions for such asset-backed securities transactions
        that
        were registered after January 1, 2006 with the Securities and Exchange
        Commission pursuant to the Securities Act of 1933 (the “Platform
        Transactions”).




The
        Asserting Party previously excluded the applicable servicing criteria set
        forth
        in §1122(d)(4)(xii) from the scope of its assessment of compliance. The
        Asserting Party has now assessed its compliance with the Applicable Servicing
        Criteria for the Reporting Period and has identified a material instance
        of
        noncompliance with that servicing criterion. Specifically, the Asserting
        Party
        did not have, during the Reporting Period, sufficient policies and procedures
        to
        capture the information with respect to the Platform Transactions necessary
        to
        determine compliance with §1122(d)(4)(xii). Accordingly, the Asserting Party has
        restated its previous assessment for the Reporting Period, which excluded
        evaluation of the criterion, to include the criterion and reflect the material
        noncompliance as a result of its assessment.




The
        Asserting Party has concluded that, with the exception of the aforementioned
        material noncompliance, the Asserting Party has complied, in all material
        respects, with the Applicable Servicing Criteria for the Reporting Period
        with
        respect to the Platform Transactions taken as a whole. The Asserting Party
        used
        the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to
        assess
        the compliance with the Applicable Servicing Criteria.




PricewaterhouseCoopers
        LLP, an independent registered public accounting firm, has issued an attestation
        report on the assessment of compliance with the Applicable Servicing Criteria
        as
        of and for the Reporting Period ending December 31, 2006.




American
      Security Insurance Company


Standard
      Guaranty Insurance Company


TrackSure
        Insurance Agency, Inc.


(formerly,
        “Safeco Financial Institution Solutions, Inc.”)




/s/
      John
      Frobose




By:
        John
        Frobose


Senior
        Vice President




Date:
        February 23, 2007, except for the Asserting Party’s restatement described above
        regarding the assessment of the servicing criteria set forth in 1122(d)(4)(xii)
        which was previously excluded from the scope of its assessment of compliance
        with applicable servicing criteria, as to which the date is January 30,
        2008.









ASSURANT
                Specialty
                Property
              260
                  Interstate North Circle, SE
                Atlanta,
                  GA 30339-2210
                T
                  770.763.1000
                F
                  770.859.4403
                www.assurant.com







July
        25,
        2007




Sharon
        Maerkle


Home
        Loan
        Services


150
        Alleghany Center Mall


Pittsburgh,
        PA 15212




Re:
        SEC
        Inquiry of Assurant Regulation AB Section 1122(d)(4)(xii)




Ms.
        Maerkle,




We
        are
        providing this letter in response to the question that you received from
        the SEC
        regarding Assurant’s exclusion of Section 1122(d)(4)(xii) from our 2006
        Regulation AB Report on Assessment of Compliance with Regulation AB
        (“Assessment”).




In
        our
        Assessment, we asserted that as your chosen provider of insurance tracking
        and
        monitoring services, we are the company that is responsible for following
        the
        procedures that you have defined and incorporated as part of our Outsourcing
        Agreement; which include making insurance disbursements for you on behalf
        of
        your borrowers which servicing function is described in Section 1122(d)(4)(xi).
        Our responsibilities under the Outsourcing Agreement do not include monitoring
        whether any late payment was paid on behalf of a borrower [obligor] or whether
        any such late payment was due to the borrower’s error or omission as required by
        Section 1122(d)(4)(xii). Accordingly, in our Assessment we excluded the criteria
        set forth in Section 1122(d)(4)(xii) from those servicing criteria applicable
        to
        the activities performed by us with respect to the servicing
        platform.




PricewaterhouseCoopers
        excluded the same criteria from its attestation report because it was not
        included in our Assessment.




Should
        you have any additional questions, please do not hesitate to contact your
        Account Executive or me.







Best
        Regards,




/s/
        John
        Frobose


John
        Frobose


Senior
      Vice President


Product
        Line Executive