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Exhibit 34.1
 [KPMG Audit plc Letterhead]
 Report of Independent Registered Public Accounting Firm
 
     
  
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Servicing Criteria
    
    Applicable Servicing CriteriaPerformed bythe Vendor for
    
    Performedwhich the
    
    directly orCompany is the
    
    indirectly byReference
    
    Criteria
    
    Responsible Party
    
    the CompanyGeneral Servicing Considerations1122(d)(1)(i)
    
    Policies and procedures are instituted to monitor any performance or
other triggers and events of default in accordance with the transaction
agreements.
    
    Not applicable
    
    ü1122(d)(1)(ii)
    
    If any material servicing activities are outsourced to third
parties, policies and procedures are instituted to monitor the third
partys performance and compliance with such servicing activities.
    
    Not applicable
    
    ü1122(d)(1)(iii)
    
    Any requirements in the transaction agreements to maintain a back-up
servicer for the pool assets are maintained.
    
    Not applicable
    
    ü1122(d)(1)(iv)
    
    A fidelity bond and errors and omissions policy is 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.
    
    Not applicable
    
    Not applicableCash Collection and Administration1122(d)(2)(i)
    
    Payments on pool assets are deposited into the appropriate 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.
    
    ü
    
    ü1122(d)(2)(ii)
    
    Disbursements made via wire transfer on behalf of an obligor or to
an investor are made only by authorized personnel.
    
    Not applicable
    
    ü1122(d)(2)(iii)
    
    Advances of funds or guarantees regarding 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.
    
    Not applicable
    
    Not applicable1122(d)(2)(iv)
    
    The related accounts for the transaction, such as 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.
    
    Not applicable
    
    ü1122(d)(2)(v)
    
    Each custodial account is maintained at a federally 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 Rule 13k-1(b)(1)
under the Securities Exchange Act of 1934, as amended.
    
    Not applicable
    
    ü1122(d)(2)(vi)
    
    Unissued checks are safeguarded so as to prevent unauthorized access.
    
    Not applicable
    
    ü
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Servicing Criteria
    
    Applicable Servicing CriteriaPerformed bythe Vendor for
    
    Performedwhich the
    
    directly orCompany is the
    
    indirectly byReference
    
    Criteria
    
    Responsible Party
    
    the Company1122(d)(2)(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; (B) are prepared within 30 calendar days after
the bank statement cutoff date, or such other number of days specified
in the transaction agreements; (C) are reviewed and approved by someone
other than the person who prepared the reconciliation; and (D) contain
explanations for reconciling items. These reconciling items are resolved
within 90 calendar days of their original identification, or such other
number of days specified in the transaction agreements.
    
    Not applicable
    
    üInvestor Remittances and Reporting1122(d)(3)(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 terms set forth in
the transaction agreements; (B) provide information calculated in
accordance with the terms specified in the transaction agreements; (C)
are filed with the Commission as required by its rules and regulations;
and (D) agree with investors or the trustees records as to the total
unpaid principal balance and number of pool assets serviced by the
servicer.
    
    Not applicable
    
    ü1122(d)(3)(ii)
    
    Amounts due to investors are allocated and remitted in accordance
with timeframes, distribution priority and other terms set forth in the
transaction agreements.
    
    Not applicable
    
    ü1122(d)(3)(iii)
    
    Disbursements made to an investor are posted within two business
days to the servicers investor records, or such other number of days
specified in the transaction agreements.
    
    Not applicable
    
    ü1122(d)(3)(iv)
    
    Amounts remitted to investors per the investor reports agree with
cancelled checks, or other form of payment, or custodial bank
statements.
    
    Not applicable
    
    üPool Asset Administration1122(d)(4)(i)
    
    Collateral or security on pool assets is maintained as required by
the transaction agreements or related pool asset documents.
    
    Not applicable
    
    ü1122(d)(4)(ii)
    
    Pool assets and related documents are safeguarded as required by the
transaction agreements.
    
    Not applicable
    
    ü1122(d)(4)(iii)
    
    Any additions, removals or substitutions to the asset pool are made,
reviewed and approved in accordance with any conditions or requirements
in the transaction agreements.
    
    Not applicable
    
    ü1122(d)(4)(iv)
    
    Payments on pool assets, including any payoffs, made in accordance
with the related pool asset documents are posted to the 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.
    
    ü
    
    ü1122(d)(4)(v)
    
    The servicers records regarding the pool assets agree with the
servicers records with respect to an obligors unpaid principal
balance.
    
    Not applicable
    
    ü1122(d)(4)(vi)
    
    Changes with respect to the terms or status of an 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.
    
    Not applicable
    
    ü
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Servicing Criteria
    
    Applicable Servicing CriteriaPerformed bythe Vendor for
    
    Performedwhich the
    
    directly orCompany is the
    
    indirectly byReference
    
    Criteria
    
    Responsible Party
    
    the Company1122(d)(4)(vii)
    
    Loss mitigation or recovery actions (e.g., 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.
    
    Not applicable
    
    ü1122(d)(4)(viii)
    
    Records documenting collection efforts are 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 home equity loans
including, for example, phone calls, letters and payment rescheduling
plans in cases where delinquency is deemed temporary (e.g., illness or
unemployment).
    
    Not applicable
    
    ü1122(d)(4)(ix)
    
    Adjustments to interest rates or rates of return for pool assets
with variable rates are computed based on the related pool asset
documents.
    
    Not applicable
    
    ü1122(d)(4)(x)
    
    Regarding any funds held in trust for an obligor (such as escrow
accounts): (A) such funds are analyzed, in accordance with the 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 obligors in accordance with applicable pool asset
documents and state laws; and (C) such funds are returned to the obligor
within 30 calendar days of full repayment of the related pool asset, or
such other number of days specified in the transaction agreements.
    
    Not applicable
    
    Not applicable1122(d)(4)(xi)
    
    Payments made on behalf of an obligor (such as tax 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.
    
    Not applicable
    
    Not applicable1122(d)(4)(xii)
    
    Any late payment penalties in connection with any 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.
    
    Not applicable
    
    Not applicable1122(d)(4)(xiii)
    
    Disbursements made on behalf of an obligor are 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.
    
    Not applicable
    
    Not applicable1122(d)(4)(xiv)
    
    Delinquencies, charge-offs and uncollectible accounts are recognized
and recorded in accordance with the transaction agreements.
    
    Not applicable
    
    ü1122(d)(4)(xv)
    
    Any external enhancement or other support, identified in Item
1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as
set forth in the transaction agreements.
    
    Not applicable
    
    ü
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