REPORT ON ASSESSMENT OF COMPLIANCE WITH REGULATION AB SERVICING CRITERIA


       1.  Pursuant to Subpart  229.1100 - Asset  Backed  Securities,  17 C.F.R.
           ss.ss.229.1100-  229.1123  ("Regulation  AB"), Regulus Group LLC, for
           itself   and  its   wholly-owned   subsidiaries   (individually   and
           collectively "Regulus"),  is responsible for assessing its compliance
           with the servicing criteria  applicable to the remittance  processing
           services it provides to  customers  who are issuers or  servicers  of
           asset  backed   securities   transactions   and  who  have  requested
           confirmation  of Regulus'  compliance in connection  with loan and/or
           receivables  portfolios  that  include  pool assets for asset  backed
           securities transactions (the "Platform").  Remittance processing is a
           service  whereby  check  payments that are remitted by mail to a post
           office box are collected,  processed  through a highly automated data
           capture  system,  and  prepared for deposit to a bank account held by
           the beneficiary of the payment.

       2.  The  servicing  criteria set forth in Item 1122(d) of  Regulation  AB
           were used in Regulus' assessment of compliance. Regulus has concluded
           that the  servicing  criteria  set forth in Items  1122(d)(2)(i)  and
           1122(d)(4)(iv)  of  Regulation  AB are  applicable  to the  servicing
           activities  it performs with respect to the Platform  (such  criteria
           the "Applicable Servicing Criteria").  Regulus has concluded that the
           remainder  of the  servicing  criteria  set forth in Item  1122(d) of
           Regulation  AB are  inapplicable  to the  activities it performs with
           respect the  Platform  because  Regulus does not  participate  in the
           servicing activities referenced by such servicing criteria.

       3.  As of and for the year ending December 31, 2006, Regulus has complied
           in all material respects with the Applicable  Servicing  Criteria set
           forth in Item 1122(d) of Regulation AB.

       4.  KPMG  LLP,  a  registered  public  accounting  firm,  has  issued  an
           attestation  report on Regulus'  assessment  of  compliance  with the
           Applicable  Servicing Criteria as of and for the year ending December
           31, 2006.  A copy of that  attestation  report is attached  hereto as
           Exhibit A.



       /s/ Kimberlee Clark
       Kimberlee Clark
       Chief Financial Officer

       February 22, 2007


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                                    EXHIBIT A


                            [LETTERHEAD OF KPMG LLP]



             Report of Independent Registered Public Accounting Firm


The Board of Members
Regulus Group LLC:

We have examined management's assessment for those customers that management has
informed  us  have  requested  confirmation  of  compliance,   included  in  the
accompanying  Report on Assessment of  Compliance  with  Regulation AB Servicing
Criteria,  that Regulus Group LLC complied with the servicing criteria set forth
in  Item  1122(d)(2)(i)  and  1122(d)(4)(iv)  of  the  Securities  and  Exchange
Commission's  Regulation AB for remittance  processing services to those issuers
of asset backed  securities  transactions  (the Platform) as of and for the year
ended December 31, 2006.  Regulus Group LLC has determined that the remainder of
the servicing  criteria are not  applicable  to the  activities it performs with
respect  to the  Platform  as of and for  the  year  ended  December  31,  2006.
Management is  responsible  for the Company's  compliance  with those  servicing
criteria. Our responsibility is to express an opinion on management's assessment
about the Company's compliance based on our examination.

Our  examination  was conducted in  accordance  with the standards of the Public
Company Accounting  Oversight Board (United States) and,  accordingly,  included
examining,  on a test basis,  evidence about the Company's  compliance  with the
servicing  criteria  specified above and performing such other  procedures as we
considered  necessary in the circumstances.  Our examination included testing of
less than all of the individual  asset-backed  transactions  and securities that
comprise  the  Platform,  testing of less than all of the  servicing  activities
related to the Platform,  and  determining  whether the Company  processed those
selected transactions and performed those selected activities in compliance with
the servicing criteria. Furthermore, our procedures were limited to the selected
transactions and servicing activities performed by the Company during the period
covered by this report.  Our procedures  were not designed to determine  whether
errors may have  occurred  either prior to or  subsequent  to our tests that may
have  affected  the  balances or amounts  calculated  or reported by the Company
during the period  covered by this report for the selected  transactions  or any
other transactions.  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 the servicing criteria.

In our  opinion,  management's  assessment  that the Company  complied  with the
aforementioned servicing criteria as of and for the year ended December 31, 2006
is fairly stated, in all material respects.


/s/ KPMG LLP

Philadelphia, PA
February 22, 2007