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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 forwhich the Groupis the
    
    Performed byReference
    
    Criteria
    
    Responsible Party
    
    the GroupGeneral 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
    
    Not applicable1122(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
    
    Not applicable1122(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
    
    Not applicable
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Servicing Criteria
    
    Applicable Servicing CriteriaPerformed bythe Vendor forwhich the Groupis the
    
    Performed byReference
    
    Criteria
    
    Responsible Party
    
    the Group1122(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 forwhich the Groupis the
    
    Performed byReference
    
    Criteria
    
    Responsible Party
    
    the Group1122(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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