EXHIBIT 33.1



                                                                    EXHIBIT 33.1



                          ASSERTION OF COMPLIANCE WITH
                          APPLICABLE SERVICING CRITERIA



The Bank of New York, The Bank of New York Trust Company, N. A. and The Bank of
New York (Delaware) (collectively, the "Company") provides this platform-level
assessment of compliance with the servicing criteria specified in Item 1122(d)
of Regulation AB promulgated by the Securities and Exchange Commission.

Management has determined that the following servicing criteria are applicable
in regards to the following servicing platform for the following period:

PLATFORM: Publicly-issued (i.e., transaction-level reporting initially required
under the Securities Exchange Act of 1934, as amended) asset-backed securities
issued on or after January 1, 2006 (and like-kind transactions issued prior to
January 1, 2006) for which the Company provides trustee, securities
administration, or paying agent services, other than residential mortgage-backed
securities and other mortgage-related asset-backed securities.

APPLICABLE SERVICING CRITERIA: All servicing criteria set forth in Item 1122(d),
to the extent required by the related transaction agreements as to any
transaction, except for the following criteria: 1122(d)(1)(ii), 1122(d)(1)(iii),
1122(d)(1)(iv), 1122(d)(4)(vi), 1122(d)(4)(viii), 1122(d)(4)(x), 1122(d)(4)(xi),
1122(d)(4)(xii), 1122(d)(4)(xiii) and 1122(d)(4)(xiv).

PERIOD: As of June 15, 2007 and for the period January 1, 2007 through June 15,
2007.

With respect to the Platform and the Period, the Company provides the following
assessment of compliance in respect of the Applicable Servicing Criteria:

o The Company is responsible for assessing its compliance with the Applicable
Servicing Criteria.

o The Company has assessed compliance with the Applicable Servicing Criteria.

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o As of June 15, 2007 and for the Period, the Company was in material compliance
with the Applicable Servicing Criteria other than as identified on Schedule A
attached.

KPMG LLP, an independent registered public accounting firm, has issued an
attestation report with respect to the Company's assessment of compliance with
the Applicable Servicing Criteria as of and for the Period.


The Bank of New York
The Bank of New York Trust Company, N.A.
The Bank of New York (Delaware)



/s/ Robert L. Griffin

Robert L. Griffin
Authorized Signer


August 29, 2007



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                                   SCHEDULE A

                      MATERIAL INSTANCES OF NON-COMPLIANCE



1122(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.

With respect to collections received on assets relating to certain series of
securities, such collections were deposited into a general account held by the
Indenture Trustee and remitted directly to the investors in such series rather
than through a segregated account relating specifically to such series as
required by the related transaction documents. All collections were properly
allocated by the Indenture Trustee to the related series of securities and
timely remitted to the investors in such series. The segregated account relating
to each series of securities was established by the Indenture Trustee during the
Period but such accounts were not utilized in all instances by the Indenture
Trustee as stated above. Procedures have been established and are currently
being enforced so that collections are deposited into the general account and
then transferred to the segregated account for the related series of securities
within the applicable time frames and then remitted to the investors in such
series in accordance with the related transaction documents.


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