**Report
      on Assessment of Compliance with Securities and Exchange**


**Commission’s
      Regulation AB Servicing Criteria**





For
      the
      calendar year ending December 31 2006, or portion thereof (the “Period”), ZC
      Sterling Insurance Agency, Inc. (“ZCSIA”) has been a subcontractor for Servicers
      identified in Appendix A.





The
      undersigned are Senior Vice President of ZCSIA, have sufficient authority to
      make the statements contained in this Assertion and are responsible for
      assessing compliance with the servicing criteria applicable to ZCSIA. ZCSIA
      has
      used the servicing criteria communicated to ZCSIA by the Servicer to assess
      compliance with the applicable servicing criteria. Accordingly, servicing
      criteria 1122 (d) 1(iv), 1122 (d) 4(xi), 1122 (d) 4(xii), and 1122 (d) 4(xiii)
      are applicable to the activities performed by ZCSIA with respect to the
      Platforms covered by this report. The remaining servicing criteria set forth
      in
      Item 1122 (d) of the Securities and Exchange Commission’s Regulation AB are not
      applicable to the activities performed by ZCSIA with respect to the Platform
      covered by this report. As a subcontractor for Servicer, ZCSIA has determined
      that it complied in all material respects with the servicing criteria listed
      below. ZCSIA engaged Ernst & Young, LLP (“E&Y”), a registered public
      accounting firm, to review ZCSIA’s assessment, and E&Y has issued an
      attestation report on ZCSIA’s assessment of compliance with the applicable
      servicing criteria for the Period.





1.  ZCSIA
      maintained a fidelity bond and errors & omissions policy in effect on ZCSIA
      throughout the reporting period in the amount of coverage required by the
      transaction agreements between the Servicer and ZCSIA
      (1122(d)((1)(iv)).





2.  Payments
      made on behalf of Servicer’s obligor for insurance premiums 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 thirty (30) calendar days prior to these dates, or
      such
      other number of days specified in the transaction agreements between Servicer
      and ZCSIA (1122(d)(4)(xi)).





3.  Any
      late
      payment penalties in connection with any payment for insurance to be made on
      behalf of Servicer’s obligor are paid from the Servicer’s funds or ZCSIA’s funds
      and not charged to Servicer’s obligor, unless the late payment was due to the
      obligor’s error or omission (1122(d)(4)(xii)).








4.  File(s)
      provided to Servicer from which Servicer may make disbursements made on behalf
      of Servicer’s obligor are provided to Servicer on an accurate and timely basis
      and the information thereon is subject to such controls as are specified in
      the
      transaction agreements between Servicer and ZCSIA
      (1122(d)(4)(xiii)).








Sincerely,


ZC
      STERLING INSURANCE AGENCY, INC.





By: 
      /s/ Arthur J. Castner


Arthur J. Castner





Title:  Senior
      Vice President - Hazard Operations




Date:  February
      20, 2007








By: 
        /s/ James P. Novak
 James P. Novak





Title:  Senior
      Vice President & General Counsel





Date:  February
      20, 2007


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**Appendix
      A**





The
      following is a list of Clients serviced on the ZC Sterling Automated Tracking
      Solution (Tracking System) Platform:





1.
            Eastern
                Savings Bank, fsb


2.
            Homebanc
                Mortgage Corporation


3.
            Irwin
                Mortgage Corporation


4.
            Champion
                Mortgage and Key Bank USA National
                Association


5.
            Midland
                Mortgage Co.


6.
            Popular
                Mortgage Servicing, Inc. and Equity One,
                Inc.


7.
            ResMAE
                Mortgage Corporation and Residential Mortgage Assistance Enterprise,
                LLC




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