Exhibit 33.1


[LOGO]                                                Wells Fargo Home Mortgage
                                                      One Home Campus
                                                      Des Moines, lA 50326-0001

                                                      YourWellsFargoMortgage.com

                             Wells Fargo Bank, N.A.

   2006 Certification Regarding Compliance with Applicable Servicing Criteria


1.    Wells Fargo Bank, N.A. (the "Servicer") is responsible for assessing its
      compliance with the servicing criteria applicable to it under paragraph
      (d) of Item 1122 of Regulation AB as set forth in Exhibit A hereto in
      connection with the primary servicing of residential mortgage loans by its
      Wells Fargo Home Mortgage division, other than the servicing of such loans
      for Freddie Mac, Fannie Mae, Ginnie Mae, state and local government bond
      programs, or a Federal Home Loan Bank (the servicing "Platform");

2.    The Servicer has engaged certain vendors (the "Vendors") to perform
      specific, limited or scripted activities as of and for the year ended
      December 31, 2006, and the Servicer has elected to take responsibility for
      assessing compliance with the servicing criteria or portion of the
      servicing criteria applicable to such Vendors as set forth in Exhibit A
      hereto, with the exception of those Vendors that have provided their own
      report on assessment of compliance with servicing criteria, which reports
      are attached hereto as Exhibit D;

3.    Except as set forth in paragraph 4 below, the Servicer used the criteria
      set forth in paragraph (d) of Item 1122 of Regulation AB to assess the
      compliance with the applicable servicing criteria;

4.    The criteria identified as Inapplicable Servicing Criteria on Exhibit A
      hereto are inapplicable to the Servicer based on the activities it
      performs with respect to its Platform;

5.    The Servicer has complied, in all material respects, with the applicable
      servicing criteria as of and for the year ended December 31, 2006, except
      as described on Exhibit B hereto;

6.    The Servicer has not identified and is not aware of any material instance
      of noncompliance by the Vendors with the applicable servicing criteria as
      of and for the year ended December 31, 2006;

7.    The Servicer has not identified any material deficiency in its policies
      and procedures to monitor the compliance by the Vendors with the
      applicable servicing criteria for the year ended December 31, 2006; and

8.    KPMG LLP, a registered public accounting firm, has issued an attestation
      report on the Servicer's assessment of compliance with the applicable
      servicing criteria as of and for the year ended December 31, 2006, which
      attestation report is included on Exhibit C attached hereto.


March 1, 2007
                                                 WELLS FARGO BANK, N.A.

                                                 By: /s/ Mary C. Coffin
                                                     ---------------------------
                                                     Mary C. Coffin
                                                     Executive Vice President

                                         Wells Fargo Home Mortgage
                                         is a division of Wells Fargo Bank, N.A.

<PAGE>

                                    EXHIBIT A
                                       to
                            Wells Fargo Bank, N.A.'s
   2006 Certification Regarding Compliance With Applicable Servicing Criteria

<TABLE>
<CAPTION>
--------------------------------------------------------------------------------------------------------------------------------
                               Servicing Criteria                                   Applicable Servicing          Inapplicable
                                                                                          Criteria                  Servicing
                                                                                                                     Criteria
--------------------------------------------------------------------------------------------------------------------------------
  Reference                                  Criteria                               Performed      Performed
                                                                                       by             by
                                                                                    Servicer       Vendor(s)
--------------------------------------------------------------------------------------------------------------------------------
                               General Servicing Considerations
--------------------------------------------------------------------------------------------------------------------------------
<S>               <C>                                                                  <C>           <C>                <C>
1122(d)(l)(i)     Policies and procedures are instituted to monitor any                 X
                  performance or other triggers and events of default in
                  accordance with the transaction agreements.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(1)(ii)    If any material servicing activities are outsourced to                X
                  third parties, policies and procedures are instituted to
                  monitor the third party's performance and compliance with
                  such servicing activities.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(1)(iii)   Any requirements in the transaction agreements to maintain a                                           X
                  back-up servicer for the mortgage loans are maintained,
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(1)(iv)    A fidelity bond and errors and omissions policy is in effect          X
                  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.
--------------------------------------------------------------------------------------------------------------------------------
                       Cash Collection and Administration
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(2)(i)     Payments on mortgage loans are deposited into the                     X(1)         X(2)
                  appropriate custodial bank accounts and related bank
                  clearing accounts no more than two business days following
                  receipt, or such other number of days specified in the
                  transaction agreements.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(2)(ii)    Disbursements made via wire transfer on behalf of an obligor          X
                  or to an investor are made only by authorized personnel.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(2)(iii)   Advances of funds or guarantees regarding collections,  cash          X
                  flows or distributions, and any interest or other fees charged
                  for  such  advances,   are  made,  reviewed  and  approved  as
                  specified in the transaction agreements.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(2)(iv)    The related accounts for the transaction, such as cash                X
                  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.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(2)(v)     Each custodial account is maintained at a federally insured           X
                  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-l(b)(l) of the Securities
                  Exchange Act.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(2)(vi)    Unissued checks are safeguarded so as to prevent unauthorized         X(3)         X(4)
                  access.
--------------------------------------------------------------------------------------------------------------------------------
</TABLE>
----------
(1)   A portion of this servicing criteria is performed by a vendor, as set
      forth in footnote 2 below.

(2)   A lockbox vendor receives payments, creates transaction files, deposits
      checks, reconciles files to deposits and transmits the transaction files
      to Wells Fargo. See Exhibit D.

(3)   A portion of this servicing criteria is performed by vendors, as set forth
      in footnote 4 below.

(4)   Insurance vendors prepare and safeguard checks on behalf of Wells Fargo.
      As to one such vendor, see Exhibit D.


<PAGE>

<TABLE>
<CAPTION>
--------------------------------------------------------------------------------------------------------------------------------
                               Servicing Criteria                                   Applicable Servicing          Inapplicable
                                                                                          Criteria                 Servicing
                                                                                                                    Criteria
--------------------------------------------------------------------------------------------------------------------------------
  Reference                                  Criteria                               Performed      Performed
                                                                                       by             by
                                                                                    Servicer       Vendor(s)
--------------------------------------------------------------------------------------------------------------------------------
<S>               <C>                                                                  <C>           <C>                <C>
1122(d)(2)(vii)   Reconciliations are prepared on a monthly basis for all               X
                  asset-backed securities related bank accounts, including
                  custodial accounts and related bank clearing accounts. These
                  reconciliations are (A) mathematically accurate; (B) prepared
                  within 30 calendar days after the bank statement cutoff date,
                  or such other number of days specified in the transactidn
                  agreements; (C) 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.
---------------------------------------------------------------------------------------------------------------------------------
                       Investor Remittances and Reporting
---------------------------------------------------------------------------------------------------------------------------------
1122(d)(3)(i)     Reports to investors, including those to be filed with the            X
                  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 mortgage loans serviced by the
                  Servicer.
---------------------------------------------------------------------------------------------------------------------------------
1122(d)(3)(ii)    Amounts due to investors are allocated and remitted in                X
                  accordance with timeframes, distribution priority and other terms
                  set forth in the transaction agreements.
---------------------------------------------------------------------------------------------------------------------------------
1122(d)(3)(iii)   Disbursements made to an investor are posted within two               X
                  business days to the Servicer's investor records, or such
                  other number of days specified in the transaction agreements.
---------------------------------------------------------------------------------------------------------------------------------
1122(d)(3)(iv)    Amounts remitted to investors per the investor reports                X
                  agree with cancelled checks, or other form of payment, or
                  custodial bank statements.
---------------------------------------------------------------------------------------------------------------------------------
                            Pool Asset Administration
---------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(i)     Collateral or security on mortgage loans is maintained as             X
                  required by the transaction agreements or related mortgage
                  loan documents.
---------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(ii)    Mortgage  loan and  related  documents  are  safeguarded  as          X
                  required by the transaction agreements.
---------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(iii)   Any additions, removals or substitutions to the asset pool            X
                  are made, reviewed and approved in accordance with any
                  conditions or requirements in the transaction agreements.
---------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(iv)    Payments on mortgage loans, including any payoffs, made in            X(5)         X(6)
                  accordance with the related mortgage loan 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 mortgage loan documents.
---------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(v)     The Servicer's records regarding the mortgage loans agree             X
                  with the Servicer's records with respect to an obligor's
                  unpaid principal balance.
---------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(vi)    Changes with respect to the terms or status of an obligor's           X
                  mortgage loans (e.g., loan modifications or re-agings) are
                  made, reviewed and approved by authorised personnel in
                  accordance with the transaction agreements and related pool
                  asset documents.
---------------------------------------------------------------------------------------------------------------------------------
</TABLE>
----------

(5)   A portion of this servicing criteria is performed by a vendor, as set
      forth in footnote 6 below.

(6)   A lockbox vendor receives payments, creates transaction files, deposits
      checks, reconciles files to deposits and transmits the transaction files
      to Wells Fargo. See Exhibit D.

<PAGE>

<TABLE>
<CAPTION>
--------------------------------------------------------------------------------------------------------------------------------
                               Servicing Criteria                                   Applicable Servicing          Inapplicable
                                                                                          Criteria                 Servicing
                                                                                                                    Criteria
--------------------------------------------------------------------------------------------------------------------------------
  Reference                                  Criteria                               Performed      Performed
                                                                                       by             by
                                                                                    Servicer       Vendor(s)
--------------------------------------------------------------------------------------------------------------------------------
<S>               <C>                                                                  <C>           <C>                <C>
1122(d)(4)(vii)   Loss mitigation or recovery actions (e.g., forbearance plans,         X
                  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.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(viii)  Records documenting collection efforts are maintained during          X
                  the period a mortgage loan is delinquent in accordance with
                  the transaction agreements. Such records arc 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 mortgage loans including, for
                  example, phone calls, letters and payment rescheduling plans
                  in cases where delinquency is deemed temporary (e.g., illness
                  or unemployment).
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(ix)    Adjustments to interest rates or rates of return for mortgage         X
                  loans with variable rates are computed based on the related
                  mortgage loan documents.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(x)     Regarding any funds held in trust for an obligor (such as             X
                  escrow accounts): (A) such funds are analyzed, in accordance
                  with the obligor's mortgage loan 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 mortgage
                  loan documents and state laws; and (C) such funds are returned
                  to the obligor within 30 calendar days of full repayment of
                  the related mortgage loans, or such other number of days
                  specified in the transaction agreements.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(xi)    Payments made on behalf of an obligor (such as tax or                 X(7)       X(8)
                  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.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(xii)   Any late payment penalties in connection with any payment             X
                  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.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(xiii)  Disbursements made on behalf of an obligor are posted                 X(9)       X(10)
                  within two business days to the obligor's records maintained
                  by the servicer, or such other number of days specified in
                  the transaction agreements.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(xiv)   Delinquencies, charge-offs and uncollectible accounts are             X
                  recognized and recorded in accordance with the transaction
                  agreements.
--------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(xv)    Any external enhancement or other support, identified in Item                                           X
                  1114(a)(1) through (3) or Item 1115 of Regulation AB, is
                  maintained as set forth in the transaction agreements.
--------------------------------------------------------------------------------------------------------------------------------
</TABLE>

----------
(7)   A portion of this servicing criteria is performed by vendors, as set forth
      in footnote 8 below,

(8)   Insurance vendors obtain renewal invoices, create disbursement
      transactions and submit payments to payees. As to one such vendor, see
      Exhibit D.

(9)   A portion of this servicing criteria is performed by one or more vendors,
      as set forth in footnote 10 below.

(10)  Insurance vendors obtain renewal invoices, create disbursement
      transactions and submit payments to payees. As to one such vendor, see
      Exhibit D.

<PAGE>

                                    EXHIBIT B
                                       to
                             Wells Fargo Bank, N.A.'s
   2006 Certification Regarding Compliance With Applicable Servicing Criteria

Wells Fargo Bank, N.A. ("Wells Fargo") acknowledges the following material
instances of noncompliance with the applicable servicing criteria:

      1.    1122(d)(3)(i) - Delinquency Reporting - For certain loans
            sub-serviced by Wells Fargo or for which servicing rights were
            acquired on a bulk-acquisition basis, Wells Fargo determined that it
            provided incomplete data to some third parties who use such data to
            calculate delinquency ratios and determine the status of loans with
            respect to bankruptcy, foreclosure or real estate owned. The
            incomplete reporting only affected securitizations that included
            delinquent loans. Instead of the actual due date being provided for
            use in calculating delinquencies, the date of the first payment due
            to the security was provided. Wells Fargo subsequently included
            additional data in the monthly remittance reports, providing the
            actual borrower due date and unpaid principal balance, together with
            instructions to use these new fields if such monthly remittance
            reports are used to calculate delinquency ratios.

      2.    1122(d)(4)(vii) - Notification of Intent to Foreclose - Wells Fargo
            determined that, as required by certain servicing agreements, it did
            not provide investors with prior notification of intent to
            foreclose. While investors received monthly delinquency status
            reports that listed loans in foreclosure, such reports were received
            after such loans had been referred to an attorney. A new process is
            being implemented to send such notifications if contractually
            required, unless an investor opts out in writing.

<PAGE>

                                    EXHIBIT C
                                       to
                            Wells Fargo Bank, N.A.'s
   2006 Certification Regarding Compliance With Applicable Servicing Criteria

             Report of Independent Registered Public Accounting Firm

<PAGE>

[LOGO]

                              KPMG LLP
                              2500 Ruan Center
                              666 Grand Avenue
                              Des Moines, IA 50309

             Report of Independent Registered Public Accounting Firm

The Board of Directors
Wells Fargo Bank, N.A.:

We have examined Wells Fargo Bank, N.A.'s (the Company) compliance with the
servicing criteria set forth in Item 1122(d) of the Securities and Exchange
Commission's Regulation AB for its primary servicing of residential mortgage
loans by its Wells Fargo Home Mortgage division, other than the servicing of
such loans for Freddie Mac, Fannie Mae, Ginnie Mae, state and local government
bond programs, or a Federal Home Loan Bank (the Platform), except for servicing
criteria 1122(d)(l)(iii) and 1122(d)(4)(xv), which the Company has determined
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 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.

Our examination disclosed the following instances of material noncompliance with
certain servicing criteria applicable to the Company during the year ended
December 31, 2006:

1.    1122(d)(3)(i) - Delinquency Reporting - The Company provided incomplete
      data to some third parties who use such data to calculate delinquency
      ratios and determine the status of loans with respect to bankruptcy,
      foreclosure or real estate owned. Instead of the actual due date being
      provided for use in calculating delinquencies, the date of the first
      payment due to the security was provided.

2.    1122(d)(4)(vii) - Notification of Intent to Foreclose - The Company, as
      required by certain servicing agreements, did not provide investors with
      prior notification of intent to foreclose.

          KPMG LLP, a U.S. limited liability partnership, is the U.S.
             member firm of KPMG International, a Swiss cooperative

<PAGE>

[LOGO]

As described in the accompanying 2006 Certification Regarding Compliance with
Applicable Servicing Criteria, for servicing criteria 1122(d)(2)(i),
1122(d)(2)(vi), 1122(d)(4)(iv), 1122(d)(4)(xi), and 1122(d)(4)(xiii), the
Company has engaged various vendors to perform the activities required by these
servicing criteria. The Company has determined that these vendors are not
considered "servicers" as defined in Item 1101(j) of Regulation AB, and the
Company has elected to take responsibility for assessing compliance with the
servicing criteria applicable to each vendor as permitted by Interpretation
17.06 of the SEC Division of Corporation Finance Manual of Publicly Available
Telephone Interpretations ("Interpretation 17.06"), with the exception of those
vendors who have provided their own reports on assessment of compliance with
servicing criteria to the Company, for which the Company does not take such
responsibility. As permitted by Interpretation 17.06, the Company has asserted
that it has policies and procedures in place designed to provide reasonable
assurance that the vendors' activities comply in all material respects with the
servicing criteria applicable to each vendor. The Company is solely responsible
for determining that it meets the SEC requirements to apply Interpretation 17.06
for the vendors and related criteria as described in its assertion, and we
performed no procedures with respect to the Company's eligibility to apply
Interpretation 17.06.

In our opinion, except for the instances of material noncompliance described
above, the Company complied, in all material respects, with the aforementioned
servicing criteria as of and for the year ended December 31, 2006.

                                    /s/ KPMG LLP

Des Moines, Iowa
March 1, 2007

<PAGE>

                                    EXHIBIT D
                                       to
                            Wells Fargo Bank, N.A.'s
   2006 Certification Regarding Compliance With Applicable Servicing Criteria

      Vendors' Reports on Assessment of Compliance With Servicing Criteria


<PAGE>

[REGULUS LOGO]

    Report on Assessment of Compliance with Regulation AB Servicing Criteria

      1.    Pursuant to Subpart 229.1100-Asset Backed Securities, 17 C.F.R.
            Sections 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 to 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

 560 LATOUR COURT | NAPA, CA | 94558 | TEL: 707.254.4000 | FAX: 707.254.4070 |
                                REGULUSGROUP.COM
<PAGE>

[LOGO]

                          KPMG LLP
                          1601 Market Street
                          Philadelphia, PA 19103-2499

             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 and servicers of loan and/or receivables portfolios
that include pool assets for 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

          KPMG LLP, a U.S. limited liability partnership, is the U.S.
             member firm of KPMG International, a Swiss cooperative

<PAGE>

                                                                          [LOGO]

                                                    ZC Sterling Corporation
                                                    210 Interstate North Parkway
                                                    Suite 400
                                                    Atlanta, GA 30339


                                                    Tel 770.690.8400
                                                    Fax 770.690.8240
                                                    http://www.zcsterling.com



  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 Presidents 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) 2(vi), 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)((i)(iv)).

2. To the extent that ZCSIA prints checks for Servicer or otherwise has
Servicer's checks or check stock, unissued checks are safeguarded so as to
prevent unauthorized access (1122(d)(2)(vi)). [AS OF DECEMBER 31, 2006, THIS
PROVISION WILL APPLY ONLY FOR THE FOLLOWING SERVICERS: ABN Amro Mortgage Group,
Inc, Option One Mortgage Corporation, Sun Trust Mortgage, Inc., HomEq Servicing
Corporation, Wachovia Insurance Corporation, Wells Fargo Home Mortgage.

<PAGE>

3. 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)).

4. 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)).

5. 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: Ferbruary 20, 2007

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

Title: Senior Vice President & General Counsel

Date: February 20, 2007


                                                                               2
<PAGE>

[LOGO]

                          Ernst & Young LLP                Phone: (404) 874-8300
                          Suite 2800                       www.ey.com
                          600 Peachtree Street
                          Atlanta, Georgia 30308-2215

             Report of Independent Registered Public Accounting Firm

We have examined management's assertion, included in the accompanying Report on
Assessment of Compliance with Securities and Exchange Commission's Regulation AB
Servicing Criteria, that ZC Sterling Insurance Agency, Inc. (the Company)
complied with certain servicing criteria set forth in Item 1122 (d) of the
Securities and Exchange Commission's Regulation AB for the ZC Sterling
Integrated Product Solution (ZIPS) hazard insurance outsourcing Platform
(Platform) as of and for the year ended December 31, 2006. The, Company has
determined that only certain servicing criteria 1122 (d) l(iv), 1122 (d) 2(vi),
1122 (d) 4(xi), 1122 (d) 4(xii), and 1122 (d) 4(xiii) are applicable to the
activities performed by them with respect to the Platform covered by this
report. The Company has determined that 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 them with respect to the
Platform covered by this report. See Appendix A of management's assertion for
the Platform covered by this report. Management is responsible for the Company's
compliance with those servicing criteria. Our responsibility is to express an
opinion on management's assertion about the Company's compliance with the
servicing criteria based on our examination.

Our examination was conducted in accordance with 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 applicable
servicing criteria and performing such other procedures as we considered
necessary in the circumstances. Our examination included testing of less than
all of the servicing activities related to the Platform, and determining whether
the Company performed those selected activities in compliance with the servicing
criteria. Furthermore, our procedures were limited to the 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 Platform. 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 assertion that the Company complied with the
aforementioned servicing criteria as of and for the year ended December 31, 2006
for the ZIPS Platform is fairly stated, in all material respects.

                                        /s/ Ernst & Young LLP
February 20, 2007

                   A Member Practice of Ernst & Young Global
<PAGE>

Appendix A
----------
The  following  is a list of  Clients  serviced  on the ZC  Sterling  Integrated
Product Solution (ZIPS) Platform:

      1.    ABN Amro Mortgage Group, Inc.
      2.    Dovenmuehle Mortgage, Inc.
      3.    HomEq Servicing Corporation
      4.    Option One Mortgage Corporation
      5.    People's Choice Home Loan, Inc.
      6.    Sun Trust Mortgage, Inc.
      7.    Wachovia  Insurance Agency (and its affiliates,  including  Wachovia
            Mortgage Corporation)
      8.    Wells Fargo Home Mortgage


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