Exhibit 33.5



                                   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


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[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
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[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