|EXHIBIT
  34.1
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Report of Independent Registered
Public Accounting Firm



|Board of DirectorsCitibank, N.A.:
|---------------------------------

We have examined Citibank, N.A.s (or
Company) compliance with the servicing criteria set forth in Item 1122(d) of
the Securities and Exchange Commissions Regulation AB for publicly-issued
(i.e., transaction-level reporting required under the Securities Exchange Act of
1934, as amended) securities backed by insurance-related funding agreements
issued on or after January 1, 2006 for which the Company provides paying agent,
calculation agent, trustee and registrar services, (the Platform), excluding
servicing criteria 1122(d)(1)(ii), 1122(d)(1)(iii), 1122(d)(1)(iv),
1122(d)(2)(iii), 1122(d)(2)(iv), 1122(d)(2)(vi), 1122(d)(2)(vii), 1122(d)(3)(i),
1122(d)(4)(i) through 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 twelve months 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 non-compliance with criterion 1122(d)(3)(ii) and
1122(d)(3)(iii) applicable to the Company as of and for the twelve months ended
December 31, 2006. Instances of material non-compliance related to criterion
1122(d)(3)(ii) were noted.In some instances, certain distributions to investors were
made one day after the timeframes stated in the transaction agreements.
Instances of material non-compliance related to criterion 1122(d)(3)(iii) were
noted.In
some instances, certain distributions were not posted to the Servicers investor
records within two business days.

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



|KMPG
LLP
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|Chicago, IllinoisFebruary 28, 2007
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