**EXHIBIT 33.6**

** Management Assessment of Compliance with Applicable Servicing Criteria**

1.                  CitiMortgage, Inc (the “Servicer”) is responsiblefor assessing 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 servicing of 1) first lien residential mortgage loans (other than (a) Freddie Mac, FannieMae, Ginnie Mae residential mortgage loan securitizations, (b) special bond programs and (c) loans held for its own portfolio) and 2) student loans issued subsequent to January 1, 2006, for which the Servicer performs a particular servicing function pursuant to aservicing agreement with a third party, utilizing the Citilink system (the “Platform”) as of and for the year ended December 31, 2006**;**

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. As set forth in Exhibit A hereto, the Servicer’s management has determined that these Vendors are not considered a “servicer”as defined in Item 1101(j) of Regulation AB, and the Servicer’s management 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 CorporationFinance Manual of Publicly Available Telephone Interpretations (Interpretation 17.06). As permitted by Interpretation 17.06, management 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 Servicer’s management is solely responsible for determining that it meets the SEC requirements to apply Interpretation 17.06 for the Vendors and relatedcriteria;

3.                  Except as set forth in paragraph 4 below, the Servicer used thecriteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance with the applicable servicing criteria as of and for the year ended December 31, 2006;

4.                  The criterialisted as Inapplicable Servicing Criteria on Exhibit A hereto are inapplicable to the Servicer based on the activities it performs with respect to asset-backed securities transactions involving the Platform.  For student loan transactions all of the criteria onExhibit A are inapplicable to the Servicer, except for1122(d)(3)(i)(A), 1122(d)(3)(i)(B) and 1122(d)(3)(ii), based on the activities it performs with respect to asset-backed securities transactions involving thePlatform; 

5.                  The Servicer has complied, in all material respects, with theapplicable servicing criteria as of and for the year ended December 31, 2006;

6.                  The Servicer has not identified and is not aware of any materialinstance 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 itspolicies 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 anattestation report on the Servicer’s assessment of compliance with the applicable servicing criteria as of and for the year ended December 31, 2006.

February 27, 2007

By: /s/ Herb Gover

Name:  Herb GoverTitle:   Executive Vice President, North American Consumer Asset Operations

 

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EXHIBIT A

| **Servicing Criteria** | **Applicable Servicing Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  | **INAPPLICABLE Servicing Criteria[1]**       |
|------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------|
| **Reference**          | **Criteria**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | **Performed Directly byServicer[2]**         | **Performed by Vendor(s) for which Servicer is Responsible Party[3]** | ** ** |
|                   | **General Servicing Considerations**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                         |   |   |
| 1122(d)(1)(i)          | Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | **X**                                        | ** ** | ** ** |
| 1122(d)(1)(ii)         | If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicingactivities.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(1)(iii)        | Any requirements in the transaction agreements to maintain a back-up servicer for the mortgage loans are maintained.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **                                   | ** ** | **X** |
| 1122(d)(1)(iv)         | A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by andotherwise in accordance with the terms of the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                   | ** **

**X**                            | ** ** | ** ** |
|                   | **Cash Collection and Administration**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | ** **                                   | ** ** | ** ** |
| 1122(d)(2)(i)          | Payments on mortgage loans are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days following receipt, or such other number ofdays specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ** **

**X[i]**                         | **X[ii]** | ** ** |
| 1122(d)(2)(ii)         | Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X[iii]**                       | **X[iv]** | ** ** |
| 1122(d)(2)(iii)        | Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in thetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(2)(iv)         | The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g., with respect to comminglingof cash) as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **                                   | ** ** | **X** |
| 1122(d)(2)(v)          | Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, “federally insured depositoryinstitution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act.                                                                                                                                                                                                                                                                                                         | ** **

** **

**X**                | ** ** | ** ** |
| 1122(d)(2)(vi)         | Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(2)(vii)        | Reconciliations are prepared on a monthly basis for all 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 transaction 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. | ** **

** **

**X**                | ** ** | ** ** |
|                   | **Investor Remittances and Reporting**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | ** **                                   | ** ** | ** ** |
| 1122(d)(3)(i)          | Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commissionrequirements. 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 filedwith 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.                               | ** **

** **

** **

**X**    | ** ** | ** ** |
| 1122(d)(3)(ii)         | Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transactionagreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(3)(iii)        | Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(3)(iv)         | Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

**X**                            | ** ** | ** ** |
|                   | **Pool Asset Administration**                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ** **                                   | ** ** | ** ** |
| 1122(d)(4)(i)          | Collateral or security on mortgage loans is maintained as required by the transaction agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | ** **

**X[v]**                         | ** **

**X[vi]** | ** ** |
| 1122(d)(4)(ii)         | Mortgage loan and related documents are safeguarded as required by the transaction agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ** **

** **                       | ** **

**X[vii]** | ** ** |
| 1122(d)(4)(iii)        | Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(4)(iv)         | Payments on mortgage loans, including any payoffs, made in accordance with the related mortgage loan documents are posted to the Servicer’s obligor records maintained no more than twobusiness 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.                                                                                                                                                                                                                                                                         | ** **

** **

**X[viii]**          | **X[ix]** | ** ** |
| 1122(d)(4)(v)          | The Servicer’s records regarding the mortgage loans agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(4)(vi)         | Changes with respect to the terms or status of an obligor's mortgage loans (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with thetransaction agreements and related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                          | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(4)(vii)        | Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted andconcluded in accordance with the timeframes or other requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                              | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(4)(viii)       | Records documenting collection efforts are maintained during the period a mortgage loan is delinquent in accordance with the transaction agreements. Such records are maintained on at least amonthly 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 isdeemed temporary (e.g., illness or unemployment).                                                                                                                                                                           | ** **

** **

**X**                | ** ** | ** ** |
| 1122(d)(4)(ix)         | Adjustments to interest rates or rates of return for mortgage loans with variable rates are computed based on the related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(4)(x)          | Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s mortgage loan documents, on at least an annualbasis, 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 calendardays of full repayment of the related mortgage loans, or such other number of days specified in the transaction agreements.                                                                                                 | ** **

** **

** **

**X[x]** | **X[xi]** | ** ** |
| 1122(d)(4)(xi)         | Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for suchpayments, 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.                                                                                                                                                                                                                                                                                                     | ** **

** **

**X[xii]**           | **X[xiii]** | ** ** |
| 1122(d)(4)(xii)        | Any late payment penalties in connection with any payment 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 wasdue to the obligor’s error or omission.                                                                                                                                                                                                                                                                                                                                                                                                                                                     | ** **

**X[xiv]**                       | **X[xv]** | ** ** |
| 1122(d)(4)(xiii)       | Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the Servicer, or such other number of days specified in thetransaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | ** **

**X[xvi]**                       | **X[xvii]** | ** ** |
| 1122(d)(4)(xiv)        | Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | ** **

**X**                            | ** ** | ** ** |
| 1122(d)(4)(xv)         | Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ** **

**X**                            | ** ** | ** ** |

 

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[Reserved for Future USE]

Exhibit B*

 

1.   [Describe material instances of noncompliance byServicer.]                                                           **None Identified**

2.  [Describe any remediation efforts.]

3.  [Describe material instances of noncompliance by Vendors identified byServicer.]                **None Identified**

4.  [Describe any remediation efforts.]  

5.  [Describe material deficiencies in Servicer’s policies and procedures to monitorVendors.]                **None Identified**

6.  [Describe any remediation efforts.]  

*Accountants’ attestation will cover only paragraphs 1, 3 and 5 or, alternatively, will exclude paragraphs 2, 4 and 6. 

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[1]Check only criteria that Servicer neither performs nor takes responsibility for the performance of aVendor. 

[2]  If checked, describe in footnote any portion of the applicable criterion that is not performed by theServicer (because performed by Vendor or performed by another servicing function participant). See footnotes to Exhibit A at end of document.

[3]If checked, describe in footnote the portion of the applicable criterion (if less than all) that isperformed by the Vendor.  See footnotes to Exhibit A at end of document.

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**Footnotes to Exhibit A Servicing Criteria**

[i]The servicer performs all of the criterion 1122(d)(2)(i) except for the lockbox function, which is a specific, limited activity. 

[ii]The vendor performs only the lockbox function for criterion 1122(d)(2)(i).

[iii]The servicer under criterion 1122(d)(2)(ii) makes authorized disbursements on behalf of an obligor for escrowed amounts andto investors and/or the paying agent for their disbursement to investors.  The paying agent (another party participating in the servicing function for which the servicer is not the responsible party) makes authorized disbursements to investors.

[iv]Under criterion 1122(d)(2)(ii), in specific, limited instances the tax and insurance monitoring vendors make disbursements onbehalf of an obligor.

[v]The servicer prepares and ships the required loan documents to the vendor that performs the custodian function.

[vi]The vendor performs the custodian function.

[vii]The vendor performs the custodian function.

[viii]The servicer performs all of the criterion 1122(d)(4)(iv) except for the lockbox function, which is a specific, limitedactivity.

[ix]The vendor performs only the lockbox function for criterion 1122(d)(4)(iv).

[x]The servicer performs all of the functions under criterion 1122(d)(4)(x) except for specific, limited tax and insurancemonitoring activity performed by vendors.

[xi]The vendors performs specific, limited tax and insurance monitoring functions for criterion 1122(d)(4)(x).

[xii]The servicer performs all of the functions under criterion 1122(d)(4)(xi) except for specific, limited tax and insurancemonitoring activity performed by vendors.

[xiii]The vendors performs specific, limited tax and insurance monitoring functions for criterion 1122(d)(4)(xi).

[xiv]The servicer performs all of the functions under criterion 1122(d)(4)(xii) except for specific, limited tax and insurancemonitoring activity performed by vendors.

[xv]The vendors performs specific, limited tax and insurance monitoring functions for criterion 1122(d)(4)(xii).

[xvi]The servicer performs all of the functions under criterion 1122(d)(4)(xiii) except for specific, limited tax and insurancemonitoring activity performed by vendors.

[xvii]The vendors performs specific, limited tax and insurance monitoring functions for criterion 1122(d)(4)(xiii).