WELLS                                               Corporate Trust Services
FARGO                                               9062 Old Annapolis Road
                                                    Columbia, MD 21045-1951
                                                    410 884-2000
                                                    410 715-2380 Fax

                                                    Wells Fargo Bank, N.A.

        ASSESSMENT OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIA

Corporate Trust Services division of Wells Fargo Bank, National Association
(the "Company") provides this assessment of compliance with the following
applicable servicing criteria set forth in Item 1122(d) of Regulation AB
promulgated by the Securities and Exchange Commission. Management has
determined that the servicing criteria are applicable in regards to the
servicing platform for the period as follows:

Platform: Publicly-issued (i.e., transaction-level reporting initially required
under the Securities Exchange Act of 1934, as amended) residential mortgage-
backed securities, commercial mortgage-backed securities and other asset-backed
securities, for which the Company provides master servicing, trustee, securities
administration or paying agent services, excluding transactions issued by any
agency or instrumentality of the U.S. government or any government sponsored
entity (the "Platform").

Applicable Servicing Criteria: All servicing criteria set forth in Item 1122(d),
to the extent required in the related transaction agreements or required by the
Item 1122(d) servicing criteria in regards to the activities performed by the
Company, except for the following criteria: 1122(d)(l)(iii), 1122(d)(4)(ii),
1122(d)(4)(iv), 1122(d)(4)(v), 1122(d)(4)(viii), 1122(d)(4)(ix), 1122(d)(4)(x),
1122(d)(4)(xi), 1122(d)(4)(xii) and 1122(d)(4)(xiii), which management has
determined are not applicable to the activities the Company performs with
respect to the Platform (the "Applicable Servicing Criteria").

Period: Twelve months ended December 31, 2006 (the "Period").

Third parties classified as vendors: With respect to servicing criteria
1122(d)(4)(i), the Company has engaged various vendors to handle certain
Uniform Commercial Code filing functions required by the servicing criteria
("vendors"). The Company has determined that none of the vendors is a
"servicer" as defined in Item 1101(j) of Regulation AB, and the Company elects
to take responsibility for assessing compliance with the portion of 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"). The Company has policies
and procedures in place to provide reasonable assurance that each vendor's
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.

With respect to the Platform and the Period, the Company provides the following
assessment of compliance with respect to the Applicable Servicing Criteria:

1. The Company is responsible for assessing its compliance with the Applicable
Servicing Criteria.

2. The Company has assessed compliance with the Applicable Servicing Criteria,
including servicing criteria for which compliance is determined based on
Interpretation 17.06 as described above, as of and for the Period. In
performing this assessment, management used the criteria set forth by the
Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation
AB.

3. Other than as identified on Schedule A hereto, as of and for the Period, the
Company was in material compliance with the Applicable Servicing Criteria. Any
material instances of noncompliance by a vendor of which the Company is aware
and any material deficiency in the Company's policies and procedures to monitor
vendors' compliance that the Company has identified is specified on Schedule A
hereto.

KPMG LLP, a registered public accounting firm, has issued an attestation report
with respect to the Company's foregoing assessment of compliance as of and for
the Period.
                                WELLS FARGO BANK, NATIONAL ASSOCIATION

                                By: /s/ Brian Bartlett
                                    ------------------
                                        Brian Bartlett

                                Its: Executive Vice President

                                Dated: March 1, 2007





WELLS                                               Corporate Trust Services
FARGO                                               9062 Old Annapolis Road
                                                    Columbia, MD 21045-1951
                                                    410 884-2000
                                                    410 715-2380 Fax

                                                    Wells Fargo Bank, N.A.
                        Schedule A


          Material Instances of Noncompliance by the Company


1122(d)(3)(i)- Delinquency Reporting - During the reporting period, certain
monthly investor or remittance reports included errors in the calculation
and/or the reporting of delinquencies for the pool assets, which errors may or
may not have been material. All such errors were the result of data processing
errors and/or the mistaken interpretation of data provided by other parties
participating in the servicing function. All necessary adjustments to data
processing systems and/or interpretive clarifications have been made to correct
those errors and to remedy related procedures.


          Material Instances of Noncompliance by any Vendor

                                  NONE

Material Deficiencies in Company's Policies and Procedures to Monitor Vendors'
                                Compliance

                                  NONE