Countrywide HOME LOANS 2900 Madera RoadSimi Valley, California 93065- 6298 (805) 955-1000ASSESSMENT OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIACountrywide Financial Corporation and certain of its subsidiaries, including its direct and indirect wholly-owned subsidiaries, Countrywide Home Loans, Inc. (CHL),Countrywide Tax Services Corporation, Newport Management Corporation, and Countrywide Home Loans Servicing, L.P., a wholly-owned subsidiary of CHL (collectively the "Company") provides this platform- level assessment, for whichCountrywide Financial Corporation and such subsidiaries participated in sevicingfunctions, as such term is described under Title 17, Section 229.1122 of the Code of Federal Regulations ("Item 1122 of Regulation AB"), of compliance in respect of the following Applicable Servicing Criteria specified in Item 1122(d) of Regulation AB promulgated by the Securities and Exchange Commission in regard to the followingservicing platform for the following period: Platform: publicly- Issued (i.e., registered with the Securities and ExchangeCommission pursuant to the Securities Act of 1933, as amended) residential mortgage-backed securities (securities collateralized by residential mortgage loans, including prime, alternative loan, products, sub-prime, HELOC and closed seconds) issued on or after January 1, 2006 fo r which the Company provides cash collection and administration, investor remittances and reporting (except for those activities relating to trustee and paying agent services), and pool asset administration (except for those activities relating to custodial operations of pool assets and related documents), collectively "Servicing Functions " and for which the related issue r has a fiscal year end of December 31, 2006. The platform excludes any transactions issued by any government sponsored enterprise for which the Company provides Servicing Functions.Period: as of and fo r the year ended December 31, 2006. Applicable Servicing Criteria: all servicing criteria set forth in Item 1122(d), to the extent required in the related agreements, except for the following paragraphs: 1122(d)(1)(iii), 1122(d)(3)(i)(B), only as it relates to information other than thatcontained in the monthly remittance report delivered by the servicer to the master servicer, trustee, and/or bond administrator, 1122(d)(3)(i)(D), only as it relates to the agreeing with investors' records as to the total unpaid principal balance and number of pool assets serviced by the servicer, 1122(d)(3)(ii), only as it relates to amounts other than amounts remitted by the servicer to the master servicer, trustee, and/or bondadministrator, 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(i) and 1122(d)(4)(ii), only as 1122(d)(4)(i) and 1122(d)(4)(ii) relate to the custodial operations of the pool assets and related documents (collateral file) by the document custodian responsible for such Exhibit 33 a)functions for the related transaction, and I 122(d)(4)(xv), only as it relates to Item 1115 of Regulation AB (derivative transactions). With respect to the Platform and the Period, the Company provides the following assessment of compliance in respect of the Applicable Servicing Criteria:1. The Company is responsible for assessing its compliance with the ApplicableServicing Criteria. 2. The Company has assessed compliance with the Applicable Servicing Criteria. 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. KPMG LLP, an independent registered public accounting firm, has issued an attestation report with respect to the Company's foregoing assessment of compliance. COUNTRYWIDE FINANCIAL CORPORATIONBy: /s/: Steve BaileySteve BaileyIts: Senior Managing Director and Chief Executive Officer, Loan AdministrationDated: February 28, 2007By: /s/: Kevin MeyersKevin MeyersIts: Managing Director and Chief Financial Officer, Countrywide Home Loans, Inc. Loan AdministrationDated: February 28, 2007Schedule AMaterial Instances of NoncomplianceNo material instances of noncompliance: the Company has complied, in all material respects, with the applicable servicing criteria as of and for the year ended December 31, 2006.[Chase logo]                                                JPMCB- PrimeManagement's Report on Assessment of Compliance with Applicable ServicingCriteriaJPMorgan Chase Bank, National Association (the "Asserting Party") is responsible for assessing compliance as of December 31, 2006 and for the period from January 1, 2006 through December 31, 2006 (the "Reporting Period"), with the servicing criteria set forth in Title 17, Section 229.1122(d) of the Code of Federal Regulations (the "CFR"), excluding the inapplicable servicing criteria as set forth in Exhibit A hereto (such criteria, after giving effect to the exclusions identified on Exhibit A, the "Applicable Servicing Criteria"). This report covers the asset-backed securities transactions backed by primeresidential mortgages serviced on the Real Estate ("RE") servicing system where the related asset-backed securities were outstanding during the Reporting Period (the "Platform").The Asserting Party (i) has used the criteria set forth in 17 CFR 229.1122(d) to assess the compliance by the Asserting Party with the Applicable Servicing Criteria for the Reporting Period and (ii) has concluded that the Asserting Party has complied, in an material respects, with the Applicable Servicing Criteria as of December 31, 2006 and for the Reporting Period with respect to the Platform, taken as a whole. PricewaterhouseCoopers LLP, an independent registered public accounting firm, has issued an attestation report for the Platform on our assessment of compliance with theApplicable Servicing Criteria as of December 31, 2006 and for the Reporting Period as set forth in this report. JPMorgan Chase Bank, National AssociationSigned: /s/: David LowmanName: David LowmanTitle: Executive Vice PresidentDate: 02/26/2007Exhibit 33 b)Exhibit A**SERVICING CRITERIA****APPLICABLESERVICINGCRITERIA**InapplicableServicing Criteria**Reference****Criteria****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(1)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 servicing activities.X1122(d)(1)(iii)Any requirements in the transaction agreements to maintain a back- up servicer for the mortgage loans are maintained,`x1122(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 and otherwise in accordance with the terms of the transaction agreements.x**Cash Collection and Administration**1122(d)(2)(i)Payments on mortgage loans arc deposited into the 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.X1122(d)(2)(ii)Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.X1122(d)(2)(iii)Advances of hinds 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 the transaction agreements. X1122(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 commingling of cash) as set forth in the transaction agreements.X1122(d)(2)(v)Each custodial account is maintained at a federally insured depository institution as set forth in the transactionagreements. 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-1(b)(l)Xof the Securities Exchange Act1122(d)(2)(vi)Unissued checks are safeguarded so as to prevent unauthorized access. .X1122(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(1) The Asserting Party monitors events of default as obligated pursuant to the transaction agreements.**SERVICING CRITERIA****APPLICABLESERVICINGCRITERIA****InapplicableServicingCriteria****Reference****Criteria****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 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.`X1122(d)(3)(ii)Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.X1122(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.X1122(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.X1122(d)(4)(ii)Mortgage loan and related documents are safeguarded as required by the transaction agreements**X**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.X1122(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 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.X1122(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.X1122(d)(4)(v i)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 the transaction agreements and related pool asset documents.X1122(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 and concluded in accordance with the timeframes or other requirements established by the transaction agreements.X1122(d)(4)(v iii)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 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).`X1122(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.X1122(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 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.X1122(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 Xappropriate 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 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.X1122(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 the transaction agreements.X1122(d)(4)(xiiv)Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.X1122(d)(4)(xiv )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[CHASE logo]CHF-PrimeManagement's Report on Assessment of Compliance with Applicable Servicing CriteriaChase Home Finance LLC (the "Asserting Party") is responsible for assessing compliance as of December 3l, 2006 and for the period from January l, 2006 through December 31, 2006 (the "Reporting Period"), with the servicing criteria set forth in Title 17, Section 229.1122(d) of the Code of Federal Regulations (the "CFR"), excluding the inapplicable servicing criteria as set forth in Exhibit A hereto (such criteria, after giving effect to the exclusions identified on Exhibit A, the "Applicable Servicing Criteria").This report covers the asset-backed securities transactions backed by prime residential mortgages serviced on the Real Estate ("RE") servicing system where the related asset-backed securities were outstanding during the Reporting Period (the "Platform"). The Asserting Party has engaged certain vendors (the "Vendors") to perform specific and limited activities or activities scripted by the Asserting Party as of and during the Reporting Period, and the Asserting Party elects to take responsibility for assessing compliance with the Applicable Servicing Criteria or portion of the servicing criteria applicable to such Vendors as set forth in Exhibit A hereto (such criteria, the "Applicable Vendor Servicing Criteria"). The Asserting Party (i) has not identified and is not aware of any material instance of noncompliance by the Vendors with the Applicable Vendor Servicing Criteria and (ii) has not identified any material deficiency in its policies and procedures to monitor the compliance by the Vendors with the Applicable Vendor Servicing Criteria as of December 31, 2006 and for the Reporting Period.The Asserting Party (i) has used the criteria set forth in 17 CFR 229.1122(d) to assess the compliance by the Asserting Party with the Applicable Servicing Criteria for the Reporting Period and (ii) has concluded that the Asserting Party has complied, in all material respects, with the Applicable Servicing Criteria as of December 31, 2006 and for the Reporting Period with respect to the Platform, taken as a whole. PricewaterhouseCoopers LLP, an independent registered public accounting firm, has issued an attestation report for the Platform on our assessment of compliance with the Applicable Servicing Criteria as of December 31, 2006 and for the Reporting Period as set forth in this report.Chase Home Finance LLCSigned: /s/: Kim GreavesSigned: /s/: Jim MillerName: Kim GreavesName: Jim MillerTitle: Senior Vice PresidentTitle: Senior Vice PresidentDate: 02/26/2007Date: 02/26/2007Exhibit 33 c)EXHIBIT ACHF - Prime**SERVICING CRITERIA****APPLICABLESERVICINGCRITERIA**InapplicableServicingCriteria**Reference****Criteria****PerformedbyServicer****PerformedbyVendor(s)****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(1)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 servicing activities. X1122(d)(1)(iii)Any requirements in the transactionagreements to maintain a back- up servicer for the mortgage loans are maintained,`x1122(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 and otherwise in accordance with the terms of the transaction agreements. x**Cash Collection and Administration**1122(d)(2)(i)Payments on mortgage loans arc deposited into the 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. xX(2)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**1122(d)(2)(iii)Advances of hinds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for suchadvances, are made, reviewed and approved as specified in the transaction agreements. X1122(d)(2)(iv)The related accounts for the transaction, such as cash reserve - accounts or accounts Xestablished 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 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 Rule13k-1(b)(l)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****X(3)**(1) The Asserting Party monitors events of default as obligated pursuant to the transaction agreements.(2) An affiliate vendor deposits funds from customer transactions to a lockbox clearing account.(3) Two vendors prepare account reconciliations on disbursement clearing accounts.**SERVICING CRITERIA****APPLICABLESERVICING CRITERIA**InapplicableServicingCriteria**Reference****Criteria****Performedby Servicer****PerformedbyVendor(s)**Investor Remittances and Reporting1122(d)(3)(i)Reports to investors, including those to be filed with the 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 X(4)`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 accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.X(5)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(6)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(7)Pool Asset Administration1122(d)(4)(i)Collateral or security on mortgage loans is maintained as required by the transaction agreements or related mortgage loan documents.X1122(d)(4)(ii)Mortgage loan and related documents are safeguarded as required by the transaction agreementsX1122(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.X1122(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 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.X1122(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)(v i)Changes with respect to the terms or status of an obligor's mortgage loans (e.g., loanmodifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the **X**transaction agreements and related pool asset documents.4)The Asserting Party provides monthly pool accounting reports to the appropriate party pursuant to the transaction agreements.5)The Asserting Party remits amounts to the appropriate party pursuant to the transaction agreements.6)Disbursements made to the appropriate party pursuant to the transaction agreements are posted within two business days to the Asserting Party's records, or such other number of days specified in the transaction agreements.7)The Asserting Party reconciles its records relating to disbursements made to the appropriate party pursuant to the transaction agreements.**SERVICING CRITERIA****APPLICABLESERVICING CRITERIA**InapplicableServicingCriteria**Reference****Criteria****Performedby Servicer****PerformedbyVendor(s)**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 and concluded in accordance with the timeframes or other requirements established by the transaction agreements.X1122(d)(4)(v iii)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 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).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.X1122(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 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) xsuch 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 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.XX(8)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 was due to the obligor's error or omission.X1122(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 the transaction agreements.X1122(d)(4)(xiiv)Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.**X**1122(d)(4)(xiv )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(8) Two vendors provide information used by the Asserting Party to pay taxes and insurance on behalf of obligors.PHH Mortgage [PHH Logo]3000 Leadenhall RoadMt. Laurel, NJ 08054 REPORT ON ASSESSMENT OF COMPLIANCE WITH REGULATION ABSERVICING CRITERIAPHH Mortgage Corporation (the "Asserting Party") is responsible for assessing compliance as of December 31, 2006 and for the period from January 1, 2006 through December 31, 2006 (the "Reporting Period") with the servicing criteria set forth in Section 229.1122(d) of the Code of Federal Regulations (the "CFR"), except for criteriaset forth in Section 229.1122(d)(3)(i)(c), (d)(4)(ii), (d)(4)(xv) and (d)(1)(iii) of the CFR,which the Asserting Party has concluded are not applicable to the servicing activities it performs with respect to the transactions covered by this report (the "ApplicableServicing Criteria"). The criteria set forth in Section 229.1122 (d)(4)(vii) and (d)(4)(xi) of the CFR are performed by outsource providers on behalf of the Asserting Party; however, the Asserting Party has monitored the outsourcing of these criteria and assumes responsibility for compliance. The transactions covered by this report include all non-agency loan sale agreements executed after January 1, 2006 as well as all re-securitization transactions after January 1, 2006 for which the Asserting Party  served as servicer (the "Platform").The Asserting Party has assessed its compliance with the Servicing Criteria as of December 31, 2006 and for the Reporting Period and has concluded that the Asserting Party has complied, in all material respects, with the Servicing Criteria with respect to the Platform taken as a whole except for as discussed below; StandardDescription1122(d)(1)(i)The Asserting Party has not instituted policies and procedures to specifically monitor performance or other triggers or events of default stated in the transaction agreements.1122(d)(1)(iv)During the months of July, August, and September, the Company's minimum coverage requirement exceeded its $160 million fidelity bond by amounts ranging up to approximately $1.3 million. Effective September 27, 2006, the Company's fidelity bond was increased to $170 million.1122(d)(3)(i)(A)The Asserting Party did not maintain or provide one of the required monthly reports stated in the Iransaction agreementsduring the year.1122(d)(3)(i)(D)The Asserting Party did not perform procedures to agree the unpaid principal balance and number of loans serviced by the Asserting Party with that of the investors or trustees.Exhibit 33 d)Deloitte & Touche, an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the Servicing Criteria for the Reporting Period as set forth in this assertion. PHH Mortgage Corporation Date; February 28, 2007 /s/: Terence W. Edwards Terence W. Edwards President and Chief Executive Officer /s/: Mark Danahy Mark Danahy Senior Vice President and Chief Financial Officer /s/: Martin L. Foster Martin L. Foster Senior Vice President -- Loan Servicing Exhibit 33 e)[SunTrust Mortgage logo]SunTrust Mortgage, Inc.Post Office Box 26149Richmond. VA 23250-6149Toll Free l.800.634.7928www.suntrustmortgage.comMANAGEMENT'S ASSERTION ON COMPLIANCE WITH REGULATION AB CRITERIASunTrust Mortgage, Inc. (the "Asserting Party") is responsible for assessing compliance as of and for the year ended December 31, 2006 (the "Reporting Period") with the servicing criteria set forth in Title 17, Section 229.1122(d) of the Code of Federal Regulations (the "CFR"), as set forth in Appendix A hereto in connection with the servicing of the asset-backed securitizationsbacked by residential mortgage loans serviced by the Asserting Party (the `Applicable Servicing Criteria"). This report covers all residential mortgage loan securitization transactions occurringafter December 31, 2005 (the "Platform:)The Asserting Party has assessed its compliance with the Applicable Servicing Criteria for the Reporting period and has identified three material instances of noncompliance with servicingcriteria set forth in Section 229.1122(d)(1)(i), Section 229.1122(d)(2)(i), and Section 229.1122(d)(2)(iv), respectively, of the CFR with respect to the Platform. Specifically, for the period from January 1, 2006 through December 31, 2006 the Asserting Party (a) did not institute policies and procedures to monitor any performance or other triggers and events of default in accordance with the transaction agreements, (b) did not process payments into the appropriate custodial bank accounts within two business days of receipt or per the related transaction agreement, and (C) did not establish separately maintained custodial accounts in accordance with the applicable transaction agreements. The Asserting Party has further concluded that, with the exception of the aforementioned material instances of noncompliance, the Asserting Party has complied, in all material respects, with the Applicable Servicing Criteria as of December 31,2006 and for the period front January 1,2006 through December 31, 2006. Pricewaterhouse Coopers LLP, an independent registered public accounting firm, has issued an attestation report on the assessment of compliance with the Applicable Servicing Criteria for the Reporting Period. SunTrust Mortgage, Inc. /s/ John R Purcell Jr.John R.Purcell,Jr.Senior Vice President- Manager, Servicing Division Dated: February 27, 2007APPENDIX A**SERVICING CRITERIA****APPLICABLE****SERVICING CRITERIA****Reference****Criteria****Performed****Directly****by****SunTrust****Mortgage,****Inc.****Performed****by****Vendor(s)****for whichSunTrust****Mortgage,****Inc. is the****Responsible****Party****Inapplicable****Servicing****Criteria****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 servicing activities.**X**1122(d)(1)(iii)Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets 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 and otherwise in accordance with the terms of the transaction agreements.**X****Cash Collection and Administration**1122(d)(2)(i)Payments on pool assets 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 of days specified in the transaction agreements.**X****1****X****2**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**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 the transaction 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 commingling of 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 depository institution" 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**1The Asserting Party is responsible for this criteria except as it pertains to lockbox payments.2Another party is responsible for the lockbox components of this criterion.**SERVICING CRITERIA****APPLICABLE****SERVICING CRITERIA****Reference****Criteria****Performed****Directly****by****SunTrust****Mortgage,****Inc.****Performed****by****Vendor(s)****for whichSunTrust****Mortgage,****Inc. is the****Responsible****Party****Inapplicable****Servicing****Criteria**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 reconciliationsare (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 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 pool assets 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 transaction agreements.**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 pool assets is maintained as required by the transaction agreements or related mortgage loan documents.**X**1122(d)(4)(ii)Pool asset and related documents are safeguarded as required by the transaction agreements**X**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 pool assets, including any payoffs, made in accordance with the related pool asset 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 otheritems (e.g., escrow) in accordance with the related pool asset documents.**X**1122(d)(4)(v)The Servicer's records regarding the pool assets agree with the Servicer's records with respect to an obligor's unpaid principal balance.**X****SERVICING CRITERIA****APPLICABLE****SERVICING CRITERIA****Reference****Criteria****Performed****Directly****by****SunTrust****Mortgage,****Inc.****Performed****by****Vendor(s)****for whichSunTrust****Mortgage,****Inc. is the****Responsible****Party****Inapplicable****Servicing****Criteria**1122(d)(4)(vi)Changes with respect to the terms or status of an obligor's pool assets (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction 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 and concluded 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 pool asset is delinquent in accordance with the transaction agreements. Such records are 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 pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delin quency is deemed temporary (e.g., illness or unemployment).**X**1122(d)(4)(ix)Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset 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 pool asset 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 pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements.**X**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(3)****X(4)**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 was due to the obligor's error or omission.**X**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 the transaction agreements.**X**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**3Another party is responsible for the insurance payments components of this criterio n.4The Asserting Party is responsible for the criteria except as it pertains to insurance payments.Management's Assertion Report on Compliance with Applicable Servicing Criteria Pursuant to Item 1122 of Regulation AB under the Securities Exchange Act of 1934 U.S. Bank National Association ("U.S. Bank") as a party participating in the servicing function for the following transactions: U.S. Bank Corporate Trust Asset Backed Securities Platform (1)hereby provides the following report on its assessment of compliance with the servicing criteria set forth in Item 1122 of Regulation AB applicable to it and as described on Exhibit A hereto: 1.  U.S. Bank is responsible for assessing its compliance with the servicing criteria applicable to it as noted on the accompanying Exhibit A; 2.  U.S. Bank used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess its compliance with the applicable servicing criteria ; 3.  U.S. Bank's assessment of its compliance with the applicable servicing criteria is as of and for the period beginning on January 1, 2006 and ending December 31, 2006, the end of the fiscal year covered by the Form 10-K report. U.S. Bank's participation in the servicing function complied in all material respects with the applicable servicing criteria . 4.  Ernst & Young, a registered public accounting firm, has issued an attestation report on U.S. Bank's assessment of compliance with the applicable servicing criteria as of and for the period beginning on January 1, 2006 and ending December 31, 2006, the end of the fiscal year covered by the Form 10-K report. U.S. BANK NATIONAL ASSOCIATION /s/ Bryan R. Calder Name: Bryan R. Calder Title: Executive Vice President Date: February 26, 2007 1 The U.S. Bank Corporate Trust ABS Platform (the "Platform") consists of the activities involved in the performance of servicing functions for (i) publicly issued asset-backed and mortgage-backed transactions the securities of which were offered on or after January 1, 2006 and (ii) certain asset-backed transactions offered prior to January 1, 2006 for which the Issuer has voluntarily elected to make Regulation AB compliant filings under the Securities Exchange Act of 1934, as amended. The Platform does not include transactions comprised of the repackaging of corporate debt and/or other agency securities. Exhibit 33 f)U.S. Bank Master Servicing Platform2**EXHIBIT A to Management's Assertion****Reg AB Reference****Servicing Criteria****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.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 servicing activities. 1122(d)(1)(iii)Any requirements in the transaction agreements to maintain a back-up servicer for the Pool Assets are maintained. Not Applicable1122(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 and otherwise in accordance with the terms of the transaction agreements. **Cash Collection and Administration**1122(d)(2)(i)Payments on pool assets 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 of days specified in the transaction agreements. 1122(d)(2)(ii)Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel. 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 the transaction agreements. 1122(d)(2)(iv)The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of over collateralization, 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 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-1(b)(1) of the Securities Exchange Act.1122(d)(2)(vi)Unissued checks are safeguarded so as to prevent unauthorized access. 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. **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 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 U.S. Bank Master Servicing Platform3balance and number of Pool Assets serviced by the Servicer. 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 transaction agreements. 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.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. **Pool Asset Administration**1122(d)(4)(i)Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents. 1122(d)(4)(ii)Pool assets  and related documents are safeguarded as required by the transaction agreements1122(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.1122(d)(4)(iv)Payments on pool assets, including any payoffs, made in accordance with the related pool asset 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 pool asset documents. Not Applicable1122(d)(4)(v)The Servicer's records regarding the pool assets agree with the Servicer's records with respect to an obligor's unpaid principal balance. Not Applicable1122(d)(4)(vi)Changes with respect to the terms or status of an obligor's pool assets (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents. Not Applicable1122(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 and concluded in accordance with the timeframes or other requirements established by the transaction agreements. Not Applicable1122(d)(4)(viii)Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are 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 pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment). Not Applicable1122(d)(4)(ix)Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents. Not Applicable1122(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 pool asset 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 pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements. Not ApplicableU.S. Bank Master Servicing Platform41122(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 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. Not Applicable1122(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 was due to the obligor's error or omission. Not Applicable1122(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 the transaction agreements. Not Applicable1122(d)(4)(xiv)Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements. 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.