ZC
                Sterling Corporation210
              Interstate North ParkwaySuite
              400Atlanta,
              GA 30339Tel
              770.690.8400Fax
              770.690.8240http://www.zcsterling.com




**Report
      on Assessment of Compliance with Securities and Exchange**


**Commission's
      Regulation AB Servicing Criteria**




For
      the
      calendar year ending December 31 2006, or portion thereof (the "Period"), ZC
      Sterling Insurance Agency, Inc. ("ZCSIA") has been a subcontractor for Servicers
      identified in Appendix A.




The
      undersigned are Senior Vice President of ZCSIA, have sufficient authority to
      make the statements contained in this Assertion and are responsible for
      assessing compliance with the servicing criteria applicable to ZCSIA. ZCSIA
      has
      used the servicing criteria communicated to ZCSIA by the Servicer to assess
      compliance with the applicable servicing criteria. Accordingly, servicing
      criteria 1122 (d) 1(iv), 1122 (d) 4(xi), 1122 (d) 4(xii), and 1122 (d) 4(xiii)
      are applicable to the activities performed by ZCSIA with respect to the
      Platforms covered by this report. The remaining servicing criteria set forth
      in
      Item 1122 (d) of the Securities and Exchange Commission's Regulation AB are
      not
      applicable to the activities performed by ZCSIA with respect to the Platform
      covered by this report. As a subcontractor for Servicer, ZCSIA has determined
      that it complied in all material respects with the servicing criteria listed
      below. ZCSIA engaged Ernst & Young, LLP ("E&Y"), a registered public
      accounting firm, to review ZCSIA's assessment, and E&Y has issued an
      attestation report on ZCSIA's assessment of compliance with the applicable
      servicing criteria for the Period.




1.  ZCSIA
      maintained a fidelity bond and errors & omissions policy in effect on ZCSIA
      throughout the reporting period in the amount of coverage required by the
      transaction agreements between the Servicer and ZCSIA
      (1122(d)((1)(iv)).




2.  Payments
      made on behalf of Servicer's obligor for insurance premiums 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 thirty (30) calendar days prior to these dates,
      or
      such other number of days specified in the transaction agreements between
      Servicer and ZCSIA (1122(d)(4)(xi)).









3.   
       Any late payment penalties in connection with any payment for insurance to
      be made on behalf of Servicer's obligor are paid from the Servicer's funds
      or
      ZCSIA's funds and not charged to Servicer's obligor, unless the late payment
      was
      due to the obligor's error or omission (1122(d)(4)(xii)).




4.
      File(s) provided to Servicer from which Servicer may make disbursements made
      on
      behalf of Servicer's obligor are provided to Servicer on an accurate and timely
      basis and the information thereon is subject to such controls as are specified
      in the transaction agreements between Servicer and ZCSIA
      (1122(d)(4)(xiii).




Sincerely,


ZC STERLING
      INSURANCE AGENCY, INC.






By:
            /s/
              Arthur J. CastnerArthur
              J. CastnerTitle:
            Senior
              Vice President - Hazard OperationsDate:
            February
              20, 2007By:
            /s/
              James P. NovakJames
              P. NovakTitle:
            Senior
              Vice President & Genreal CounselDate:
            February
              20, 2007







**A** **ppendix
        A**
  The
        following is a list of Clients serviced on the ZC Sterling Automated Tracking Solution
        (Tracking System) Platform:
  1.  Eastern
        Savings Bank, fsb
 2.  Homebanc
        Mortgage Corporation
 3.  Irwin
        Mortgage Corporation
 4.  Champion
        Mortgage and Key Bank USA National Association
 5.  Midland
        Mortgage Co.
 6.  Popular
        Mortgage Servicing, Inc. (f/k/a Equity One, Inc.)
 7.  ResMAE
          Mortgage Corporation and Residential Mortgage Assistance Enterprise,
          LLC