EX-34.1
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KPMG LLP
303 East Wacker Drive
Chicago, IL 60601-5212


Report of Independent Registered Public Accounting Firm


The Board of Directors
The Trust & Securities Services department of Deutsche Bank National Trust
Company and Deutsche Bank Trust Company Americas:


We have examined the compliance of the Trust & Securities Services department of
Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas
(collectively the "Company") with the servicing criteria set forth in
Item 1122(d) of the Securities and Exchange Commission's Regulation AB for
publicly-issued (i.e., transaction-level reporting required under the Securities
Exchange Act of 1934, as amended) residential mortgage-backed securities,
commercial mortgage-backed securities and other asset-backed securities issued
on or after January 1, 2006, for which the Company provides trustee, securities
administration, paying agent or custodian services, as defined in the
transaction agreements, excluding publicly-issued transactions sponsored or
issued by any government sponsored entity (the Platform), except for servicing
criteria 1122(d)(2)(iii) and 1122(d)(4)(iv) - 1l22(d)(4)(xiv), which the Company
has determined are not applicable to the activities it performs with respect to
the Platform, as of and for the year ended December 31, 2008. The Company has
determined the following servicing criteria to be applicable only to the
activities the Company performs with respect to the Platform as described below:

* Servicing criterion 1122(d)(1)(iii) is applicable only with respect to the
Company's continuing obligation to act as, or locate a, successor servicer under
the circumstances referred to in certain transaction agreements.  It is
management's interpretation that the Company has no other active back-up
servicing responsibilities in regards to 1122(d)(1)(iii) as of and for the year
ended December 31, 2008. Furthermore, Management's Assertion of Compliance
indicates that there were no activities performed related to this criterion
during the year ended December 31, 2008 with respect to the Platform, because
there were no occurrences of events that would require the Company to perform
such activities.

* Servicing criterion 1122(d)(4)(iii) is applicable to the activities the
Company performs with respect to the Platform only as it relates to the
Company's obligation to report additions, removals or substitutions on reports
to investors in accordance with the transactions agreements.

Management is responsible for the Company's compliance with those servicing
criteria. Our responsibility is to express an opinion on the Company's
compliance based on our examination.

Our examination was conducted in accordance with the standards of the Public
Company Accounting Oversight Board (United States) and, accordingly, included
examining, on a test basis, evidence about the Company's compliance with the
servicing criteria specified above and


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performing such other procedures as we considered necessary in the
circumstances. Our examination included testing selected asset-backed
transactions and securities that comprise the Platform, testing selected
servicing activities related to the Platform, and determining whether the
Company processed those selected transactions and performed those selected
activities in compliance with the servicing criteria. Furthermore, our
procedures were limited to the selected transactions and servicing activities
performed by the Company during the period covered by this report. Our
procedures were not designed to determine whether errors may have occurred
either prior to or subsequent to our tests that may have affected the balances
or amounts calculated or reported by the Company during the period covered by
this report for the selected transactions or any other transactions. We believe
that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on the Company's compliance
with the servicing criteria.

As described in the accompanying Management's Assertion of Compliance for
servicing criteria 1122(d)(2)(i), 1122(d)(4)(i) and 1122(d)(4)(ii), the Company
has engaged various vendors to perform the activities required by these
servicing criteria. The Company has determined that none of these vendors is
considered a "servicer" as defined in Item 1101(j) of Regulation AB, and the
Company 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 Corporation Finance Manual of Publicly Available
Telephone Interpretations ("Interpretation 17.06"). As permitted by
Interpretation 17.06, the Company 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 Company is solely responsible for determining
that it meets the SEC requirements to apply Interpretation 17.06 for the vendors
and related criteria as described in its assertion, and we performed no
procedures with respect to the Company's eligibility to apply Interpretation
17.06.

Our examination disclosed the following material noncompliance with servicing
criterion 1122(d)(1)(i), as applicable to the Company during the year ended
December 31, 2008. Policies and procedures were not instituted to monitor
certain events of default in that notification of the event of default was not
provided to the certificateholders within the timeframe required by the
transaction agreements.

In our opinion, except for the material noncompliance described above, the
Company complied, in all material respects, with the aforementioned servicing
criteria, including servicing criteria 1122(d)(2)(i), 1122(d)(4)(i) and
1122(d)(4)(ii) for which compliance is determined based on Interpretation
17.06 as described above, as of and for the year ended December 31, 2008.


/s/ KPMG LLP

Chicago, Illinois
February 27,2009


KPMG LLP, a U.S. limited liability partnership, is the U.S. member firm of KPMG
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