PricewaterhouseCoopers
      LLP214
      N. Tryon StreetSte
      3600Charlotte
      NC 28202Telephone
      (704) 344 7500Facsimile
      (704) 344 4100






Report
of Independent Registered Public Accounting Firm





To the
Board of Directors of Bank
of America, National Association,





We have
examined Bank of America, National Association's (the "Company") compliance with
the servicing criteria set forth in Item 1122(d) of the Securities and Exchange
Commission's Regulation AB for the domestic asset-backed securities transactions
for which the Company acted as servicer involving residential mortgage loans,
other than government sponsored entities, or transactions that do not have
scheduled interest and/or scheduled principal remittance schedules as outlined
in their respective transaction agreements, with the exception of certain
non-registered transactions (the "Platform") described in the accompanying
Appendix A of the Certification Regarding Compliance with Applicable Servicing
Criteria, as of December 31, 2008 and for the year then ended, excluding
criterion 1122(d)(1)(iii)
which the Company has determined is not applicable to the servicing activities
they perform with respect to the Platform. As described in Appendix A, for
servicing criteria 1122 (d)(2)(ii), 1122
(d)(4)(iv), 1122 (d)(4)(xi), 1122 (d)(4)(xii) and 1122 (d)(4)(xiii), the Company
has engaged various vendors to perform the activities required by these
servicing criteria. The Company has determined that these vendors are not
considered "servicers" 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 determination of its eligibility to
use Interpretation 17.06. Management is responsible for the Company's compliance
with the servicing criteria. Our responsibility is to express an opinion on the Company's
compliance with the servicing criteria based on our examination.
 
 Our
examination was conducted in accordance with 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 applicable servicing criteria
and performing such other procedures as we considered necessary in the
circumstances. Our examination included testing of selected asset-backed
transactions and securities that comprise the Platform, testing of 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 applicable servicing criteria. 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 detect noncompliance arising from errors that may have occurred
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. 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.







Our
examination disclosed the following material noncompliance with the servicing
criteria set forth in Item 1122
(d)(4)(vii) of Regulation AB applicable to the Company during the year ended
December 31, 2008.
Certain foreclosures were not initiated in accordance with the timeframes
established by the transaction agreements.
 
 In our
opinion, except for the material noncompliance described in the preceding
paragraph, Bank of America,
National Association complied with the aforementioned applicable servicing
criteria as of and for the year ended December 31, 2008 for the domestic
asset-backed securities transactions for which the Company acted as servicer
involving residential mortgage loans, other than government sponsored entities,
or transactions that do not have scheduled interest and/or scheduled principal
remittance schedules as outlined in their respective transaction agreements,
with the exception of certain non-registered transactions, in all material
respects.