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| 1. | Bank      of America, National Association (the "Servicer") is responsible for      assessing compliance by it with the servicing criteria applicable to it      under paragraph (d) of Item 1122 of Regulation AB, as of December 31, 2008      and for the period from January 1, 2008 through December 31, 2008 (the      "Reporting Period"), as set forth in Appendix A hereto, in connection with      asset-backed securities transactions involving commercial mortgage loan      transactions that involved an offer or sale of asset-backed securities      that were required to be registered on or after January  1, 2006      with the Securities and Exchange Commission pursuant to the Securities Act      of 1933 (the "Platform");                                                                               |
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| 2. | The      Servicer engaged certain vendors (the "Vendors") to perform certain      specific, limited or scripted activities during the Reporting Period,      related to portions of the servicing criteria as set forth in Appendix A      hereto (such portions of the servicing criteria include, and only include,      Item 1122(d)(2)(i) (only with respect to standard lockbox processing by      depositing checks into the appropriate account indicated by the Servicer)      and Item 1122(d)(4)(xi) (only with respect to verifying outstanding tax      payments and processing such tax payments pursuant to the Servicer's      direction)). The Servicer has elected to take responsibility for assessing      compliance with the portion of the servicing criteria performed by such      Vendors;                           |
| 3. | Except      as set forth in paragraph 4 below, the Servicer used the criteria set      forth in paragraph (d) of Item 1122 of Regulation AB to assess the      compliance with the applicable servicing criteria;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
| 4. | The      criteria in Items 1122(d)(l)(iii), 1122(d)(2)(ii) (only with respect to      disbursements      made to investors), 1122(d)(2)(iii) (other than with respect to      transactions for which the related transaction agreements specifically      required it to advance property protection expenses or payments of      interest and/or principal), 1122(d)(3)(i), 1122(d)(3)(ii),      1122(d)(3)(iii), 1122(d)(3)(iv),      1122(d)(4)(ii), 1122(d)(4)(vii), 1122(d)(4)(viii) (other than for the      period prior      to a servicing transfer event (as defined in the transaction agreements))      and 1122(d)(4)(xv) (other than with respect to those items identified in      Item 1114(a)(l)), of Regulation AB are inapplicable to the Servicer based      on the activities it performs with respect to the Platform;  |
| 5. | The      Servicer has complied, in all material respects, with the applicable      servicing criteria for the Reporting Period with respect to the      Platform;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |
| 6. | The   Servicer  has  not  identified  and  is  not  aware  of      any  material instance of noncompliance by the Vendors with the      applicable servicing criteria for the Reporting Period with respect to the      Platform;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |
| 7. | The      Servicer has not identified any material deficiency in its policies and      procedures to monitor the compliance by the Vendors with the applicable      servicing criteria for the Reporting Period with respect to the Platform;      and                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |

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| 8. | PricewaterhouseCoopers      LLP, an independent registered public accounting firm, has issued an      attestation report on the Servicer's assessment of compliance with the      applicable servicing criteria as of December 31, 2008 and for the      Reporting Period.  |
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|   | BANK      OF AMERICA, NATIONAL ASSOCIATION                                      |
|--------|-------------------------------------------------------------------------------------------|
| By:    |        /s/ Janice M. Smith                                                           |
|   | Name:  Janice      M. SmithTitle:    Managing      Director |

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|          | SERVICING      CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                   | APPLICABLE      SERVICING CRITERIA                                                                                                                                                                    |
|--------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Reference          | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                  | Servicer                                                                                                                                                                                                   | Vendor |
|               |   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 mortgage loans are maintained.                                                                                                                                                                                                                                                                                  |                                                                                                                                                                                                       |   |
| 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 mortgage loans 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                                                                                                                                                                                              | X(only with respect to standard      lockbox processing by depositing checks into the appropriate account      indicated by the Servicer) |
| 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 (other than with respect to      disbursements made to investors)                                                                                                                                   |   |
| 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(only with respect to transactions for      which the related transaction agreements specifically required it to      advance property protection expenses or payments of interest and/or      principal) |   |
| 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                                                                                                                                                                                                          |   |

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|                        | SERVICING      CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | APPLICABLE      SERVICINGCRITERIA |
|-----------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------|
| Reference                   | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               | Servicer                          | Vendor |
|   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               |   |
|                        |  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.                                 |                              |   |
| 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 mortgage loans is maintained as required by the transaction      agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | X                                 |   |
| 1122(d)(4)(ii)              | Mortgage      loan and related documents are safeguarded as required by the transaction      agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |                              |   |
| 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 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.                                                                                                                                                                                                                                                                                              | X                                 |   |
| 1122(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)(vi)              | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | 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.                                                                                                                                                                                                                                                                                                                                                                                                                        |                              |   |

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|                   | SERVICING      CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           | APPLICABLESERVICING      CRITERIA                                                                                      |
|------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------|
|  Reference        | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | Servicer                                                                                                               | Vendor |
|  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 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 (only for the period prior to a servicing      transfer event (as defined in the transaction      agreements))  |   |
| 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | 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 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. | 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 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.                                                                                                                                                                                                                     |  X                                                                                                                | X (only      with respect to verifying outstanding tax payments and processing such tax      payments pursuant to the Servicer's direction) |
| 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(only with respect to those items identified      in Item 1114(a)(1))                                                 |   |

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