Management Assessment
 
       /s/ April HugheyApril Hughey, VP of Structured
Transactions and Collateral
Management3/31/2009Date




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APPENDIX B
 INAPPLICABLEAPPLICABLE
    
    SERVICINGSERVICING CRITERIA
    
    SERVICING CRITERIA
    
    CRITERIAPerformed
    
    Performed byby
    
    subservicer(s)
    
    NOTVendor(s)
    
    or vendor(s)
    
    performed byfor which
    
    for which the
    
    the Bank or byPerformed
    
    the Bank is
    
    Bank is NOT
    
    subservicer(s)Directly
    
    the
    
    the
    
    or vendor(s)by
    
    Responsible
    
    Responsible
    
    retained byReference
    
    Criteria
    
    the Bank
    
    Party
    
    Party
    
    the BankGeneral Servicing Considerations1122(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.
    
    X1122(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 [pool assets] 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.
    
    XCash Collection and Administration1122(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.
    
    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 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.
    
    
    
    
    
    
    
    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 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.
    
    X1122(d)(2)(vi)
    
    Unissued checks are safeguarded so as to prevent unauthorized
access.
    
    
    
    
    
    
    
    X




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INAPPLICABLEAPPLICABLE
    
    SERVICINGSERVICING CRITERIA
    
    SERVICING CRITERIA
    
    CRITERIAPerformed
    
    Performed byby
    
    subservicer(s)
    
    NOTVendor(s)
    
    or vendor(s)
    
    performed byfor which
    
    for which the
    
    the Bank or byPerformed
    
    the Bank is
    
    Bank is NOT
    
    subservicer(s)Directly
    
    the
    
    the
    
    or vendor(s)by
    
    Responsible
    
    Responsible
    
    retained byReference
    
    Criteria
    
    the Bank
    
    Party
    
    Party
    
    the Bank1122(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.
    
    XInvestor 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 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.
    
    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.
    
    XPool Asset Administration1122(d)(4)(i)
    
    Collateral or security on [pool assets] is maintained as required by
the transaction agreements or related mortgage loan documents.
    
    X1122(d)(4)(ii)
    
    [pool asset] and related documents are safeguarded as required by
the transaction agreements
    
    
    
    X (1)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 [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.
    
    X1122(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




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INAPPLICABLEAPPLICABLE
    
    SERVICINGSERVICING CRITERIA
    
    SERVICING CRITERIA
    
    CRITERIAPerformed
    
    Performed byby
    
    subservicer(s)
    
    NOTVendor(s)
    
    or vendor(s)
    
    performed byfor which
    
    for which the
    
    the Bank or byPerformed
    
    the Bank is
    
    Bank is NOT
    
    subservicer(s)Directly
    
    the
    
    the
    
    or vendor(s)by
    
    Responsible
    
    Responsible
    
    retained byReference
    
    Criteria
    
    the Bank
    
    Party
    
    Party
    
    the Bank1122(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.
    
    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)(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).
    
    X1122(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.
    
    
    
    
    
    
    
    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 [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.
    
    
    
    
    
    
    
    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 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.
    
    
    
    
    
    
    
    X1122(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)(xiv)
    
    Delinquencies, charge-offs and uncollectible accounts are
recognized and recorded in accordance with the transaction
agreements.
    
    X1122(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
 Footnote (1):