EX-34.4
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PricewaterhouseCoopers LLP
350 South Grand Avenue
Los Angeles CA 90071
Telephone (213) 356 6000
Facsimile (813) 637 4444

Report of Independent Registered Public Accounting Firm

To the Board of Directors and Shareholder of Countrywide Home Loans, Inc. and
Countrywide Home Loans Servicing, L.P.:

We have examined Countrywide Home Loans, Inc. ("CHL") and Countrywide Home Loans
Servicing, L.P. ("Countrywide Servicing LP", and together with CHL, the
"Servicer"), each a wholly-owned indirect subsidiary of Bank of America
Corporation, together with their affiliates Countrywide Tax Services Corporation
("Countrywide Tax Services") and Newport Management Corporation ("Newport
Management", and together with the Servicer and Countrywide Tax Services, the
"Company"), compliance with the servicing criteria set forth in Item 1122(d) of
the Securities and Exchange Commission's Regulation AB for publicly-issued
(i.e., registered with the Securities and Exchange Commission pursuant to the
Securities Act of 1933, as amended) residential mortgage-backed securities
(securities collateralized by residential mortgage loans, including prime,
alternative loan products, sub-prime, HELOC and closed seconds) issued on or
after January 1, 2006 for which the Company provides cash collection and
administration, investor remittances and reporting (except for those activities
relating to trustee and paying agent services), and pool asset administration
(except for those activities relating to custodial operations of pool assets and
related documents), and for which the related issuer has a fiscal year end of
December 31, 2008. The platform excludes any transactions issued by any
government sponsored enterprise for which the Company provides the servicing
functions described in the preceding sentence (the Platform) described in the
accompanying Assessment of 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 determined is not applicable to the servicing
activities performed by them with respect to the Platform. 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)(vi) and 1122(d)(4)(vii) of
Regulation AB applicable to the Company during year ended December 31, 2008. For
criterion 1122(d)(4)(vi), in some instances changes with respect to the terms or
status of an obligor's loan were made without the clear consent of the trustee.
For criterion


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1122(d)(4)(vii), certain loss mitigation or recovery actions were not initiated,
conducted or concluded in accordance with the required timeframes established
under the transaction agreements.

In our opinion, except for the material noncompliance described in the preceding
paragraph, the Company complied with the aforementioned applicable servicing
criteria as of and for the year ended December 31, 2008 for the Platform, in all
material respects.


/s/ PricewaterhouseCoopers LLP

February 27, 2009