EX-33.1
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Management Assessment of Compliance with Applicable Servicing Criteria

1. CitiMortgage, Inc. (the "Servicer") is responsible for assessing compliance
   with the applicable servicing criteria set forth in Item 1122(d) of
   Regulation AB of the Securities and Exchange Commission, as set forth in
   Exhibit A hereto, in connection with the servicing of first lien residential
   mortgage loans, for which the Servicer performs a particular servicing
   function pursuant to a servicing agreement with a third party, except for
   (a) Freddie Mac, Fannie Mae, and Ginnie Mae residential mortgage loan
   securitizations unless part of a special bond program and (b) loans held for
   its own portfolio, utilizing the Citilink system (the "Platform") as of and
   for the year ended December 31, 2012;

2. The Servicer has engaged certain Vendors (the "Vendors") to perform
   specific, limited or scripted activities as of and for the year ended
   December 31, 2012. As set forth in Exhibit A hereto, the Servicer's
   management has determined that these Vendors are not considered a "servicer"
   as defined in Item 1101(j) of Regulation AB, and the Servicer's
   management 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, management 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 Servicer's management is solely responsible
   for determining that it meets the SEC requirements to apply Interpretation
   17.06 for the Vendors and related criteria;

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 as of and for the year
   ended December 31, 2012;

4. The criteria listed as Inapplicable Servicing Criteria on Exhibit A hereto
   are inapplicable to the Servicer based on the activities it performs with
   respect to asset-backed securities transactions involving the Platform;

5. The Servicer has complied, in all material respects, with the applicable
   servicing criteria as of and for the year ended December 31, 2012, except as
   described on Exhibit B hereto;

6. The Servicer has not identified and is not aware of any material instance
   of noncompliance by the Vendors with the applicable servicing criteria as of
   and for the year ended December 31, 2012;

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 as of and for the year ended December 31, 2012; and


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8. KPMG LLP, a registered public accounting firm, has issued an attestation
   report on the Servicer's compliance with the applicable servicing criteria
   as of and for the year ended December 31, 2012.


February 28, 2013

By:    /s/ Anthony Renzi
Name:  Anthony Renzi
Title: Senior Vice President, CitiMortgage, Inc.
       Senior Officer in Charge of Servicing


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Exhibit A - Citilink Platform

<TABLE>
<CAPTION>
                                                                                                             INAPPLICABLE
                                                                          APPLICABLE                         SERVICING
                             SERVICING CRITERIA                           SERVICING CRITERIA                 CRITERIA

                                                                                                                      NOT
                                                                                 Performed          Performed by      performed by
                                                                                 by Vendor(s)       subservicer(s)    CitiMortgage,
                                                                                 for which          or Vendor(s)      Inc. or by
                                                                 Performed       CitiMortgage,      for which         subservicer(s
                                                                 Directly        Inc.               CitiMortgage,     or Vendor(s))
                                                                 by              is the             Inc. is NOT the   retained by
                                                                 CitiMortgage,   Responsible        Responsible       CitiMortgage,
                                                                 Inc.            Party              Party^1           Inc.^2
Reference          Criteria

                <c>                                           <c>             <c>                <c>               <c>
                   General Servicing Considerations

                   Policies and procedures are instituted        X
                   to monitor any performance or other
                   triggers and events of default in
                   accordance with the transaction
1122(d)(1)(i)      agreements.

                   If any material servicing activities          X
                   are outsourced to third parties, policies
                   and procedures are instituted to monitor
                   the third party's performance and
                   compliance with such servicing
1122(d)(1)(ii)     activities.


                   Any requirements in the transaction                                                                X
                   agreements to maintain a back-up servicer
1122(d)(1)(iii)    for the loans are maintained.

                   A fidelity bond and errors and                X
                   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
1122(d)(1)(iv)     the transaction agreements.

                   Cash Collection and Administration

                   Payments on loans are deposited               X^i             X^ii
                   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
1122(d)(2)(i)      agreements.

                   Disbursements made via wire transfer on       X^iii           X^iv                                 X^v
                   behalf of an obligor or to investor are
1122(d)(2)(ii)     made only by authorized personnel.

                   Advances of funds or guarantees               X
                   regarding collections, cash flows or
                   distributions, and any interest or other
                   fees charged for such advances, are made,
                   reviewed and approved as specified in
1122(d)(2)(iii)    the transaction agreements.

                   The related accounts for the                  X
                   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
1122(d)(2)(iv)     the transaction agreements.

                   Each custodial account is maintained at       X
                   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)
1122(d)(2)(v)      of the Securities Exchange Act.

                   Unissued checks are safeguarded so as         X
1122(d)(2)(vi)     to prevent unauthorized access.


<FN>
1 Check only those criteria which are performed by subservicer(s) or Vendor(s) retained by CitiMortgage.

2 Check only those criteria which CitiMortgage does NOT (i) perform directly, (ii) take responsibility for
  the performance of by a Vendor, or (iii) retain subservicer(s) or Vendor(s) to perform.
</FN>
</TABLE>


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<TABLE>
<CAPTION>
                                                                                                             INAPPLICABLE
                                                                          APPLICABLE                         SERVICING
                             SERVICING CRITERIA                           SERVICING CRITERIA                 CRITERIA

                                                                                                                      NOT
                                                                                 Performed          Performed by      performed by
                                                                                 by Vendor(s)       subservicer(s)    CitiMortgage,
                                                                                 for which          or Vendor(s)      Inc. or by
                                                                 Performed       CitiMortgage,      for which         subservicer(s
                                                                 Directly        Inc.               CitiMortgage,     or Vendor(s))
                                                                 by              is the             Inc. is NOT the   retained by
                                                                 CitiMortgage,   Responsible        Responsible       CitiMortgage,
                                                                 Inc.            Party              Party^1           Inc.^2
Reference          Criteria

                <c>                                           <c>             <c>                <c>               <c>

                   Reconciliations are prepared on a             X
                   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
1122(d)(2)(vii)    transaction agreements.

                   Investor Remittances and Reporting

                   Reports to investors, including those         X
                   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;
                   (D) agree with the investors' or trustee's
                   records as to the total unpaid principal
                   balance and number of loans
1122(d)(3)(i)      serviced by the Servicer.

                   Amounts due to investors are allocated        X
                   and remitted in accordance with
                   timeframes, distribution priority and
                   other terms set forth in the transaction
1122(d)(3)(ii)     agreements.

                   Disbursements made to an investor are         X
                   posted within two business days to the
                   Servicer's investor records, or such other
                   number of days specified in the transaction
1122(d)(3)(iii)    agreements.

                   Amounts remitted to investors per the         X
                   investor reports agree with cancelled
                   checks, or other form of payment, or
1122(d)(3)(iv)     custodial bank statements.

                   Pool Asset Administration

                   Collateral or security on loans               X^vi                                                 X^vii
                   is maintained as required by the
                   transaction agreements or related
1122(d)(4)(i)      mortgage loan documents.

                   Loan and related documents are                X^viii                                               X^ix
                   safeguarded as required by the
1122(d)(4)(ii)     transaction agreements

                   Any additions, removals or substitutions      X
                   to the asset pool are made, reviewed
                   and approved in accordance with
                   any conditions or requirements in the
1122(d)(4)(iii)    transaction agreements.

                   Payments on loans, including any              X^x             X^xi
                   payoffs, made in accordance with related
                   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
1122(d)(4)(iv)     with the related loan documents.

                   The Servicer's records regarding the          X
                   loans agree with the Servicer's
                   records with respect to an obligor's
1122(d)(4)(v)      unpaid principal balance.

</TABLE>


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<TABLE>
<CAPTION>
                                                                                                             INAPPLICABLE
                                                                          APPLICABLE                         SERVICING
                             SERVICING CRITERIA                           SERVICING CRITERIA                 CRITERIA

                                                                                                                      NOT
                                                                                 Performed          Performed by      performed by
                                                                                 by Vendor(s)       subservicer(s)    CitiMortgage,
                                                                                 for which          or Vendor(s)      Inc. or by
                                                                 Performed       CitiMortgage,      for which         subservicer(s
                                                                 Directly        Inc.               CitiMortgage,     or Vendor(s))
                                                                 by              is the             Inc. is NOT the   retained by
                                                                 CitiMortgage,   Responsible        Responsible       CitiMortgage,
                                                                 Inc.            Party              Party^1           Inc.^2
Reference          Criteria

                <c>                                           <c>             <c>                <c>               <c>

                   Changes with respect to the terms or          X
                   status of an obligor's loans
                   (e.g., loan modifications or re-agings)
                   are made, reviewed and approved by
                   authorized personnel in accordance
                   with the transaction agreements and
1122(d)(4)(vi)     related pool asset documents.

                   Loss mitigation or recovery actions           X
                   (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
1122(d)(4)(vii)    agreements.

                   Records documenting collection efforts        X
                   are maintained during the period a
                   loan 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 loans including, for
                   example, phone calls, letters and payment
                   rescheduling plans in cases where
                   delinquency is deemed temporary (e.g.,
1122(d)(4)(viii)   illness or unemployment).

                   Adjustments to interest rates or rates        X
                   of return for loans with variable
                   rates are computed based on the related
1122(d)(4)(ix)     loan documents.

                   Regarding any funds held in trust for         X^xii           X^xiii
                   an obligor (such as escrow accounts): (A)
                   such funds are analyzed, in accordance
                   with the obligor's 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;
                   (C) such funds are returned to the obligor
                   within 30 calendar days of full repayment
                   of the related loans, or such
                   other number of days specified in the
1122(d)(4)(x)      transaction agreements.

                   Payments made on behalf of an obligor         X^xiv           X^xv
                   (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
1122(d)(4)(xi)     the transaction agreements.

                   Any late payment penalties in connection      X^xvi           X^xvii
                   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
1122(d)(4)(xii)    to the obligor's error or omission.

                   Disbursements made on behalf of an            X^xviii         X^xix
                   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
1122(d)(4)(xiii)   agreements.

                   Delinquencies, charge-offs and                X
                   uncollectible accounts are recognized and
                   recorded in accordance with the
1122(d)(4)(xiv)    transaction agreements.

                   Any external enhancement or other             X
                   support, identified in Item
                   1114(a)(1) through (3) or Item 1115 of
                   Regulation AB, is maintained as set
1122(d)(4)(xv)     forth in the transaction agreements.



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Footnotes to Exhibit A Servicing Criteria

<FN>
i.     The servicer performs all of the criterion 1122(d)(2)(i) except for the lockbox, payoff, and exception
       functions, which are specific, limited activities.
ii.    The Vendor performs only the lockbox, payoff, and exception functions for criterion 1122(d)(2)(i).
iii.   The servicer under criterion 1122(d)(2)(ii) makes authorized disbursements on behalf of an obligor for
       escrowed amounts and to investors and/or the paying agent for their disbursement to investors.
iv.    Under criterion 1122(d)(2)(ii), in specific, limited instances the tax and insurance monitoring Vendors
       make disbursements on behalf of an obligor.
v.     The paying agent (another party participating in the servicing function for which the servicer is not the
       responsible party) makes authorized disbursements to investors.
vi.    The servicer prepares and ships the required loan documents to the Vendor that performs the custodian
       function.
vii.   The Vendor performs the custodian function.
viii.  The servicer prepares and ships the required loan documents to the Vendor that performs the custodian
       function.
ix.    The Vendor performs the custodian function.
x.     The servicer performs all of the criterion 1122(d)(4)(iv) except for the lockbox, payoff, and exception
       functions, which are specific, limited activities.
xi.    The Vendor performs only the lockbox, payoff, and exception functions for criterion 1122(d)(4)(iv).
xii.   The servicer performs all of the functions under criterion 1122(d)(4)(x) except for specific, limited tax
       and insurance monitoring activity performed by Vendors.
xiii.  The Vendors perform specific, limited tax and insurance monitoring functions for criterion
       1122(d)(4)(x).
xiv.   The servicer performs all of the functions under criterion 1122(d)(4)(xi) except for specific, limited tax
       and insurance monitoring activity performed by Vendors.
xv.    The Vendors perform specific, limited tax and insurance monitoring functions for criterion
       1122(d)(4)(xi).
xvi.   The servicer performs all of the functions under criterion 1122(d)(4)(xii) except for specific, limited
       tax and insurance monitoring activity performed by Vendors.
xvii.  The Vendors perform specific, limited tax and insurance monitoring functions for criterion
       1122(d)(4)(xii).
xviii. The servicer performs all of the functions under criterion 1122(d)(4)(xiii) except for specific, limited
       tax and insurance monitoring activity performed by Vendors.
xix.   The Vendors perform specific, limited tax and insurance monitoring functions for criterion
       1122(d)(4)(xiii).
</FN>
</TABLE>


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Exhibit B

1. Material instances of noncompliance by the Servicer.

A. Regulation AB Item - 1122(d)(1)(ii) - In certain instances, the Servicer did
   not comply with policies and procedures that the Servicer instituted to
   monitor the performance of third parties to which material servicing
   activities were outsourced by the Servicer.

B. Regulation AB Item - 1122(d)(4)(vii) - In certain instances, the Servicer
   did not initiate, conduct, and conclude loss mitigation or recovery actions
   (e.g., forbearance plans, modifications and deeds in lieu of foreclosure,
   foreclosures and repossessions, as applicable) in accordance with the
   timeframes or other requirements established by the transaction agreements.

2. Servicer's commentary regarding material instances of noncompliance.

A. Regulation AB Item - 1122(d)(1)(ii) - Third Party Servicing

   An internal review identified noncompliance with the Servicer's policies and
   procedures related to the oversight of third parties to which material
   servicing activities were outsourced in the areas of customer data security,
   continuity of business plans, and performance monitoring. The Servicer has
   developed a robust third party oversight program and is committed to its
   ongoing management of vendors. At the time of the review, the Servicer was
   in the process of implementing additional quality control and control
   testing to ensure that all of the identified items were appropriately
   reviewed. Further, a number of other recommendations have been implemented
   as of December 31, 2012 and any remaining items continue to be tracked
   through opened corrective action plans and are on target for completion on
   or before November 30, 2013.

B. Regulation AB Item - 1122(d)(4)(vii) - Actions related to loss mitigation or
   recovery

   Internal reviews identified noncompliance with timeframes and other
   requirements established by the transaction agreements. The noncompliance
   related to bankruptcies was in the areas of adherence to U.S. Federal
   Bankruptcy Code timelines, including proof of claims filings; late removal
   of accounts from bankruptcy status; bankruptcy processing controls; and
   bankruptcy technology risk assessment. The noncompliance related to real
   estate related to noncompliance with the Servicer's policies and procedures
   related to fraud and AML prevention, legal and regulatory requirements, and
   REO strategies. Many of the corrective action plans associated with these
   reviews have been completed and the remaining plans are targeted for
   completion by September 30, 2013.