Exhibit 34.1
 REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM




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Santander
    
    
    
    
    
    UPFC(Applicable
    
    
    
    
    
    (Applicable
    
    Citi (ApplicableReg AB
    
    Relevant Servicing Criteria / General
    
    Yes/No)
    
    HSBC (Applicable Yes/No)
    
    Yes/No)
    
    Yes/No)Criteria #
    
    Servicing Considerations
    
    (1)
    
    (2)
    
    (3)
    
    (4)1/1/2010 -
    
    8/27/2010 -
    
    3/13/2010 -
    
    5/10/2010 -
    
    9/3/2010 -12/31/2010
    
    12/31/2010
    
    8/26/2010
    
    12/31/2010
    
    12/31/2010Servicing Criteria  General Servicing Considerations(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.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(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.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(d) (1) (iii)
    
    Any requirements in the transaction
agreements to maintain a back-up
servicer for the pool assets are
maintained.
    
    Yes
    
    Yes
    
    N/A
    
    Yes
    
    Yes(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.
    
    Yes
    
    Yes
    
    Yes
    
    Yes
    
    YesCash Collection and Administration(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 of receipt, or
such other number of days specified
in the transaction agreements.
    
    Yes
    
    Yes
    
    Yes
    
    Yes
    
    Yes(d) (2) (ii)
    
    Disbursements made via wire transfer
on behalf of an obligor or to an
investor are made only by authorized
personnel.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(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.
    
    N/A
    
    N/A
    
    N/A
    
    N/A
    
    N/A(d) (2) (iv)
    
    The related accounts for the
transaction, such as cash reserve
accounts or accounts established as
a form of over collateralization,
are separately maintained (e.g. with
respect to commingling of cash) as
set forth in the transaction
agreements.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes




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Santander
    
    
    
    
    
    UPFC(Applicable
    
    
    
    
    
    (Applicable
    
    Citi (ApplicableReg AB
    
    Relevant Servicing Criteria / General
    
    Yes/No)
    
    HSBC (Applicable Yes/No)
    
    Yes/No)
    
    Yes/No)Criteria #
    
    Servicing Considerations
    
    (1)
    
    (2)
    
    (3)
    
    (4)1/1/2010 -
    
    8/27/2010 -
    
    3/13/2010 -
    
    5/10/2010 -
    
    9/3/2010 -12/31/2010
    
    12/31/2010
    
    8/26/2010
    
    12/31/2010
    
    12/31/2010(d) (2) (v)
    
    Each custodial account is maintained
at a federally insured depository
institution as set forth in the
transaction agreements. For
purposes of the criterion,
federally insured depository
institution with respect to a
foreign financial institution means
a foreign financial institution that
meets the requirements of
§240.13k-1(b)(1) of this chapter.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(d) (2) (vi)
    
    Unissued checks are safeguarded so
as to prevent unauthorized access.
    
    N/A
    
    N/A
    
    N/A
    
    N/A
    
    N/A(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. The
reconciliations:
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(d) (2) (vii.A)
    
    The reconciliations are
mathematically accurate.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(d) (2) (vii.B)
    
    The reconciliations are prepared
within 30 calendar days after the
bank statement cutoff date, or such
other number of days specified in
the transaction agreements.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(d) (2) (vii.C)
    
    The reconciliations are reviewed and
approved by someone other than the
person who prepared the
reconciliation.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(d) (2) (vii.D)
    
    The reconciliations contain
explanations for any 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.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    YesInvestor Remittances and Reporting(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:(d) (3) (i.A)
    
    The reports are prepared in
accordance with timeframes and other
terms set forth in the transaction
agreements.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(d) (3) (i.B)
    
    The reports provide information
calculated in accordance with the
terms specified in the transaction
agreements.
    
    Yes
    
    No
    
    No
    
    Yes
    
    Yes(d) (3) (i.C)
    
    The reports are filed with the
commission as required by its rules
and regulations.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes




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##### 



Santander
    
    
    
    
    
    UPFC(Applicable
    
    
    
    
    
    (Applicable
    
    Citi (ApplicableReg AB
    
    Relevant Servicing Criteria / General
    
    Yes/No)
    
    HSBC (Applicable Yes/No)
    
    Yes/No)
    
    Yes/No)Criteria #
    
    Servicing Considerations
    
    (1)
    
    (2)
    
    (3)
    
    (4)1/1/2010 -
    
    8/27/2010 -
    
    3/13/2010 -
    
    5/10/2010 -
    
    9/3/2010 -12/31/2010
    
    12/31/2010
    
    8/26/2010
    
    12/31/2010
    
    12/31/2010(d) (3) (i.D)
    
    The reports agree with investors or
the trustee records as to the total
unpaid principal balance and number
of pool assets serviced by the
servicer.
    
    Yes
    
    Yes
    
    N/A
    
    Yes
    
    Yes(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.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(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.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(d) (3) (iv)
    
    Amounts remitted to investors per
the investor reports agree with
cancelled checks, or other form of
payment, or custodial bank
statement.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    YesPool Asset Administration(d) (4) (i)
    
    Collateral or security on pool
assets is maintained as required by
the transaction agreements or
related pool asset documents.
    
    Yes
    
    Yes
    
    Yes
    
    Yes
    
    Yes(d) (4) (ii)
    
    Pool assets and related documents
are safeguarded as required by the
transaction agreements.
    
    N/A
    
    N/A
    
    N/A
    
    N/A
    
    N/A(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.
    
    Yes
    
    Yes
    
    No
    
    Yes
    
    Yes(d) (4) (iv)
    
    Payments on pool assets, including
payoffs, made in accordance with the
related pool asset documents are
posted to the applicable 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.
    
    Yes
    
    Yes
    
    Yes
    
    Yes
    
    Yes(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.
    
    Yes
    
    Yes
    
    Yes
    
    Yes
    
    Yes(d) (4) (vi)
    
    Changes with respect to the terms or
status of an obligors pool asset
(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.
    
    Yes
    
    Yes
    
    Yes
    
    Yes
    
    Yes




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##### 



Santander
    
    
    
    
    
    UPFC(Applicable
    
    
    
    
    
    (Applicable
    
    Citi (ApplicableReg AB
    
    Relevant Servicing Criteria / General
    
    Yes/No)
    
    HSBC (Applicable Yes/No)
    
    Yes/No)
    
    Yes/No)Criteria #
    
    Servicing Considerations
    
    (1)
    
    (2)
    
    (3)
    
    (4)1/1/2010 -
    
    8/27/2010 -
    
    3/13/2010 -
    
    5/10/2010 -
    
    9/3/2010 -12/31/2010
    
    12/31/2010
    
    8/26/2010
    
    12/31/2010
    
    12/31/2010(d) (4) (vii)
    
    Loss mitigation or recovery actions
(e.g. forbearance plans,
modifications and deeds in lieu of
foreclosures and repossession, as
applicable) are initiated, conducted
and concluded in accordance with the
timeframes or other requirements
established by the transaction
agreements.
    
    Yes
    
    Yes
    
    Yes
    
    Yes
    
    Yes(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).
    
    Yes
    
    Yes
    
    Yes
    
    Yes
    
    Yes(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.
    
    N/A
    
    N/A
    
    N/A
    
    N/A
    
    N/A(d) (4) (x)
    
    Regarding any funds held in trust
for an obligor (such as escrow
accounts):(d) (4) (x.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.
    
    N/A
    
    N/A
    
    N/A
    
    N/A
    
    N/A(d) (4) (x.B)
    
    Interest on such funds is paid, or
credited, to obligors in accordance
with applicable pool asset documents
and state laws.
    
    N/A
    
    N/A
    
    N/A
    
    N/A
    
    N/A(d) (4) (x.C)
    
    Such funds are returned to the
obligor within 30 calendar days of
full repayment of the related pool
asset, or such other number of days
specified in the transaction
agreements.
    
    N/A
    
    N/A
    
    N/A
    
    N/A
    
    N/A(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.
    
    N/A
    
    N/A
    
    N/A
    
    N/A
    
    N/A




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##### 



Santander
    
    
    
    
    
    UPFC(Applicable
    
    
    
    
    
    (Applicable
    
    Citi (ApplicableReg AB
    
    Relevant Servicing Criteria / General
    
    Yes/No)
    
    HSBC (Applicable Yes/No)
    
    Yes/No)
    
    Yes/No)Criteria #
    
    Servicing Considerations
    
    (1)
    
    (2)
    
    (3)
    
    (4)1/1/2010 -
    
    8/27/2010 -
    
    3/13/2010 -
    
    5/10/2010 -
    
    9/3/2010 -12/31/2010
    
    12/31/2010
    
    8/26/2010
    
    12/31/2010
    
    12/31/2010(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.
    
    N/A
    
    N/A
    
    N/A
    
    N/A
    
    N/A(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.
    
    N/A
    
    N/A
    
    N/A
    
    N/A
    
    N/A(d) (4) (xiv)
    
    Delinquencies, charge offs and
uncollectible accounts are
recognized and recorded in
accordance with the transaction
agreements.
    
    Yes
    
    Yes
    
    Yes
    
    Yes
    
    Yes(d) (4) (xv)
    
    Any external enhancement or other
support, identified in Item
1114(a)(1) through (3) or Item 1115
of this Regulation AB, is maintained
as set forth in the transaction
agreements.
    
    Yes
    
    Yes
    
    N/A
    
    Yes
    
    Yes
  (1)
    
    Santander : SDART 2006-1, 2006-2, 2007-1, 2007-2, 2007-3, 2010-1, 2010-2, 2010-A,
2010-H, 2010-3, 2010-B, Triad 2006-A, 2006-B, 2006-C, 2007-A, 2007-B(2)
    
    HSBC: HSBC 2006-1, 2006-2, 2006-3, 2007-1(3)
    
    UPFC: 2006-A, 2006-B, 2007-A, 2007-B(4)
    
    Citi: CAIT 2009-1