|Assessment
Regarding Compliance with Applicable Servicing Criteria
|------------------------------------------------------------------







|1. | Bank of America,
National Association (the “Servicer”) is responsible for assessing its
compliance as of the dates listed in Appendix B hereto and for the
periods then ended (the “Reporting Periods”) with the servicing
criteria applicable to it under paragraph (d) of Item 1122 of
Regulation AB as set forth in Appendix A hereto, in connection with the
asset-backed securities transactions listed in Attachment B hereto
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”);
|-- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



|2. | The Servicer has
engaged a certain vendor (the “Vendor”) to perform certain specific,
limited or scripted activities during the Reporting Periods, 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). The Servicer has elected to take responsibility for
assessing compliance with the portion of the servicing criteria
performed by such Vendor;
|-- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



|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 (or
portions of criteria) denoted as inapplicable in Appendix A hereto 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 Periods with respect to the Platform;
|-- | ---------------------------------------------------------------------------------------------------------------------------------------------------



|6. | The Servicer has
not identified and is not aware of any material instance of
noncompliance by the Vendor with the applicable servicing criterion for
the Reporting Periods 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 Vendor with the applicable servicing
criterion for the Reporting Periods with respect to the Platform; and
|-- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



|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 the dates listed in Appendix B
hereto and for the Reporting Periods.
|-- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------









|February 28, 2014
|-----------------





| | BANK OF AMERICA,
NATIONAL ASSOCIATION
| | -------------------------------------



| | /s/ Robert Cox   | 
| | ---------------- | 
| | Name: Robert Cox | 
| | Title: Director  | 

---



|APPENDIX
A
|----------



|Definitions:                                                                     
|---------------------------------------------------------------------------------
|X – Servicing
criterion is applicable to the Servicer’s activities performed.    
|N/A – Servicing
criterion is inapplicable to the Servicer’s activities performed.





|Servicing
Criteria | Applicable                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          
|------------------ | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|                   | Servicing
Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  
|Reference          | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            
|                   | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                
|1122(d)(1)(iii)    | Any requirements
in the transaction agreements to maintain a back-up servicer for the
pool assets 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.                                                                                                                                                                                                                                                                                                                                                                                                                                   
|                   | Cash
Collection and Administration                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  
|1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                       
|1122(d)(2)(ii)     | Disbursements
made via wire transfer on behalf of an obligor or to an investor are
made only by authorized personnel.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                           
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                               
|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.                                                                                                                                                                                                                                                                                                                     
|1122(d)(2)(vi)     | Unissued checks
are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               
|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.
|                   | 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 pool assets 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 pool assets is maintained as required by the transaction
agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|1122(d)(4)(ii)     | Pool assets 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         
|1122(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.                                                                                                                                                                                                                                                                                        
|1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           
|1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                             
|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.                                                                                                                                                                                                                                                                                                                                                                                              
|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 pool assets including, for
example, phone calls, letters and payment rescheduling plans in cases
where delinquency is deemed temporary (e.g., illness or unemployment).                                                                                                                                                                                      
|1122(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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|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 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
asset, or such other number of days specified in the transaction
agreements.                                                                                                                
|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.                                                                                                                                                                                                                                                                                                     
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                 
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           
|1122(d)(4)(xiv)    | Delinquencies,
charge-offs and uncollectible accounts are recognized and recorded in
accordance with the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       



|[1] A
vendor performs only the lockbox function for criterion 1122(d)(2)(i).
The company takes responsibility for the vendor’s compliance with this
criterion.                                
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|[2] The
vendors CoreLogic, Inc. and National Tax Search, LLC, provided separate
Regulation AB 1122(d)attestations for their tax payment activities as
they relate to criterion 1122(d)(4)(xi).

---







|APPENDIX
B
|----------



|Company’s
Role as Master Servicer
|---------------------------------
|Transaction                      
|BACM 2006-1                      
|BACM 2006-2                      
|BACM 2006-3                      
|BACM 2006-4                      
|BACM 2006-5                      
|BACM 2006-6                      
|BACM 2007-1                      
|BACM 2007-2                      
|BACM 2007-3                      
|BACM 2007-4                      
|BACM 2007-5                      
|BACM 2008-1                      
|BACM 2008-LS1                    
|BALL 2006-277
PARK Ave MZ        
|BALL 2006-BIX1                   
|BALL 2007-BMB1                   
|BALL 2009-FDG                    
|BAMLL 2012-PARK                  
|BAMLL TRUST
2011-FSHN            
|BAMLL-DB
2012-OSI                
|BSCMSI
2006-BBA7                 
|BSCMSI
2006-BBA7                 
|CFCRE 2011-C2                    
|FREMF 2012-K19                   
|FREMF 2012-K22                   
|FREMF 2012-K501                  
|FREMF 2012-K502                  
|FREMF 2013-K705                  
|GECMC 2007-C1
(MASTER)           
|MLMT 2008-C1                     
|MSCIT 2011-C1                    
|MSC 2011-C2                      
|MSC 2012-C4                      
|MSC 2012-C5                      
|GSMSCII
2007-EOP                 
|MLFT 2008-LAQ                    
|Transaction                      
|BACM 2006-1                      
|BACM 2006-2                      
|BACM 2006-3                      
|BACM 2006-4                      
|BACM 2006-5                      
|BACM 2006-6                      
|BACM 2007-1                      
|BACM 2007-2                      
|BACM 2007-3                      
|BACM 2007-4                      
|BACM 2007-5                      
|BACM 2008-1                      
|BACM 2008-LS1                    
|BALL 2006-277
PARK Ave MZ        
|BALL 2006-BIX1                   
|BALL 2007-BMB1                   
|BALL 2009-FDG                    
|BAMLL 2012-PARK                  
|BAMLL TRUST
2011-FSHN            
|BAMLL-DB
2012-OSI                
|BSCMSI
2006-BBA7                 
|BSCMSI
2007-BBA8                 
|CFCRE 2011-C2                    
|CGCMT 2006-FL2                   
|COMM 2006-FL12                   
|COMM 2006-C7                     
|COMM 2006-C8                     
|COMM 2012-CCRE1                  
|DBUBS 2011-LC3                   
|FREMF 2012-K19                   
|FREMF 2012-K22                   
|FREMF 2012-K501                  
|FREMF 2012-K705                  
|FREMF 2013-K502                  
|GECMC 2006-C1                    
|GECMC 2007-C1
(MASTER)           
|GECMC 2007-C1
(PRIMARY)          
|GSMSCII
2007-EOP                 
|JPMorgan
2007-LDP10              
|MLFT 2008-LAQ                    
|MLMT 2008-C1                     
|MSC 2011-C2                      
|MSC 2011-C3                      
|MSC 2012-C4                      
|MSCIT 2011-C1                    
|UBS-BB 2013-C5                   
|WACHOVIA
2007-C31                
|WACHOVIA
2007-C33                
|WACHOVIA
2007-C34                
|WFCM 2010-C1                     
|Transaction                      
|BALL 2006-BIX1                   
|BALL 2007-BMB1                   
|BALL 2009-FDG                    
|BAMLL 2012-PARK                  
|BSCMSI
2006-BBA7                 
|BSCMSI
2007-BBA8                 
|GSMSCII
2007-EOP                 
|MLFT 2008-LAQ                    
|WBCMT-2007
Whale8