Report on Assessment of Compliance with SEC Regulation AB  

Servicing Criteria as Primary Servicer 

Berkadia  Commercial  Mortgage  LLC  ("Berkadia")  is  responsible  for  assessing 

compliance,  as  of  and  for  the  year  ended  December  31,  2012  (the  "Reporting  Period"), 

with the Servicing Criteria set forth in  Item 1122(d) of Regulation AB of the Securities 

and  Exchange  Commission  for  asset-backed  securities  transactions.  This  assertion 

includes  all  commercial  mortgage  loans  sold  in  public  securitizations  from  the  period 

January  1,  2006  through  December  31,  2012  for  which  Berkadia  served  as  primary 

servicer (the "Platform"). 

Berkadia has concluded that the criteria are applicable as shown below (indicated by x) to 

the primary servicing of the loans in the Platform: 

**Regulation AB Criteria 1122(d)**

Primary 

(1) General servicing considerations. 

(i) Policies and procedures are instituted to monitor any performance or other triggers and 

events of default in accordance with the transaction agreements.

X 

(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.

X 

(iii)

Any requirements in the transaction agreements to maintain a back-up servicer for the 

pool assets are maintained. 

Not Applicable 

(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. 

X 

(2) Cash collection and administration. 

 (i)  Payments  on  pool  assets  are  deposited  into  the  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.

X 

(ii)

Disbursements  made  via  wire  transfer  on  behalf  of  an  obligor or to an investor are

made only by authorized personnel. 

X 

(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. 

X 

(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. 

X 

(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  240.13k-1(b)(1) of this chapter. 

X 

(vi)

Unissued checks are safeguarded so as to prevent unauthorized access. 

X 

(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: 

(A)(B)

Are mathematically accurate
Are prepared within 30 calendar days after the bank statement cutoff date, or such other
number of days specified in the transaction agreements;

;

XX 

**Regulation AB Criteria 1122(d)**

Primary 

****

(C) Are  reviewed  and  approved  by  someone  other  than  the  person  who  prepared  the reconciliation; and

X 

(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. 

X 

(3) Investor remittances and reporting. 

(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

;

X 

(B)

Provide  information  calculated  in  accordance  with  the  terms  specified  in  the 

transaction agreements

;

X 

(C)

Are filed with the Commission as required by its rules and regulations; and

Not Applicable 

(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. 

X 

(ii)

Amounts due to investors are allocated and remitted in accordance with timeframes, 

distribution priority and other terms set forth in the transaction agreements. 

X 

(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. 

X 

(iv) Amounts remitted to investors per the investor reports agree with cancelled checks, or 

other form of payment, or custodial bank statements. 

X 

(4) Pool asset administration. 

(i)  Collateral  or  security  on  pool  assets  is  maintained  as required by the transaction

agreements or related pool asset documents. 

X 

(ii)

Pool  assets  and  related  documents  are  safeguarded  as  required  by  the  transaction 

agreements. 

Not Applicable 

(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. 

. 

X 

(iv)

Payments on pool assets, including any 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. 

X 

(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 

(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. 

X 

(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. 

Not Applicable 

**Regulation AB Criteria 1122(d)**

Primary 

(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). 

X 

(ix) Adjustments to  interest  rates or rates of return for pool  assets  with  variable  rates  are 

computed based on the related pool asset documents. 

X 

(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;

X 

(B)

Interest  on  such  funds  is  paid,  or  credited,  to  obligors in accordance with applicable

pool asset documents and state laws; and

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. 

X 

(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. 

X 

(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.

X 

(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. 

X 

(xiv)

Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in 

accordance with the transaction agreements. 

X 

(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. 

Not Applicable 

The Servicing Criteria, after  giving effect to the foregoing exclusions, are referred to as the 

"Applicable Servicing Criteria". 

The  Company  utilizes  vendors  to  support  its  servicing  operations,  including  the  use  of  a
commercial tax service which supports our assertions under 1122(d)(4)(xi) through (xiii) and theuse  of  a  lien  filing  firm  to  support  our  assertion  under  1122(d)(4)(i).  This  vendor  activitycontributes to the servicing activities to which we are asserting. In all cases, the vendors' activitiesare limited,  and the Company  assumes  responsibility  for the 1122  assessment  for these vendoractivities. These vendors do not fit the definition of servicer under Item 1101(j), and the Companyemploys policies and procedures designed to provide assurance that the vendors' activities complywith the Applicable Servicing Criteria to such vendors.

For the Reporting Period, Berkadia has assessed its compliance with the Applicable Servicing 

Criteria for the transactions and has concluded that its servicing operation has complied, in all 

material respects, with the Applicable Servicing Criteria. 

Grant Thornton LLP, an independent registered public accounting firm, has issued an attestation 

report on management's assertion of compliance with the Applicable Servicing Criteria. 

Berkadia Commercial Mortgage LLC 

February 28, 2013 

/s/ Mark E. McCool 

Mark E. McCool 

Executive Vice President 

Head of Servicing Berkadia Commercial Mortgage LLC