Assessment Regarding Compliance with Applicable Servicing Criteria  

1.

Bank  of  America,  National  Association  (the  "Servicer")  is  responsible  for  assessing  compliance  

with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of 

December  31,  2012 
and for the period from January 1, 2012 through December 31, 2012 (the

****

****

"Reporting Period"), as set forth in Appendix A hereto, in connection with asset-backed securities 

transactions  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  engaged  certain  vendors,  which  are  not  servicers  as  defined  in  Item  1101(j)  of  

Regulation AB  (the  "Vendors")  to  perform  certain  specific,  limited  or  scripted  activities  and  the 

Servicer elects to take responsibility for assessing compliance with the servicing criteria or portion 

of the servicing criteria applicable to the Vendors' activities as set forth in Appendix A hereto; 

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 listed in the column titled "Inapplicable Servicing Criteria" on Appendix A hereto are  

inapplicable  to  the  Servicer  based  on  the  activities  it  performs,  directly  or  through  its  Vendors, 

with respect to the Platform; 

5.

The  Servicer  has  complied,  in  all  material  respects,  with  the  applicable  servicing  criteria  for  the  

Reporting Period with respect to the Platform taken as a whole; 

6.

The Servicer has not identified and is not aware of any material instance of noncompliance by the  

Vendors with the applicable servicing criteria for the Reporting Period with respect to the Platform 

taken as a whole; 

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 for the Reporting Period with 

respect to the Platform taken as a whole; 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 December 31, 2012 and for the Reporting Period. 

February 22, 2013 

BANK OF AMERICA, NATIONAL ASSOCIAION 

By: /s/ Dean Roberson  

     Name: Dean Roberson   

      Title:   Director 

-   2   -  

**APPENDIX A**

**SERVICING CRITERIA**

**APPLICABLE SERVICING CRITERIA**

**INAPPLICABLE**

**SERVICING CRITERIA**

**Reference**

**Criteria**

**Servicer**

**Vendor**

**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. 

X 

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.****

X 

1122(d)(1)(iii) 

Any requirements in the transaction agreements to 

maintain a back-up servicer for the mortgage loans 

are maintained. 

X 

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. 

X 

**Cash Collection and Administration**

1122(d)(2)(i) 

Payments on mortgage loans 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. 

X 

**X**

(only with respect to  

standard lockbox  

processing by  

depositing checks into  

the appropriate  

account indicated by  

the Servicer)****

1122(d)(2)(ii) 

Disbursements made via wire transfer on behalf 

of an obligor or to an investor are made only by 

authorized personnel. 

X  

(other than with  

respect to  

disbursements made to  

investors) 

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. 

X  

(only with respect to  

transactions for which  

the related transaction  

agreements specifically  

required it to advance  

property protection  

expenses or payments  

of interest and/or  

principal) 

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. 

X 

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. 

XX 

1122(d)(2)(vi) 

Unissued checks are safeguarded so as to 

prevent unauthorized access. 

X 

- 3 - 

**SERVICING CRI'TERIA**

**APPLICABLE SERVICING CRITERIA**

**INAPPLICABLE**

**SERVICING CRITERIA**

Reference 

Criteria 

ServicerX 

Vendor 

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 3o 

calendar days after the hank 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 Remittance and Reporting**

1122d)(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 mortgage 

loans serviced by the Servicer. 

X 

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. 

X 

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. 

X 

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. 

X 

**Pool Asset Administration**

**_**

1122(d)(4)(i)1122(d)(4)(ii)

Collateral  or  security  on  mortgage  loans 

is  maintained  as  required  by  the 

transactionagreements or related mortgage loan documents.                               X 

Mortgage loan documents and related documents 

are safeguarded as required by the transaction 

agreements. 

X 

.

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. 

X 

1122(d)(4)(iv) 

Payments on mortgage loans, including any 

payoffs, made in accordance with the related 

mortgage 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 with the 

related mortgage loan documents. 

**X**

1122(d)(4)(v) 

The Servicer's records regarding the mortgage 

loans agree with the Servicer's records with respect 

X 

- 4 -  

**SERVICING CRITERIA**

**APPLICABLE SERVICING CRITERIA**

**INAPPLICABLE**

**SERVICING CRITERIA**

**Reference**

**Criteria**

**Servicer**

**Vendor**

to an obligor's unpaid principal balance. 

1122(d)(4)(vi) 

Changes with respect to the terms or status of 

an obligor's mortgage loans (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 

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. 

X 

1122(d)(4)(viii) 

Records documenting collection efforts are 

maintained during the period a mortgage 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 mortgage loans including, for example, 

phone calls, letters and payment rescheduling 

plans in cases where delinquency is deemed 

temporary (e.g., illness or unemployment). 

X  

(only for the period  

prior to a servicing  

transfer event (as  

defined in the  

transaction  

agreements)) 

1122(d)(4)(ix) 

Adjustments to interest rates or rates of return for 

mortgage loans with variable rates are computed 

based on the related mortgage loan documents. 

X 

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 mortgage 

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; and (C) 

such funds are returned to the obligor within 30****

calendar days of full repayment of the related 

mortgage loans, or such other number of days 

specified in the transaction agreements. 

X 

1122(d)(4)(xi) 

Payments made an 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 

X  

(only with respect to  

verifying outstanding  

tax payments and  

processing such tax  

payments pursuant to  

the Servicer's  

direction) 

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. 

X 

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. 

X 

1122(d)(4)(xiv) 

Delinquencies, charge-offs and uncollectible 

accounts are recognized and recorded in 

accordance with the transaction agreements. 

X 

- 5- 

**SERVICING CRITERIA**

**APPLICABLE SERVICING CRITERIA**

**INAPPLICABLE**

**SERVICING CRITERIA**

**Reference**

**Criteria**

**Servicer**

**Vendor**

1122(d)(4)(xv) 

Any external enhancement or other support, 

identified in Item 1114(a)(1) through (3) or Item 

m of Regulation AB, is maintained as set forth in 

the transaction agreements. 

X  

(only with respect to  

those items identified  

in Item 1114(0W) 

,