**Exhibit 33.1                                                                                                            Appendix I****MANAGEMENT'S ASSERTION OF COMPLIANCE******Management of the Trust & Securities Services department of Deutsche Bank National****Trust Company and Deutsche Bank Trust Company Americas (collectively the "Company") is responsible for assessing compliance with the servicing criteria set forth in item 1122(d) of Regulation AB promulgated by the Securities and Exchange Commission. Management has determined that the servicing criteria are applicable in regard to the servicing platform for the period as follows:  Platform: Publicly-issued *(i.e.,*transaction-level reporting required under the Securities Exchange Act of 1934, as amended) residential mortgage-backed securities and other asset-backed securities issued on or after January 1, 2006 for which the Company provides trustee, securities administration or paying agent services, excluding any publicly issued transactions sponsored or is sued by any government sponsored entity (the "Platform").  Applicable Servicing Criteria : All servicing criteria set forth in Item 1122(d), except for the following criteria:  I l22(d)(2)(iii), I 122(d)(4)(iv), I 122(d)(4)(v), I 122(d)(4)(vi), I 122(d)(4)(vii), I 122(d)(4)(viii), I 122(d)(4)(ix), I 122(d)(4)(x), I 122(d)(4)(xi), I 122(d)(4)(xii), I l22(d)(4)(xiii) and I 122(d)(4)(xiv), which management has determined are not applicable to the activities the Company performs with respect to the Platform (the "Applicable Servicing Criteria").  Period: Twelve months ended December 31, 2006 (the "Period"). Management's interpretation of Applicable Servicing Criteria : The Company's management has determined that servicing criteria I l22 (d)(1)(iii) is applicable only with respect to its continuing obligation to act as, or locate a, successor servicer under the circumstances referred to in certain governing documents. It is management's interpretation that Deutsche Bank Trust Company America has no other active back-up servicing responsibilities in regards to I 122(d)(l)(iii) as of and for the Period. Third parties classified as vendors : With respect to servicing criteria I I22(d)(2)(i), I l22(d)(4)(i), and I l22(d)(4)(ii), management has engaged various vendors  to perform the activities required by these servicing criteria. The Company's management has determined that these vendors are not considered a "servicer" as defined in Item 1101(j) of Regulation AB. and the Company'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 asserted that it has policies and procedures in place to provide reasonable assurance that the vendor's activities comply in all material respects with the servicing criteria applicable to each vendor. The Comp any's management is solely responsible for determining that it meets the SEC requirements to apply Interpretation 17.06 for the vendors and related criteria. With respect to the Platform, the Company's management provides the following assertion of compliance with respect to the Applicable Servicing Criteria: 1.  The Company's management is responsible for assessing the Company's compliance with the Applicable Servicing Criteria as of and for the Period.  2.  The Company's management has assessed compliance with the Applicable Servicing Criteria, including servicing criteria for which compliance is determined based on Interpretation 17.06 as described above, as of and for the Period. In performing this assessment, management used the criteria set forth by the Securities and Exchange Commission in paragraph (d) of item 1122 of Regulation AB.  3. Based on such assessment, as of and for the Period, the Company has complied, in all material respects, with the Applicable Servicing Criteria.   KPMG LLP, a registered public accounting firm, has issued an attestation report with respect to the management's assertion of compliance with the Applicable Servicing Criteria as of and for the Period. ******Appendix I******By: /s/ Gary R. Vaughan Name: Gary R. Vaughan Its: Managing Director By: /s/ David Co Name: David Co Its: Director By: /s/ Jose Sicilia Name: Jose Sicilia  Its: Managing Director By: /s/ Kevin Fischer Name: Kevin Fischer Its: Vice President By: /s/ Robert Frier Name: Robert Frier Its: Director  DEUTCHE BANK TRUST COMPANY AMERICAS By: /s/ Kevin C. Weeks Name: Kevin C. Weeks Its: Managing Director By: /s/ Jonna Kaufman Name: Jonna Kaufman Its: Director **Exhibit 33.2****Management's Assertion Report on Compliance with Applicable Servicing Criteria Pursuant to Item 1122****of Regulation AB under the Securities Exchange Act of 1934****U.S. Bank National Association ("U.S. Bank") as a party participating in the  servicing function for the following transactions:  U.S. Bank Corporate Trust Asset Backed Securities Platform hereby provides the following report on its assessment of compliance with the  servicing criteria set forth in Item 1122 of Regulation AB applicable to it  and as described on Exhibit A hereto: 1.****U.S. Bank is responsible for assessing its compliance with the********servicing criteria applicable to it as noted on the accompanying********Exhibit A;****2.****U.S. Bank used the criteria set forth in paragraph (d) of Item 1122********of Regulation AB to assess its compliance with the applicable********servicing criteria;****3.****U.S. Bank's assessment of its compliance with the applicable********servicing criteria is as of and for the period beginning on********January 1, 2006 and ending December 31, 2006, the end of the fiscal********year covered by the Form 10-K report. U.S. Bank's participation in********the servicing function complied in all material respects****with the applicable servicing criteria.********4.****Ernst & Young, a registered public accounting firm, has issued an********attestation report on U.S. Bank's assessment of compliance with the********applicable servicing criteria as of and for the period beginning on********January 1, 2006 and ending December 31, 2006, the end of the fiscal********year covered by the Form 10-K report.************U.S. BANK NATIONAL ASSOCIATION****/s/ Bryan R. Calder********Name:  Bryan R. Calder************Title: Executive Vice President********Date:  February 26, 2007********EXHIBIT A to Management's Assertion Reg AB Reference  Servicing 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.********************************Not Applicable********1122(d)(1)(iv)****A fidelity bond and errors and omissions po licy 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****************over collateralization, 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 maintaine d 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, inc luding 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.********************************Not Applicable****1122(d)(4)(ii)****Pool assets  and related documents are safeguarded as****************required by the transaction agreements****************Not Applicable********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 tra nsaction agreements,****************and allocated to principal, interest or other items****************(e.g., escrow) in accordance with the related pool****************asset documents.************************************Not Applicable****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.****************************Not Applicable****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.************************Not Applicable****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.****************************Not Applicable********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).************************Not Applicable********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.****************************Not Applicable********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 agre ements; (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 assets, or such other****************number of days specified in the transaction agreements.****************Not Applicable********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.************************Not Applicable********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.************************Not Applicable********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.****************Not Applicable********1122(d)(4)(xiv)****Delinquencies, charge-offs and uncollectible accounts****************are recognized and recorded in accordance with the****************transaction agreements.****************Not Applicable********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.************Exhibit 33.3****Wells Fargo Bank, N.A.********2006 Certification Regarding Compliance with Applicable Servicing Criteria******1. Wells Fargo Bank, N.A. (the "Servicer") is responsible for assessing its compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB as set forth in Exhibit A hereto in connection with the primary servicing of residential mortgage loans by its Wells Fargo Home Mortgage division,  other than the servicing of such loans for Freddie Mac, Fannie Mae, Ginnie Mae,  state and local government bond programs,  or a Federal Home Loan Bank (the servicing "Platform"); 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, 2006, and the Servicer  has elected to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such Vendors as set forth in Exhibit A hereto, with the exception of those Vendors that have provided their own report on assessment of compliance with servicing criteria, which reports are attached hereto as Exhibit D;  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 identified as Inapplicable Servicing Criteria on Exhibit A hereto are inapplicable to the Servicer based on the activities it performs with respect to its Platform; 5. The Servicer has complied, in all material respects, with the applicable servicing criteria as of and for the year ended December 31, 2006, 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, 2006; 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 year ended December 31, 2006;****and 8. KPMG LLP, a registered public accounting firm, has issued an attestation report on the Servicer's assessment of compliance with the applicable servicing criteria as of and for the year ended December 31, 2006, which attestation report is included on Exhibit C attached hereto. March 1, 2007 WELLS FARGO BANK, N.A. By: /s/: Mary C. Coffin Mary C. Coffin Executive Vice President**EXHIBIT A****to****Wells Fargo Bank, N.A.'s****2006 Certification Regarding Compliance With Applicable Servicing Criteria****Servicing Criteria****Applicable Servicing****Criteria****Inapplicable****Servicing****Criteria****Reference****Criteria****Performed****by****Servicer****Performed****by****Vendor(s)********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.  X1122(d)(1)(iii) Any requirements in the transaction agreements to maintain a back-up servicer for the mortgage loans are maintained.  X1122(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.  X1X21122(d)(2)(ii) Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.  X1122(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.  X1122(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.  X1122(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.  X1122(d)(2)(vi) Unissued checks are safeguarded so as to prevent unauthorized access.  X3X41 A portion of this servicing criteria is performed by a vendor, as set forth in footnote 2 below. 2 A lockbox vendor receives payments, creates transaction files, deposit s checks, reconciles files to deposits and transmits the transaction files to Wells Fargo. See Exhibit D. 3 A portion of this servicing criteria is performed by vendors, as set forth in footnote 4 below. 4 Insurance vendors prepare and safeguard checks on behalf of Wells Fargo. As to one such vendor, see Exhibit D. **Servicing Criteria****Applicable Servicing****Criteria****Inapplicable****Servicing****Criteria****Reference****Criteria****Performed****by****Servicer****Performed****by****Vendor(s)**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.  X**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 mortgage loans serviced by the Servicer.  X1122(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.  X1122(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.  X1122(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)  Collateral or security on mortgage loans is maintained as required by the transaction agreements or related mortgage loan documents.  X1122(d)(4)(ii) Mortgage loan and related documents are safeguarded as required by the transaction agreements. X1122(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.  X1122(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.  X5X61122(d)(4)(v) The Servicer's records regarding the mortgage loans agree with the Servicer's records with respect to an obligor's unpaid principal balance.  X1122(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.  X5 A portion of this servicing criteria is performed by a vendor, as set forth in footnote 6 below. 6 A lockbox vendor receives payments, creates transaction files, deposit s checks, reconciles files to deposits and transmits the transaction files to Wells Fargo. See Exhibit D.**Servicing Criteria****Applicable Servicing****Criteria****Inapplicable****Servicing****Criteria****Reference****Criteria****Performed****by****Servicer****Performed****by****Vendor(s)**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.  X1122(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).  X1122(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.  X1122(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.  X1122(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.  X7X81122(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.  X1122(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.  X9X101122(d)(4)(xiv)  Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.  X1122(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.  X****7 A portion of this servicing criteria is performed by vendors, as set forth in footnote 8 below. 8 Insurance vendors obtain renewal invoices, create disbursement transactions and submit payments to payees. As to one such vendor, see Exhibit D. 9 A portion of this servicing criteria is performed by one or more vendors, as set forth in footnote 10 below. 10 Insurance vendors obtain renewal invoices, create disbursement transactions and submit payments to payees. As to one such vendor, see Exhibit D. **EXHIBIT B****to****Wells Fargo Bank, N.A.'s****2006 Certification Regarding Compliance With Applicable Servicing Criteria**Wells Fargo Bank, N.A. ("Wells Fargo") acknowledges the following material instances of non-compliance with the applicable servicing criteria: 1.1122(d)(3)(i) - Delinquency Reporting  For certain loans sub-serviced by Wells Fargo or for which servicing rights were acquired on a bulk-acquisition basis, Wells Fargo determined that it provided  incomplete data to some third parties who use such data to calculate delinquency ratios and determine the status of loans with respect to bankruptcy, foreclosure or real estate owned.****The incomplete reporting only affected securitizations that included delinquent loans.  Instead of the actual due date being  provided for use in calculating delinquencies, the date of the first payment due to the security was  provided.  Wells Fargo  subsequently included additional data in the monthly  remittance  reports, providing the actual borrower due date and unpaid principal balance, together with instructions  to use these new fields if  such  monthly remittance reports are used to calculate delinquency ratios. 2.1122(d)(4)(vii) - Notification of Intent to Foreclose  Wells Fargo determined that, as required by certain servicing agreements, it did not provide investors with prior notification of intent to foreclose.  While investors received monthly delinquency status reports that listed loans in foreclosure, such reports were received after  such  loans had been referred to an attorney.  A new process is being implemented to send such notifications if contractually required, unless an investor opts out in writing. **EXHIBIT C****to****Wells Fargo Bank, N.A.'s****2006 Certification Regarding Compliance With Applicable Servicing Criteria**Report of Independent Registered Public Accounting Firm **EXHIBIT D****to****Wells Fargo Bank, N.A.'s****2006 Certification Regarding Compliance With Applicable Servicing Criteria**Vendors' Reports on Assessment of Compliance With  Servicing CriteriaExhibit 33.4 REGULUS  **Report on Assessment of Compliance with Regulation AB Servicing Criteria**1.Pursuant to Subpart 229.1100- Asset Backed Securities, 17 C.F.R. 229.1100-  229.1123 ("Regulation AB"), Regulus Group LLC, for itself and its wholly-owned subsidiaries (in dividually and collectively "Regulus"), is responsible for**assessing its compliance with the servicing criteria applicable to the remittance processing services it provides to customers who are issuers or servicers of asset backed securities transactions and who have requested confirmation of Regulus' compliance in connection with loan and/or receivables portfolios that include pool assets for asset backed securities transactions (the "Platform"). Remittance processing is a service whereby check payments that are remitted by mail to a post office box are collected, processed though a highly automated data capture system, and prepared for deposit to a bank account held by the beneficiary of the payment. 2.The servicing criteria set forth in Item 1122(d) of Regulation AB were used in Regulus' assessment of compliance. Regulus has concluded that the servicing criteria set forth in Items 1122(d)(2)(i) and 1122(d)(4)(iv) of Regulation AB are applicable to the servicing activities it performs with respect to the Platform (such criteria the "Applicable Servicing Criteria"). Regulus has concluded that the remainder of the servicing criteria set forth in Item 1122(d) of Regulation AB are inapplicable to the activities it performs with respect to the Platform because Regulus does not participate in the servicing activities referenced by such servicing criteria.  3.As of and for the year ending December 31, 2006, Regulus has complied in all material respects with the Applicable Servicing Criteria set forth in Item 1122(d) of Regulation AB.  4.KPMG LLP, a registered public accounting firm, has issued an attestation report on Regulus' assessment of compliance with the Applicable Servicing Criteria as of and for the year ending December 31, 2006. A copy of that attestation report is attached hereto as Exhibit A. By: /s/: Kimberlee Clark  Chief Financial Officer  February 22, 2007  860 LATOUR COURT    NAPA, CA   94558   TEL: 707.254.4000 FAX: 707.254.4070 REGULUSGROUP.COM Exhibit 33.5 `A  [ZC STERLING logo] KEEPING YOU FIRST  ZC Sterling Corporation  210 Interstate North Parkway  Suite400  Atlanta, GA 30339 Tel 770.690.8400  Fax 770.690.8240  http://www.zcsterling.com  **Report on Assessment of Compliance with Securities and Exchange****Commission's Regulation AS Servicing Criteria******For the calendar year ending December 31 2006, or portion thereof (the "Period"), ZC Sterling Insurance Agency, Inc. ("ZCSIA") has been a subcontractor for Servicers identified in Appendix A.  The undersigned are Senior Vice Presidents of ZCSIA, have sufficient authority to make the statements contained in this Assertion and are responsible for assessing compliance with the servicing criteria applicable to ZCSIA. ZCSIA has used the servicing criteria communicated to ZCSIA by the Servicer to assess compliance with the applicable servicing criteria. Accordingly, servicing criteria 1122 (d) 1(iv), 1122 (d) 2(vi), 1122 (d) 4(xi), 1122 (d) 4(xii), and 1122 (d) 4(xiii) are applicable to the activities performed by ZCSIA with respect to the Platforms covered by this report. The remaining servicing criteria set forth in Item 1122 (d) of the Securities and Exchange Commission's Regulation AB are not applicable to the activities performed by ZCSIA with respect to the Platform covered by this report. As a subcontractor for Servicer, ZCSIA has determined that it complied in all material respects with the servicing criteria listed below. ZCSIA engaged Ernst & Young, LLP ("E&Y"), a registered public accounting firm, to review ZCSIA assessment and E&Y has issued an attestation report on ZCSIA assessment of compliance with the applicable servicing criteria for the Period.  1.  ZCSIA maintained a fidelity bond and errors & omissions policy in effect on ZCSIA througho ut the reporting period in the amount of coverage required by the transaction agreements between the Servicer and ZCSIA (1122(d)((1)(iv)).  2.  To the extent that ZCSIA prints checks for Servicer or otherwise has  Servicer's checks or check stock, unissued checks are safeguarded so as to prevent  unauthorized access (1122(d)(2)(vi)). [AS OF DECEMBER 31, 2006, THIS  PROVISION WILL APPLY ONLY FOR THE FOLLOWING SERVICERS: ABN  Amro Mortgage Group, Inc, Option One Mortgage Corporation, Sun Trust  Mortgage, Inc., HomEq Servicing Corporation, Wachovia Insurance Corporation,  Wells Fargo Home Mortgage.  3.  Payments made on behalf of Servicer's obligor for insurance premiums 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 thirty (30) calendar days prior to these dates, or such other number of days specified in the transaction agreements between Servicer and ZCSIA (1122(d)(4)(xi)). 4.  Any late payment penalties in connection with any payment for insurance to be made on behalf of Servicer's obligor are paid from the Servicer's funds or ZCSIA's funds and not charged to Servicer's obligor, unless the late payment was due to the obligor's error or omission (1122(d)(4)(xii)).  5. File(s) provided to Servicer from which Servicer may make disbursements made on behalf of Servicer's obligor are provided to Servicer on an accurate and timely basis and the information thereon is subject to such controls as are specified in the transaction agreements between Servicer and ZCSIA (1122(d)(4)(xiii)).  Sincerely,  ZC STERLING INSURANCE  AGENCY, INC.  By: /s/ Arthur J Castner Arthur J. Castner Title: Senior Vice President- Hazard Operations Date: February 20, 2007 By: /s/ James P. Novak James P. Novak Title: Senior Vice President & General Counsel Date: February 20, 2007  **Appendix A**The following is a list of Clients serviced on the ZC Sterling Integrated Produc t  Solution (ZIPS) Platform:  1. ABN Amro Mortgage Group, Inc.  2. Dovenmuehle Mortgage, Inc.  3. HomEq Servicing Corporation  4. Option One Mortgage Corporation  5. People's Choice Home Loan, Inc.  6. Sun Trust Mortgage, Inc.  7. Wachovia Insurance Agenc y (and its affiliates, including Wachovia Mortgage  Corporation)  8. Wells Fargo Home Mortgage