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Managements Report on Assessment of Compliance with Applicable Servicing
Criteria
     Signed: 
Name:
    
    /s/ David Lowman

David LowmanTitle:
    
    Executive Vice PresidentDate:
    
    02/26/2007




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EXHIBIT A
 SERVICING CRITERIA
    
    
    
    INAPPLICABLEAPPLICABLE
    
    SERVICINGReference
    
    Criteria
    
    SERVICING CRITERIA
    
    CRITERIAGeneral Servicing Considerations1122(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.
    
    X11122(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 Pool Assets 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.
    
    XCash Collection and Administration1122(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.
    
    
    
    X1122(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 over collateralization, 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.
    
    
    
    X
 
 1
    
    The Asserting Party monitors events of
default as obligated pursuant to the transaction agreements.




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SERVICING CRITERIA
    
    
    
    INAPPLICABLEAPPLICABLE
    
    SERVICINGReference
    
    Criteria
    
    SERVICING CRITERIA
    
    CRITERIA1122(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.
    
    
    
    XInvestor Remittances and Reporting1122(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.
    
    
    
    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.
    
    
    
    XPool Asset Administration1122(d)(4)(i)
    
    Collateral or security on pool assets
is maintained as required by the
transaction agreements or related
pool asset documents.
    
    X1122(d)(4)(ii)
    
    Pool assets 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 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.
    
    
    
    X




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SERVICING CRITERIA
    
    
    
    INAPPLICABLEAPPLICABLE
    
    SERVICINGReference
    
    Criteria
    
    SERVICING CRITERIA
    
    CRITERIA1122(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.
    
    
    
    X1122(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.
    
    
    
    X1122(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 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).
    
    
    
    X1122(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.
    
    
    
    X1122(d)(4)(x)
    
    Regarding any funds held in trust for
an obligor (such as escrow accounts):
    
    
    
    X(A) such funds are analyzed, in
accordance with the obligors pool
asset documents, on at least an
annual basis, or such other period
specified in the transaction
agreements; (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.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.
    
    
    
    X1122(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




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SERVICING CRITERIA
    
    
    
    INAPPLICABLEAPPLICABLE
    
    SERVICINGReference
    
    Criteria
    
    SERVICING CRITERIA
    
    CRITERIA1122(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.
    
    
    
    X1122(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