Exhibit 33.1
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                                             [LOGO OMITTED] Countrywide
                                             --------------------------
                                                      HOME LOANS

                                             2900 Madera Road
                                             Simi Valley, California 93065-6298
                                             (805) 955-1000


          ASSESSMENT OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIA

     Countrywide Financial Corporation and certain of its subsidiaries,
including its direct and indirect wholly-owned subsidiaries, Countrywide Home
Loans, Inc. (CHL), Countrywide Tax Services Corporation, Newport Management
Corporation, and Countrywide Home Loans Servicing, LP, a wholly-owned subsidiary
of CHL (collectively the "Company") provides this platform-level assessment, for
which Countrywide Financial Corporation and such subsidiaries participated in
servicing functions, as such term is described under Title 17, Section 229.1122
of the Code of Federal Regulations ("Item 1122 of Regulation AB"), of compliance
in respect of the following Applicable Servicing Criteria specified in Item
1122(d) of Regulation AB promulgated by the Securities and Exchange Commission
in regard to the following servicing platform for the following period:

     Platform: publicly-issued (i.e., registered with the Securities and
     Exchange Commission pursuant to the Securities Act of 1933, as amended)
     residential mortgage-backed securities (securities collateralized by
     residential mortgage loans, including prime, alternative loan products,
     sub-prime, HELOC and closed seconds) issued on or after January 1, 2006 for
     which the Company provides cash collection and administration, investor
     remittances and reporting (except for those activities relating to trustee
     and paying agent services), and pool asset administration (except for those
     activities relating to custodial operations of pool assets and related
     documents), collectively "Servicing Functions" and for which the related
     issuer has a fiscal year end of December 31, 2006. The platform excludes
     any transactions issued by any government sponsored enterprise for which
     the Company provides Servicing Functions.

     Period: as of and for the year ended December 31, 2006.

     Applicable Servicing Criteria: all servicing criteria set forth in Item
     1122(d), to the extent required in the related agreements, except for the
     following paragraphs: 1122(d)(1)(iii), 1122(d)(3)(i)(B), only as it relates
     to information other than that contained in the monthly remittance report
     delivered by the servicer to the master servicer, trustee, and/or bond
     administrator, 1122(d)(3)(i)(D), only as it relates to the agreeing with
     investors' records as to the total unpaid principal balance and number of
     pool assets serviced by the servicer, 1122(d)(3)(ii), only as it relates to
     amounts other than amounts remitted by the servicer to the master servicer,
     trustee, and/or bond administrator, 1122(d)(3)(iii), 1122(d)(3)(iv),
     1122(d)(4)(i) and 1122(d)(4)(ii), only as 1122(d)(4)(i) and 1122(d)(4)(ii)
     relate to the custodial operations of the pool assets and related documents
     (collateral file) by the document custodian responsible for such functions
     for the related transaction, and 1122(d)(4)(xv), only as it relates to Item
     1115 of Regulation AB (derivative transactions).


<PAGE>


     With respect to the Platform and the Period, the Company provides the
following assessment of compliance in respect of the Applicable Servicing
Criteria:

     1.   The Company is responsible for assessing its compliance with the
Applicable Servicing Criteria.

     2.   The Company has assessed compliance with the Applicable Servicing
Criteria.

     3.   Other than as identified on Schedule A hereto, as of and for the
Period, the Company was in material compliance with the Applicable Servicing
Criteria.

     KPMG LLP, an independent registered public accounting firm, has issued an
attestation report with respect to the Company's foregoing assessment of
compliance.


<PAGE>


                             COUNTRYWIDE FINANCIAL CORPORATION


                             By:    /s/ Steve Bailey
                                    --------------------------------------------
                                    Steve Bailey


                             Its:   Senior Managing Director and Chief Executive
                                    Officer, Loan Administration


                             Dated: February 28, 2007


                             By:    /s/ Kevin Meyers
                                    --------------------------------------------
                                    Kevin Meyers

                             Its:   Managing Director and Chief Financial
                                    Officer, Countrywide Home Loans, Inc. Loan
                                    Administration


                             Dated: February 28, 2007


<PAGE>


                                   Schedule A
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                       Material Instances of Noncompliance
                       -----------------------------------

No material instances of noncompliance: the Company has complied, in all
material respects, with the applicable servicing criteria as of and for the year
ended December 31, 2006.