[LETTERHEAD OF WELLS FARGO HOME MORTGAGE]

                             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


<PAGE>



<TABLE>
<CAPTION>

                                    EXHIBIT A
                                       TO
                            WELLS FARGO BANK, N.A.'S
                    2006 CERTIFICATION REGARDING COMPLIANCE WITH APPLICABLE SERVICING CRITERIA


----------------------------------------------------------------------------------- ----------------------------- -----------------
                                SERVICING CRITERIA                                      APPLICABLE SERVICING        INAPPLICABLE
                                                                                              CRITERIA               SERVICING
                                                                                                                      CRITERIA
----------------------------------------------------------------------------------- ----------------------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
    REFERENCE                                 CRITERIA                              PERFORMED BY   PERFORMED BY
                                                                                      SERVICER       VENDOR(S)
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                                  GENERAL SERVICING CONSIDERATIONS
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
<S>                <C>                                                              <S>
1122(d)(1)(i)      Policies and procedures are instituted to monitor any                  X
                   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
                   X parties,  policies and procedures are instituted to monitor
                   the  third  party's  performance  and  compliance  with  such
                   servicing activities.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Any requirements in the transaction  agreements to maintain a
X 1122(d)(1)(iii) back-up servicer for the mortgage loans are maintained.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
1122(d)(1)(iv)     A fidelity bond and errors and omissions policy is in effect           X
                   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 mortgage loans are deposited into the appropriate    X(1)           X(2)
                   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.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Disbursements  made via wire transfer on behalf of an obligor
X 1122(d)(2)(ii) or to an investor are made only by authorized personnel.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Advances of funds or guarantees regarding collections, cash X
                   flows  or  distributions,  and any  interest  or  other  fees
                   charged for such advances, are made, reviewed and approved as
1122(d)(2)(iii) specified in the transaction agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   The  related  accounts  for  the  transaction,  such  as cash
                   reserve  X  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
1122(d)(2)(iv) transaction agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Each custodial account is maintained at a federally insured X
                   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
1122(d)(2)(v) Exchange Act.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Unissued checks are safeguarded so as to prevent unauthorized    X(3)           X(4)
1122(d)(2)(vi) access.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------


<PAGE>


----------------------------------------------------------------------------------- ----------------------------- -----------------
                                SERVICING CRITERIA                                      APPLICABLE SERVICING        INAPPLICABLE
                                                                                              CRITERIA               SERVICING
                                                                                                                      CRITERIA
----------------------------------------------------------------------------------- ----------------------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
    REFERENCE                                 CRITERIA                              PERFORMED BY   PERFORMED BY
                                                                                      SERVICER       VENDOR(S)
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
1122(d)(2)(vii)    Reconciliations are prepared on a monthly basis for all                X
                   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, including those to be filed with the             X
                   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.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Amounts due to investors are allocated and remitted in                 X
                   accordance with timeframes, distribution priority and other
1122(d)(3)(ii) terms set forth in the transaction agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Disbursements made to an investor are posted within two                X
                   business days to the Servicer's investor records, or such
1122(d)(3)(iii) other number of days specified in the transaction agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
1122(d)(3)(iv)     Amounts remitted to investors per the investor reports agree           X
                   with cancelled checks, or other form of payment, or custodial
                   bank statements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                                      POOL ASSET ADMINISTRATION
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
1122(d)(4)(i)      Collateral or security on mortgage loans is maintained as              X
                   required by the transaction agreements or related mortgage
                   loan documents.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
1122(d)(4)(ii)     Mortgage loan and related documents are safeguarded as                 X
                   required by the transaction agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Any additions, removals or substitutions to the asset pool are         X
                   made, reviewed and approved in accordance with any conditions
1122(d)(4)(iii) or requirements in the transaction agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Payments on mortgage loans, including any payoffs, made in       X(5)           X(6)
                   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
1122(d)(4)(iv) accordance with the related mortgage loan documents.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   The  Servicer's  records  regarding the mortgage  loans agree
                   with X the  Servicer's  records  with respect to an obligor's
                   unpaid
1122(d)(4)(v) principal balance.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Changes with respect to the terms or status of an obligor's X
                   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
1122(d)(4)(vi) asset documents.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
----------------------------------------------------------------------------------- ----------------------------- -----------------
                                SERVICING CRITERIA                                      APPLICABLE SERVICING        INAPPLICABLE
                                                                                              CRITERIA               SERVICING
                                                                                                                      CRITERIA
----------------------------------------------------------------------------------- ----------------------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
    REFERENCE                                 CRITERIA                              PERFORMED BY   PERFORMED BY
                                                                                      SERVICER       VENDOR(S)
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
1122(d)(4)(vii)    Loss mitigation or recovery actions (e.g., forbearance plans,
                   X   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.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Records documenting collection efforts are maintained during           X
                   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
1122(d)(4)(viii) or unemployment).
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Adjustments to interest rates or rates of return for mortgage          X
                   loans with variable rates are computed based on the related
1122(d)(4)(ix) mortgage loan documents.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Regarding any funds held in trust for an obligor (such as              X
                   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
1122(d)(4)(x) specified in the transaction agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Payments made on behalf of an obligor (such as tax or            X(7)           X(8)
                   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
1122(d)(4)(xi) transaction agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Any late payment  penalties in connection with any payment to
                   X be  made  on  behalf  of  an  obligor  are  paid  from  the
                   Servicer's  funds and not charged to the obligor,  unless the
                   late payment
1122(d)(4)(xii) was due to the obligor's error or omission.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Disbursements  made on behalf of an obligor are posted within
                   X(9)  X(10)  two  business  days  to  the  obligor's  records
                   maintained  by the  servicer,  or such  other  number of days
                   specified in the
1122(d)(4)(xiii) transaction agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Delinquencies, charge-offs and uncollectible accounts are              X
                   recognized and recorded in accordance with the transaction
1122(d)(4)(xiv) agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------
                   Any external enhancement or other support, identified in Item
                   X 1114(a)(1) through (3) or Item 1115 of Regulation AB, is
1122(d)(4)(xv) maintained as set forth in the transaction agreements.
------------------ ---------------------------------------------------------------- -------------- -------------- -----------------

</TABLE>


<PAGE>


                                    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.






<PAGE>


                                    EXHIBIT C
                                       TO
                            WELLS FARGO BANK, N.A.'S
   2006 CERTIFICATION REGARDING COMPLIANCE WITH APPLICABLE SERVICING CRITERIA


             Report of Independent Registered Public Accounting Firm



<PAGE>


                              [LETTERHEAD OF KPMG]



            REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


The Board of Directors
Wells Fargo Bank, N.A.:

We have  examined  Wells Fargo Bank,  N.A.'s (the Company)  compliance  with the
servicing  criteria  set forth in Item  1122(d) of the  Securities  and Exchange
Commission's  Regulation AB for its 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 Platform),  except for servicing
criteria  1122(d)(1)(iii) and  1122(d)(4)(xv),  which the Company has determined
are not  applicable to the  activities it performs with respect to the Platform,
as of and for the year ended December 31, 2006.  Management is  responsible  for
the Company's compliance with those servicing criteria. Our responsibility is to
express an opinion on the Company's compliance based on our examination.

Our  examination  was conducted in  accordance  with the standards of the Public
Company Accounting  Oversight Board (United States) and,  accordingly,  included
examining,  on a test basis,  evidence about the Company's  compliance  with the
servicing  criteria  specified above and performing such other  procedures as we
considered  necessary in the circumstances.  Our examination included testing of
less than all of the individual  asset-backed  transactions  and securities that
comprise  the  Platform,  testing of less than all of the  servicing  activities
related to the Platform,  and  determining  whether the Company  processed those
selected transactions and performed those selected activities in compliance with
the servicing criteria. Furthermore, our procedures were limited to the selected
transactions and servicing activities performed by the Company during the period
covered by this report.  Our procedures  were not designed to determine  whether
errors may have  occurred  either prior to or  subsequent  to our tests that may
have  affected  the  balances or amounts  calculated  or reported by the Company
during the period  covered by this report for the selected  transactions  or any
other transactions.  We believe that our examination provides a reasonable basis
for our opinion.  Our examination does not provide a legal  determination on the
Company's compliance with the servicing criteria.

Our examination disclosed the following instances of material noncompliance with
certain  servicing  criteria  applicable  to the  Company  during the year ended
December 31, 2006:

     1.  1122(d)(3)(i) - Delinquency Reporting - The Company 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.  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.

     2.  1122(d)(4)(vii) - Notification of Intent to Foreclose - The Company, as
         required by certain  servicing  agreements,  did not provide  investors
         with prior notification of intent to foreclose.

As described in the accompanying 2006  Certification  Regarding  Compliance with
Applicable   Servicing   Criteria,   for   servicing   criteria   1122(d)(2)(i),
1122(d)(2)(vi),   1122(d)(4)(iv),   1122(d)(4)(xi),  and  1122(d)(4)(xiii),  the
Company has engaged various vendors to perform the activities  required by these
servicing  criteria.  The  Company  has  determined  that these  vendors are not
considered  "servicers"  as defined in Item  1101(j) of  Regulation  AB, and the
Company 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"), with the exception of those
vendors who have provided  their own reports on  assessment  of compliance  with
servicing  criteria to the  Company,  for which the  Company  does not take such
responsibility.  As permitted by Interpretation  17.06, the Company has asserted
that it has  policies and  procedures  in place  designed to provide  reasonable
assurance that the vendors'  activities comply in all material respects with the
servicing criteria  applicable to each vendor. The Company is solely responsible
for determining that it meets the SEC requirements to apply Interpretation 17.06
for the vendors  and related  criteria as  described  in its  assertion,  and we
performed no  procedures  with  respect to the  Company's  eligibility  to apply
Interpretation 17.06.

In our opinion,  except for the  instances of material  noncompliance  described
above, the Company complied,  in all material respects,  with the aforementioned
servicing criteria as of and for the year ended December 31, 2006.


/s/ KPMG LLP

Des Moines, Iowa
March 1, 2007



<PAGE>


                                    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 Criteria


<PAGE>


                             [LETTERHEAD OF REGULUS]


    REPORT ON ASSESSMENT OF COMPLIANCE WITH REGULATION AB SERVICING CRITERIA


       1.  Pursuant to Subpart  229.1100 - Asset  Backed  Securities,  17 C.F.R.
           ss.ss.229.1100-  229.1123  ("Regulation  AB"), Regulus Group LLC, for
           itself   and  its   wholly-owned   subsidiaries   (individually   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  through 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 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.



       /s/ Kimberlee Clark
       Kimberlee Clark
       Chief Financial Officer

       February 22, 2007


<PAGE>


                            [LETTERHEAD OF KPMG LLP]



             Report of Independent Registered Public Accounting Firm


The Board of Members
Regulus Group LLC:

We have examined management's assessment for those customers that management has
informed  us  have  requested  confirmation  of  compliance,   included  in  the
accompanying  Report on Assessment of  Compliance  with  Regulation AB Servicing
Criteria,  that Regulus Group LLC complied with the servicing criteria set forth
in  Item  1122(d)(2)(i)  and  1122(d)(4)(iv)  of  the  Securities  and  Exchange
Commission's  Regulation AB for remittance  processing services to those issuers
of asset backed securities and servicers of loan and/or  receivables  portfolios
that include pool assets for asset backed securities transactions (the Platform)
as of and for the year ended December 31, 2006. Regulus Group LLC has determined
that  the  remainder  of  the  servicing  criteria  are  not  applicable  to the
activities it performs with respect to the Platform as of and for the year ended
December 31, 2006.  Management is responsible for the Company's  compliance with
those  servicing  criteria.  Our  responsibility  is to  express  an  opinion on
management's assessment about the Company's compliance based on our examination.

Our  examination  was conducted in  accordance  with the standards of the Public
Company Accounting  Oversight Board (United States) and,  accordingly,  included
examining,  on a test basis,  evidence about the Company's  compliance  with the
servicing  criteria  specified above and performing such other  procedures as we
considered  necessary in the circumstances.  Our examination included testing of
less than all of the individual  asset-backed  transactions  and securities that
comprise  the  Platform,  testing of less than all of the  servicing  activities
related to the Platform,  and  determining  whether the Company  processed those
selected transactions and performed those selected activities in compliance with
the servicing criteria. Furthermore, our procedures were limited to the selected
transactions and servicing activities performed by the Company during the period
covered by this report.  Our procedures  were not designed to determine  whether
errors may have  occurred  either prior to or  subsequent  to our tests that may
have  affected  the  balances or amounts  calculated  or reported by the Company
during the period  covered by this report for the selected  transactions  or any
other transactions.  We believe that our examination provides a reasonable basis
for our opinion.  Our examination does not provide a legal  determination on the
Company's compliance with the servicing criteria.

In our  opinion,  management's  assessment  that the Company  complied  with the
aforementioned servicing criteria as of and for the year ended December 31, 2006
is fairly stated, in all material respects.


/s/ KPMG LLP

Philadelphia, PA
February 22, 2007



<PAGE>




                           [LETTERHEAD OF ZC STERLING]





         REPORT ON ASSESSMENT OF COMPLIANCE WITH SECURITIES AND EXCHANGE
                  COMMISSION'S REGULATION AB 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's  assessment,  and E&Y has
issued an  attestation  report on  ZCSIA's  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 throughout 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





<PAGE>


APPENDIX A
The  following  is a list of  Clients  serviced  on the ZC  Sterling  Integrated
Product 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  Agency  (and its  affiliates,  including  Wachovia
     Mortgage Corporation)
8.  Wells Fargo Home Mortgage


<PAGE>


                        [LETTERHEAD OF ERNST & YOUNG LLP]



             REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


We have examined management's assertion,  included in the accompanying Report on
Assessment of Compliance with Securities and Exchange Commission's Regulation AB
Servicing  Criteria,  that ZC Sterling  Insurance  Agency,  Inc.  (the  Company)
complied  with  certain  servicing  criteria  set  forth in Item 1122 (d) of the
Securities  and  Exchange  Commission's   Regulation  AB  for  the  ZC  Sterling
Integrated  Product  Solution  (ZIPS)  hazard  insurance   outsourcing  Platform
(Platform)  as of and for the year ended  December  31,  2006.  The  Company has
determined that only certain 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 them with  respect  to the  Platform  covered  by this
report.  The Company has determined  that 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 them with  respect to the
Platform  covered by this report.  See Appendix A of management's  assertion for
the Platform covered by this report. Management is responsible for the Company's
compliance with those servicing  criteria.  Our  responsibility is to express an
opinion  on  management's  assertion  about the  Company's  compliance  with the
servicing criteria based on our examination.

Our examination was conducted in accordance with standards of the Public Company
Accounting Oversight Board (United States) and, accordingly, included examining,
on a test basis,  evidence  about the Company's  compliance  with the applicable
servicing  criteria  and  performing  such  other  procedures  as we  considered
necessary in the  circumstances.  Our examination  included testing of less than
all of the individual  asset backed  transactions and securities that compromise
the platform,  testing of less than all of the servicing  activities  related to
the Platform,  and  determining  whether the Company  performed  those  selected
activities  in  compliance  with  the  servicing  criteria.   Furthermore,   our
procedures  were limited to the  servicing  activities  performed by the Company
during the period covered by this report.  Our  procedures  were not designed to
determine  whether errors may have occurred either prior to or subsequent to our
tests that may have  affected the balances or amounts  calculated or reported by
the  Company  during the  period  covered by this  report for the  Platform.  We
believe that our examination  provides a reasonable  basis for our opinion.  Our
examination does not provide a legal  determination on the Company's  compliance
with the servicing criteria.

In our  opinion,  management's  assertion  that the  Company  complied  with the
aforementioned servicing criteria as of and for the year ended December 31, 2006
for the ZIPS Platform is fairly stated, in all material respects.



/s/ Ernst & Young LLP

February 20, 2007





(1)  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,  deposits
     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.

(5)  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,  deposits
     checks, reconciles files to deposits and transmits the transaction files to
     Wells Fargo. See Exhibit D.

(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.