ASSESSMENT
OF COMPLIANCE WITH THE APPLICABLE SERVICING CRITERIA
   Corporate
Trust Services division of Wells Fargo Bank, National Association (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.  The Company has determined that the servicing
criteria are applicable in regards to the servicing platform for the period as
follows:
   Platform:  Publicly-issued
(i.e., transaction-level reporting initially required under the Securities
Exchange Act of 1934, as amended) residential mortgage-backed securities,
commercial mortgage-backed securities and other asset-backed securities, for
which the Company provides master servicing, trustee, securities administration
or paying agent services, excluding any publicly issued transactions issued by
any agency or instrumentality of the U.S. government or any government sponsored
entity, and further excluding the transactions issued prior to 2006 for which
Wells Fargo outsources all material servicing activities (as defined by
Regulation AB) (the "Platform").
   Applicable
Servicing Criteria:  All servicing criteria set forth in Item 1122(d),
to the extent required in the related transaction agreements, or required by the
Item 1122(d) servicing criteria in regards to the activities performed by the
Company, except for the following criteria:  1122(d)(4)(ii),
1122(d)(4)(iv), 1122(d)(4)(v), 1122(d)(4)(viii), 1122(d)(4)(ix), 1122(d)(4)(x),
1122(d)(4)(xi), 1122(d)(4)(xii) and 1122(d)(4)(xiii), which Management has
determined are not applicable to the activities the Company performs with
respect to the Platform ("the Applicable Servicing Criteria").
   Period:  As
of and for the twelve months ended December 31, 2008 (the
"Period").
   Third
parties classified as vendors:  With respect to servicing criteria
1122(d)(4)(i); the Company has engaged various vendors to handle certain Uniform
Commercial Code filing functions required by the servicing criteria
("vendors").  The Company has determined that none of these vendors
are a "servicer" as defined in Item 1101(j) of Regulation AB, and the Company
elects to take responsibility for assessing compliance with the portion of 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").  The Company 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 Company 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 and the Period, the Company provides the following
assessment of compliance with respect to 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,
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 Company's assessment of compliance as of and for the
Period.
   WELLS FARGO BANK,
National Association
    By: /s/ Brian Bartlett
 Brian Bartlett
   Its:  Executive
Vice President
   Dated: February 19,
2009