Exhibit 99.3

Management's Assertion on Compliance
with the Specified Minimum Servicing Standards Set Forth
in the Uniform Single Attestation Program for Mortgage Bankers

Report of Management

We, as members of management of IndyMac Bank, F.S.B. (the "Bank"), are
responsible for complying with the specified minimum servicing standards
set forth in Exhibit A to this report ("specified minimum servicing
standards") related to the servicing of Home Equity Lines of Credit.  We
are also responsible for establishing and maintaining effective internal
control over compliance with these standards.  We have performed an
evaluation of the Bank's compliance with the specified minimum servicing
standards as of December 31, 2004 and for the year then ended. Based on
this evaluation, we assert that during the year ended December 31, 2004,
the Bank complied, in all material respects, with the specified minimum
servicing standards, except as described below.

The specified minimum servicing standards require that custodial bank
reconciliations be prepared and reviewed by two different individuals and
that they be performed within forty-five (45) days after the custodial bank
statement cutoff date.  However, during the year ended December 31, 2004,
the Bank noted four (4) out of fourteen (14) custodial bank reconciliations
tested were neither signed nor dated and, therefore, there was insufficient
evidence to conclude that the Bank complied with the specified minimum
servicing standards. The Bank has since implemented procedures to ensure
reconciliation of all custodial bank accounts in accordance with the
specified minimum servicing standards.

As of December 31, 2004 and for the year then ended, the Bank had in effect
a fidelity bond in the amount of $50,000,000 and an errors and omissions
policy in the amount of $20,000,000.



/s/: Pat Jackson                        /s/: Jim Jerwers
Pat Jackson                             Jim Jerwers
Executive Vice President and            Executive Vice President
Chief Executive Officer                 HELOC Portfolio Manager
Home Equity and Government Lending


/s/: Scott Keys                       /s/: Jeff Lankey
Scott Keys                            Jeff Lankey
Executive Vice President and          Senior Vice President and
Chief Financial Officer               Chief Accounting Officer


February 23, 2005

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Exhibit A

Specified Minimum Servicing Standards

I.	Custodial Bank Accounts

1. Reconciliations shall be prepared on a monthly basis for all custodial
bank accounts and related bank clearing accounts.  These reconciliations
shall:

a. be mathematically accurate;

b. be prepared within forty-five (45) calendar days after the cutoff date.
  The cutoff date is the date as of which a bank account is reconciled
every month.  It may, or may not, coincide with a prescribed investor
reporting date but shall be consistent from period to period;

c. be reviewed and approved by someone other than the person who prepared
the reconciliation; and

d. document explanations for reconciling items.  These reconciling items
shall be resolved within ninety (90) calendar days of their original
identification.

2. Funds of the servicing entity shall be advanced in cases where there
is an overdraft in an investor's or a mortgagor's account.

3. Each custodial account shall be maintained at a federally insured
depository institution in trust for the applicable investor.

II.	Mortgage Payments

1. Mortgage payments shall be deposited into the custodial bank accounts
and related bank clearing accounts within two (2) business days of receipt.

2. Mortgage payments made in accordance with the mortgagor's loan documents
shall be posted to the applicable mortgagor records within two (2) business
days of receipt.

3. Mortgage payments shall be allocated to principal, interest, insurance,
taxes or other escrow items in accordance with the mortgagor's loan documents.


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Exhibit A

Specified Minimum Servicing Standards (continued)

III.	Disbursements

1. Disbursements made via wire transfer on behalf of a mortgagor or
investor shall be made only by authorized personnel.

2. Disbursements made on behalf of a mortgagor or investor shall be posted
within two (2) business days to the mortgagor's or investor's records
 maintained by the servicing entity.

3. Amounts remitted to investors per the servicer's investor reports shall
agree with cancelled checks, or other form of payment, or custodial bank
statements.

IV.	Investor Accounting and Reporting

1. The servicing entity's investor reports shall agree with, or reconcile
to, investors' records on a monthly basis as to the total unpaid principal
balance and number of loans serviced by the servicing entity.

V. Mortgagor Loan Accounting

1.	The servicing entity's mortgage loan records shall agree with, or
reconcile to, the records of mortgagors with respect to the unpaid principal
balance on a monthly basis.

2. Adjustments on adjustable rate mortgage (ARM) loans shall be computed
based on the related mortgage note and any ARM rider.

VI. Delinquencies

1. Records documenting collection efforts shall be maintained during the
period a loan is in default and shall be undated at least monthly.  Such
records shall describe the entity's activities in monitoring delinquent
loans including, for example, phone calls, letters and mortgage payment
rescheduling plans in cases where the delinquency is deemed temporary
(i.e., illness or unemployment).

VII. Insurance Policies

1. A fidelity bond and errors and omissions policy shall be in effect on
the servicing entity throughout the reporting period in the amount of
coverage represented to investors in management's assertion.