Exhibit 99.2b

MIDLAND LOAN SERVICES

Management's Assertion on Compliance with the Servicing Standards

Set Forth in the Servicing Policy for the Year Ended December 31, 2003

Report of Management

As of and for the year ended December 31, 2003, Midland Loan Services, Inc. (MLS), an indirect wholly-owned subsidiary of The PNC Financial Services Group, Inc. (PNC), has complied, in all material respects, with MLS's established minimum servicing standards in the Servicing Policy for commercial loans and multifamily servicing as set forth in Appendix I. The minimum servicing standards are based on the Mortgage Bankers Association of America's Uniform Single Attestation Program for Mortgage Bankers, modified to address the unique characteristics of commercial loans and multifamily servicing. The minimum servicing standards within the Servicing Policy do not include standards V.4 and VI.1, which the Mortgage Bankers Association of America has interpreted as inapplicable to commercial loan and multifamily servicing. 

As of and for this same period, PNC was covered by a fidelity bond in the amount of $200,000,000**and an errors and omissions policy in the amount of $80,000,000*.*
MIDLAND LOAN SERVICES, INC.
***Douglas D. Dansforth/*	*/*Steven W. Smith*/*	*/*Vincent E Beckett	*
Douglas D. Dansforth/	/Steven W. Smith/	/	Vincent E Beckett

CEO/President/	/Executive Vice President/	/CFO/	Executive Vice President

February 5, 2004

A Member fo the PNC  Financial Services Group

10851 Mastin  P.O.Box 25965 Shawnee Mission Kansas 66225-5965

www.midlandls.com 913 253 9000 T 913 253 9709 F

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
**APPENDIX I**
MINIMUM SERVICING STANDARDS AS SET FORTH IN THE MORTGAGE BANKERS ASSOCIATION OF AMERICA'S UNIFORM SINGLE ATTESTATION PROGRAM FOR MORTGAGE BANKERS

 
** 
- CUSTODIAL BANK ACCOUNTS
Reconciliations shall be prepared on a monthly basis for all custodial bank accounts and related bank clearing accounts. These reconciliations shall:

- be mathematically accurate;

- be prepared within forty-five (45) calendar days after the cut-off date;

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

- 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.

4.	Escrow funds held in trust for a mortgagor shall be returned to the mortgagor within thirty (30) calendar days of payoff of the mortgage loan.

II.	MORTGAGE PAYMENTS
Mortgage payments shall be deposited into the custodial bank accounts and related bank clearing accounts within two business days of receipt.
Mortgage payments made in accordance with the mortgagor's loan documents shall be posted to the applicable mortgagor records within two business days of receipt.
Mortgage payments shall be allocated to principal, interest, insurance, taxes or other escrow items in accordance with the mortgagor's loan documents.
Mortgage payments identified as loan payoffs shall be allocated in accordance with the mortgagor's loan documents.

 

III.	DISBURSEMENTS
Disbursements made via wire transfer on behalf of a mortgagor or investor shall be made only by authorized personnel.
Disbursements made on behalf of a mortgagor or investor shall be posted within two business days to the mortgagor's or investor's records maintained by the servicing entity.
Tax and insurance payments shall be made on or before the penalty or insurance policy expiration dates, as indicated on tax bills and insurance premium notices, respectively, provided that such support has been received by the servicing entity at least thirty (30) calendar days prior to these dates.
Any late payment penalties paid in conjunction with the payment of any tax bill or insurance premium notice shall be paid from the servicing entity's funds and not charged to the mortgagor, unless the late payment was due to the mortgagor's error or omission.
Amounts remitted to investors per the servicer's investor reports shall agree with cancelled checks, or other form of payment, or custodial bank statements.
Unused checks shall be safeguarded so as to prevent unauthorized access.

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

V.	MORTGAGE LOAN ACCOUNTING
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.
Adjustments on ARM loans shall be computed based on the related mortgage note and any ARM rider.
Escrow accounts shall be analyzed, in accordance with the mortgagor's loan documents, on at least an annual basis.
Interest on escrow accounts shall be paid, or credited, to mortgagors in accordance with the applicable state laws.

VI.	DELINQUENCIES
Records documenting collection efforts shall be maintained during the period a loan is in default and shall be updated 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 (e.g. illness or unemployment).

VII.	INSURANCE POLICIES
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.*****