Exhibit 33.1


[LOGO]KPMG                                            Wells Fargo Bank, N.A.
                                                      Home Mortgage Division
                                                      1 Home Campus
                                                      Des Moines, IA 50328-0001



                             Wells Fargo Bank, N.A.

   2007 Certification Regarding Compliance with Applicable Servicing Criteria


1.    Wells Fargo Bank, N.A. (the "Servicer") is responsible for assessing
      compliance with the servicing criteria applicable to it under paragraph
      (d) of Item 1122 of Regulation AB, as of and for the year ended December
      31, 2007 (the "Reporting Period"), as set forth in Exhibit A hereto. The
      transactions covered by this report include transactions for which the
      Servicer's Wells Fargo Home Mortgage division acted as the primary
      servicer of residential mortgage loans, 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");

2.    The Servicer has engaged certain vendors, which are not deemed to be
      servicers as defined in Item 1101(j) of Regulation AB (the "Vendors"), to
      perform specific, limited or scripted activities for the Reporting Period,
      and the Servicer has elected to take respnsibility for assessing
      compliance with the servicing criteria or portion of the servicing
      criteria applicable to such Vendors' activities as set forth in Exhibit A
      hereto;

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 listed in the column titled "Inapplicable Servicing Criteria"
      on Exhibit A hereto are inapplicable to the Servicer based on the
      activities it performs, directly or through its Vendors, with respect to
      the Platform;

5.    The Servicer has complied, in all material respects, with the applicable
      servicing criteria as of December 31, 2007, and for the Reporting Period
      with respect to the Platform taken as a whole;

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 December 31, 2007, and for the Reporting Period with respect to the
      Platform taken as a whole;

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 as of December 31, 2007, or for the
      Reporting Period with respect to the Platform taken as a whole; 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 for the Reporting Period, which attestation report is
      included on Exhibit B attached hereto.


February 25, 2008
                                                 WELLS FARGO BANK, N.A.

                                                 By: /s/ Mary C. Coffin
                                                     ---------------------------
                                                     Mary C. Coffin
                                                     Executive Vice President


<PAGE>

                                    EXHIBIT A
                                       to
                            Wells Fargo Bank, N.A.'s
   2007 Certification Regarding Compliance With Applicable Servicing Criteria

<TABLE>
<CAPTION>
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                                                                                                               INAPPLICABLE
                                                                                      APPLICABLE                SERVICING
                               SERVICING CRITERIA                                 SERVICING CRITERIA             CRITERIA
------------------------------------------------------------------------------------------------------------------------------------
                                                                                            Performed   Performed by
                                                                                               by      subservicer(s)      NOT
                                                                                            Vendor(s)   or vendor(s)  performed by
                                                                                            for which     for which   Servicer or by
                                                                                Performed  Servicer is   Servicer is  subservicer(s)
                                                                                 Directly      the          NOT the    or vendor(s)
                                                                                    by     Responsible   Responsible   retained by
  Reference                              Criteria                                Servicer     Party         Party        Servicer
------------------------------------------------------------------------------------------------------------------------------------
                               General Servicing Considerations
------------------------------------------------------------------------------------------------------------------------------------
<S>               <C>                                                              <C>        <C>          <C>            <C>
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            X
                  third parties, policies and procedures are instituted to
                  monitor the third party's performance and compliance with
                  such servicing activities.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(1)(iii)   Any requirements in the transaction agreements to maintain a                                             X
                  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.
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                       Cash Collection and Administration
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(2)(i)     Payments on mortgage loans are deposited into the                 X(1)      X(2)
                  appropriate 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.
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1122(d)(2)(ii)    Disbursements made via wire transfer on behalf of an obligor      X
                  or to an investor are made only by authorized personnel.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(2)(iii)   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
                  specified in the transaction agreements.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(2)(iv)    The related accounts for the transaction, such as cash            X
                  reserve 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
                  transaction agreements.
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1122(d)(2)(v)     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-l(b)(l) of the Securities
                  Exchange Act.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(2)(vi)    Unissued checks are safeguarded so as to prevent unauthorized     X(3)      X(4)
                  access.
------------------------------------------------------------------------------------------------------------------------------------
</TABLE>

----------
(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.
(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.


<PAGE>

<TABLE>
<CAPTION>
------------------------------------------------------------------------------------------------------------------------------------
                                                                                                               INAPPLICABLE
                                                                                      APPLICABLE                SERVICING
                               SERVICING CRITERIA                                 SERVICING CRITERIA             CRITERIA
------------------------------------------------------------------------------------------------------------------------------------
                                                                                            Performed   Performed by
                                                                                               by      subservicer(s)      NOT
                                                                                            Vendor(s)   or vendor(s)  performed by
                                                                                            for which     for which   Servicer or by
                                                                                Performed  Servicer is   Servicer is  subservicer(s)
                                                                                 Directly      the          NOT the    or vendor(s)
                                                                                    by     Responsible   Responsible   retained by
  Reference                              Criteria                                Servicer     Party         Party        Servicer
------------------------------------------------------------------------------------------------------------------------------------
<S>               <C>                                                              <C>        <C>          <C>            <C>
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.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(3)(ii)    Amounts due to investors are allocated and remitted in            X
                  accordance with timeframes, distribution priority and other
                  terms set forth in the transaction agreements.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(3)(iii)   Disbursements made to an investor are posted within two           X
                  business days to the Servicer's investor records, or such
                  other number of days specified in the transaction agreements.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(3)(iv)    Amounts remitted to investors per the investor reports            X
                  agree 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.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(iii)   Any additions, removals or substitutions to the asset pool        X
                  are made, reviewed and approved in accordance with any
                  conditions or requirements in the transaction agreements.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(iv)    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
                  accordance with the related mortgage loan documents.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(v)     The Servicer's records regarding the mortgage loans agree         X
                  with the Servicer's records with respect to an obligor's
                  unpaid principal balance.
------------------------------------------------------------------------------------------------------------------------------------
</TABLE>

----------

(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, deposit
      checks, reconciles files to deposit and transmits the transaction files
      to Wells Fargo.

<PAGE>

<TABLE>
<CAPTION>
------------------------------------------------------------------------------------------------------------------------------------
                                                                                                               INAPPLICABLE
                                                                                      APPLICABLE                SERVICING
                               SERVICING CRITERIA                                 SERVICING CRITERIA             CRITERIA
------------------------------------------------------------------------------------------------------------------------------------
                                                                                            Performed   Performed by
                                                                                               by      subservicer(s)      NOT
                                                                                            Vendor(s)   or vendor(s)  performed by
                                                                                            for which     for which   Servicer or by
                                                                                Performed  Servicer is   Servicer is  subservicer(s)
                                                                                 Directly      the          NOT the    or vendor(s)
                                                                                    by     Responsible   Responsible   retained by
  Reference                              Criteria                                Servicer     Party         Party        Servicer
------------------------------------------------------------------------------------------------------------------------------------
<S>               <C>                                                              <C>        <C>          <C>            <C>
1122(d)(4)(vi)    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
                  asset documents.
------------------------------------------------------------------------------------------------------------------------------------
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.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(viii)  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
                  or unemployment).
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(ix)    Adjustments to interest rates or rates of return for mortgage     X
                  loans with variable rates are computed based on the related
                  mortgage loan documents.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(x)     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
                  specified in the transaction agreements.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(xi)    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 transaction agreements.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(xii)   Any late payment penalties in connection with any payment         X
                  to be made on behalf of an obligor are paid from the
                  Servicer's funds and not charged to the obligor, unless the
                  late payment was due to the obligor's error or omission.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(xiii)  Disbursements made on behalf of an obligor are posted             X(9)       X(10)
                  within two business days to the obligor's records maintained
                  by the Servicer, or such other number of days specified in
                  the transaction agreements.
------------------------------------------------------------------------------------------------------------------------------------
1122(d)(4)(xiv)   Delinquencies, charge-offs and uncollectible accounts are         X
                  recognized and recorded in accordance with the transaction
                  agreements.
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1122(d)(4)(xv)    Any external enhancement or other support, identified in Item                                       X
                  1114(a)(1) through (3) or Item 1115 of Regulation AB, is
                  maintained as set forth in the transaction agreements.
------------------------------------------------------------------------------------------------------------------------------------
</TABLE>

----------
(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.
(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.


<PAGE>



                                    EXHIBIT B
                                       to
                            Wells Fargo Bank, N.A.'s
   2007 Certification Regarding Compliance With Applicable Servicing Criteria

             Report of Independent Registered Public Accounting Firm


<PAGE>

[LOGO]KPMG

                     KPMG LLP
                     2500 Ruan Center
                     666 Grand Avenue
                     Des Moines, IA 50309

             Report of Independent Registered Public Accounting Firm

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

We have examined management's assessment, included in the accompanying 2007
Certification Regarding Compliance with Applicable Servicing Criteria, that
Wells Fargo Bank, N.A. (the Company) complied 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 bond programs, or a Federal
Home Loan Bank (the Platform), except for servicing criteria 1122(d)(l)(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, 2007. 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
selected asset-backed transactions and securities that comprise the Platform,
testing selected 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.

As described in the accompanying 2007 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 none of these vendors is
considered a "servicer" 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"). 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.

          KPMG LLP, a U.S. limited liability partnership, is the U.S.
             member firm of KPMG International, a Swiss cooperative.
<PAGE>

[LOGO]KPMG


In our opinion, management's assessment that the Company complied with the
aforementioned servicing criteria, including servicing criteria 1122(d)(2)(i),
1122(d)(2)(vi), 1122(d)(4)(iv), 1122(d)(4)(xi), and 1122(d)(4)(xiii) for which
compliance is determined based on Interpretation 17.06 as described above, as of
and for the year ended December 31, 2007 is fairly stated, in all material
respects.


                                    /s/ KPMG LLP

Des Moines, Iowa
February 25, 2008