MANAGEMENT'S ASSERTION OF COMPLIANCE

Management  of the Trust &  Securities  Services  department  of  Deutsche  Bank
National  Trust Company and Deutsche Bank Trust Company  Americas  (collectively
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. Management has determined that the servicing
criteria are  applicable in regard to the  servicing  platform for the period as
follows:

Platform:  Publicly-issued (i.e., transaction-level reporting required under the
Securities  Exchange  Act  of  1934,  as  amended)  residential  mortgage-backed
securities,   commercial   mortgage-backed  securities  and  other  asset-backed
securities  issued on or after  January 1, 2006 for which the  Company  provides
trustee,   securities  administration,   paying  agent  or  custodian  services,
excluding any publicly issued transactions sponsored or issued by any government
sponsored entity (the "Platform").

Applicable Servicing Criteria: All servicing criteria set forth in Item 1122(d),
except   for   the   following   criteria:   1122(d)(2)(iii),    1122(d)(4)(iv),
1122(d)(4)(v),      1122(d)(4)(vi),      1122(d)(4)(vii),      1122(d)(4)(viii),
1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii)
and  1122(d)(4)(xiv),  which management has determined are not applicable to the
activities  the Company  performs with respect to the Platform (the  "Applicable
Servicing Criteria").  Servicing criterion  1122(d)(4)(iii) is applicable to the
activities the Company  performs with respect to the Platform only as it relates
to the Company's  obligation to report  additions,  removals or substitutions on
reports to  investors  in  accordance  with the  transactions  agreements.  With
respect  to  applicable  servicing  criterion  1122(d)(1)(iii),  there  were  no
activities  performed  during the twelve  months  ended  December  31, 2007 with
respect to the Platform,  because there were no occurrences of events that would
require the Company to perform such activities.

Period: Twelve months ended December 31, 2007 (the "Period").

Management's  interpretation  of Applicable  Servicing  Criteria:  The Company's
management has determined that servicing criteria  1122(d)(1)(iii) is applicable
only with respect to its continuing obligation to act as, or locate a, successor
servicer under the circumstances referred to in certain governing documents.  It
is management's  interpretation that Deutsche Bank Trust Company Americas has no
other active back-up servicing responsibilities in regards to 1122(d)(1)(iii) as
of and for the Period.

Third  parties  classified  as  vendors:  With  respect  to  servicing  criteria
1122(d)(2)(i), 1122(d)(4)(i), and 1122(d)(4)(ii), management has engaged various
vendors to perform the  activities  required by these  servicing  criteria.  The
Company's  management  has  determined  that these vendors are not  considered a
"servicer"  as  defined  in Item  1101(j) of  Regulation  AB, and the  Company's
management 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,   management  has  asserted  that  it  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's  management 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's  management  provides
the following  assertion of compliance with respect to the Applicable  Servicing
Criteria:

1.    The  Company's  management  is  responsible  for  assessing  the Company's
      compliance with the Applicable Servicing Criteria.

2.    The  Company's  management  has assessed  compliance  with the  Applicable
      Servicing  Criteria,  including servicing criteria for which compliance is
      determined based on Interpretation 17.06 as described above. 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  management's  assertion of compliance  with the  Applicable
Servicing Criteria as of and for the Period.


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                                        DEUTSCHE BANK OF NATIONAL TRUST COMPANY

                                        By: /s/ Gary R. Vaughan
                                            Name: Gary R. Vaughan
                                            Its: Managing Director

                                        By: /s/ David Co
                                            Name: David Co
                                            Its: Director

                                        By: /s/ Jose Sicilia
                                            Name: Jose Sicilia
                                            Its: Managing Director

                                        By: /s/ Kevin Fischer
                                            Name: Kevin Fischer
                                            Its: Director

                                        By: /s/ Robert Frier
                                            Name: Robert Frier
                                            Its: Director




                                        DEUTSCHE BANK TRUST COMPANY AMERICAS

                                        By: /s/ Kevin C. Weeks
                                            Name: Kevin C. Weeks
                                            Its: Managing Director

                                        By: /s/ Jenna Kaufman
                                            Name: Jenna Kaufman
                                            Its: Director


Dated: February 29, 2008


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