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Managements Report on Assessment of Compliance with Applicable Servicing Criteria
       Signed:
    
    /s/ Kim Greaves
    
    
    
    Signed:
    
    /s/ Jim MillerName: Kim Greaves
Title: Senior Vice President
    
    
    
    
    
    Name: Jim Miller
Title: Senior Vice PresidentDate: 02/25/2008
    
    
    
    Date: 02/25/2008




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EXHIBIT A
 APPLICABLESERVICING CRITERIA
    
    INAPPLICABLESERVICING CRITERIA
    
    Performed by
    
    Performed by
    
    SERVICINGReference
    
    Criteria
    
    Servicer
    
    Vendor(s)
    
    CRITERIAGeneral Servicing Considerations1122(d)(1)(i)
    
    Policies and procedures are
instituted to monitor any
performance or other triggers and
events of default in accordance
with the transaction agreements.
    
    X11122(d)(1)(ii)
    
    If any material servicing
activities are outsourced to
third parties, policies and
procedures are instituted to
monitor the third partys
performance and compliance with
such servicing activities.
    
    X21122(d)(1)(iii)
    
    Any requirements in the
transaction agreements to
maintain a back-up servicer for
the mortgage loans are
maintained.
    
    
    
    
    
    X1122(d)(1)(iv)
    
    A fidelity bond and errors and
omissions policy is in effect 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.
    
    XCash Collection and Administration1122(d)(2)(i)
    
    Payments on mortgage loans are
deposited into the 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.
    
    X
    
    X2,31122(d)(2)(ii)
    
    Disbursements made via wire
transfer on behalf of an obligor
or to an investor are made only
by authorized personnel.
    
    X1122(d)(2)(iii)
    
    Advances of funds or guarantees
regarding collections, cash flows
or distributions, and any
interest or other fees charged
for such advances, are made,
reviewed and approved as
specified in the transaction
agreements.
    
    X1122(d)(2)(iv)
    
    The related accounts for the
transaction, such as cash 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.
    
    X1122(d)(2)(v)
    
    Each custodial account is
maintained at a federally insured
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-1(b)(1) of the Securities
Exchange Act.
    
    X1122(d)(2)(vi)
    
    Unissued checks are safeguarded
so as to prevent unauthorized
access.
    
    X
 
 1
    
    The Asserting Party monitors events of default as
obligated pursuant to the transaction agreements.2
    
    The Asserting Party has determined that none of its
vendors is a servicer as defined in Item 1101(j) of Regulation AB. The
Asserting Party 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 such vendor.3
    
    An affiliate vendor deposits funds from customer
transactions to a lockbox clearing account.




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APPLICABLESERVICING CRITERIA
    
    INAPPLICABLESERVICING CRITERIA
    
    Performed by
    
    Performed by
    
    SERVICINGReference
    
    Criteria
    
    Servicer
    
    Vendor(s)
    
    CRITERIA1122(d)(2)(vii)
    
    Reconciliations are prepared on a
monthly basis for all
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.
    
    X
    
    X2,4Investor Remittances and Reporting1122(d)(3)(i)
    
    Reports to investors, including
those to be filed with the
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.
    
    X51122(d)(3)(ii)
    
    Amounts due to investors are
allocated and remitted in
accordance with timeframes,
distribution priority and other
terms set forth in the
transaction agreements.
    
    X61122(d)(3)(iii)
    
    Disbursements made to an investor
are posted within two business
days to the Servicers investor
records, or such other number of
days specified in the transaction
agreements.
    
    X71122(d)(3)(iv)
    
    Amounts remitted to investors per
the investor reports agree with
cancelled checks, or other form
of payment, or custodial bank
statements.
    
    X8Pool Asset Administration1122(d)(4)(i)
    
    Collateral or security on
mortgage loans is maintained as
required by the transaction
agreements or related mortgage
loan documents.
    
    
    
    
    
    X1122(d)(4)(ii)
    
    Mortgage loan and related
documents are safeguarded as
required by the transaction
agreements
    
    
    
    
    
    X1122(d)(4)(iii)
    
    Any additions, removals or
substitutions to the asset pool
are made, reviewed and approved
in accordance with any conditions
or requirements in the
transaction agreements.
    
    X1122(d)(4)(iv)
    
    Payments on mortgage loans,
including any payoffs, made in
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
    
    X
 
 4
    
    Two vendors prepare account reconciliations on
disbursement clearing accounts.5
    
    The Asserting Party provides monthly pool accounting
reports to the appropriate party pursuant to the transaction agreements.6
    
    The Asserting Party remits amounts to the appropriate
party pursuant to the transaction agreements.7
    
    Disbursements made to the appropriate party pursuant
to the transaction agreements are posted within two business days to the
Asserting Partys records, or such other number of days specified in the
transaction agreements.8
    
    The Asserting Party reconciles its records relating to
disbursements made to the appropriate party pursuant to the transaction
agreements.




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APPLICABLESERVICING CRITERIA
    
    INAPPLICABLESERVICING CRITERIA
    
    Performed by
    
    Performed by
    
    SERVICINGReference
    
    Criteria
    
    Servicer
    
    Vendor(s)
    
    CRITERIAwith the related mortgage loan
documents.1122(d)(4)(v)
    
    The Servicers records regarding
the mortgage loans agree with the
Servicers records with respect
to an obligors unpaid principal
balance.
    
    X1122(d)(4)(vi)
    
    Changes with respect to the terms
or status of an obligors
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.
    
    X1122(d)(4)(vii)
    
    Loss mitigation or recovery
actions (e.g., forbearance plans,
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.
    
    X1122(d)(4)(viii)
    
    Records documenting collection
efforts are maintained during 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).
    
    X1122(d)(4)(ix)
    
    Adjustments to interest rates or
rates of return for mortgage
loans with variable rates are
computed based on the related
mortgage loan documents.
    
    X1122(d)(4)(x)
    
    Regarding any funds held in trust
for an obligor (such as 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.
    
    X1122(d)(4)(xi)
    
    Payments made on behalf of an
obligor (such as tax or 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.
    
    X
    
    X2,91122(d)(4)(xii)
    
    Any late payment penalties in
connection with any payment 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.
    
    X1122(d)(4)(xiii)
    
    Disbursements made on behalf of
an obligor are posted within two
business days to the obligors
records maintained by the
servicer, or such other number of
days specified in the transaction
agreements.
    
    X1122(d)(4)(xiv)
    
    Delinquencies, charge-offs and
uncollectible accounts are
recognized and recorded in
accordance with the transaction
agreements.
    
    X
 
 9
    
    Two vendors provide information used by the Asserting
Party to pay taxes and insurance on behalf of obligors.




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APPLICABLESERVICING CRITERIA
    
    INAPPLICABLESERVICING CRITERIA
    
    Performed by
    
    Performed by
    
    SERVICINGReference
    
    Criteria
    
    Servicer
    
    Vendor(s)
    
    CRITERIA1122(d)(4)(xv)
    
    Any external enhancement or other
support, identified in Item
1114(a)(1) through (3) or Item
1115 of Regulation AB, is
maintained as set forth in the
transaction agreements.
    
    
    
    
    
    X