EXHIBIT 33.13

     Report on Assessment of Compliance with Servicing Criteria for Year End
     December 31, 2006 of ZC Sterling Insurance Agency, Inc., as Vendor for
                      SunTrust Mortgage, Inc., as Servicer



                    Report on Assessment of Compliance with
                Securities and Exchange Commission's Regulation
                              AB Servicing Criteria

For the  calendar  year  ending  December  31,  2006,  or portion  thereof  (the
"Period"), ZC Sterling Insurance Agency, Inc. ("ZCSIA") has been a subcontractor
for Servicers identified in Appendix A.

The undersigned are Senior Vice Presidents of ZCSIA,  have sufficient  authority
to make the  statements  contained in this  Assertion  and are  responsible  for
assessing  compliance with the servicing criteria applicable to ZCSIA. ZCSIA has
used the  servicing  criteria  communicated  to ZCSIA by the  Servicer to assess
compliance  with  the  applicable  servicing  criteria.  Accordingly,  servicing
criteria 1122 (d) 1 (iv),  1122 (d) 2 (vi),  1122 (d) 4 (xi),  1122 (d) 4 (xii),
and 1122 (d) 4 (xiii) are applicable to the  activities  performed by ZCSIA with
respect  to the  Platforms  covered  by this  report.  The  remaining  servicing
criteria set forth in Item 1122 (d) of the Securities and Exchange  Commission's
Regulation  AB are not  applicable  to the  activities  performed  by ZCSIA with
respect to the Platform covered by this report. As a subcontractor for Servicer,
ZCSIA  has  determined  that it  complied  in all  material  respects  with  the
servicing  criteria listed below.  ZCSIA engaged Ernst & Young,  LLP ("E&Y"),  a
registered  public  accounting  firm to review ZCSIA's  assessment,  and E&Y has
issued an  attestation  report on  ZCSIA's  assessment  of  compliance  with the
applicable servicing criteria for the Period.

1.   ZCSIA maintained a fidelity bond and errors & omissions policy in effect on
     ZCSIA throughout the reporting period in the amount of coverage required by
     the transaction agreements between the Servicer and ZCSIA (1122(d)(1)(iv)).

2.   To the extent  that ZCSIA  prints  checks for  Servicer  or  otherwise  has
     Servicer's checks or check stock,  unissued checks are safeguarded so as to
     prevent  unauthorized  access  (1122(d)(2)(vi)).  [AS OF DECEMBER 31, 2006,
     THIS  PROVISION  WILL  APPLY  ONLY FOR THE  FOLLOWING  SERVICERS:  ABN Amro
     Mortgage Group, Inc., Option One Mortgage Corporation,  Sun Trust Mortgage,
     Inc., HomEq Servicing Corporation,  Wachovia Insurance  Corporation,  Wells
     Fargo Home Mortgage.]

3.   Payments  made on behalf of Servicer's  obligor for insurance  premiums 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  thirty (30)  calendar
     days prior to these dates,  or such other  number of days  specified in the
     transaction agreements between Servicer and ZCSIA (1122(d)(4)(xi)).

4.   Any late payment  penalties in connection with any payment for insurance to
     be made on behalf of Servicer's  obligor are paid from the Servicer's funds
     or ZCSIA's  funds and not charged to  Servicer's  obligor,  unless the late
     payment was due to the obligor's error or omission (1122(d)(4)(xii)).

5.   File(s)  provided to Servicer  from which  Servicer may make  disbursements
     made on behalf  of  Servicer's  obligor  are  provided  to  Servicer  on an
     accurate  and timely basis and the  information  thereon is subject to such
     controls as are specified in the transaction  agreements  between  Servicer
     and ZCSIA (1122(d)(4)(xiii)).


Sincerely,

ZC STERLING INSURANCE AGENCY, INC.

By: /s/ Arthur J. Castner
        -----------------
Title:   Senior Vice President - Hazard Operations
Date:    February 20, 2007


By:  /s/ James P. Novak
    -------------------

Title:   Senior Vice President & General Counsel
Date:    February 20, 2007


Appendix A

     The following is a list of Clients  serviced on the ZC Sterling  Integrated
Product Solution (ZIPS) Platform:

1.  ABN Amro Mortgage Group, Inc.
2.  Dovenmuehle Mortgage, Inc.
3.  HomEq Servicing Corporation
4.  Option One Mortgage Corporation
5.  People's Choice Home Loan, Inc.
6.  Sun Trust Mortgage, Inc.
7.  Wachovia Insurance Agency (and its affiliates, including
        Wachovia Mortgage Corporation)
8.  Wells Fargo Home Mortgage