EXHIBIT 33.11

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



SunTrust Mortgage


    REPORT ON ASSESSMENT OF COMPLIANCE WITH REGULATION AB SERVICING CRITERIA

SunTrust  Mortgage,  Inc. (the  "Asserting  Party") is responsible for assessing
compliance  as of and for the year  ended  December  31,  2006  (the  "Reporting
Period") with the servicing criteria set forth in Title 17, Section  229.1122(d)
of the Code of  Federal  Regulations  (the  "CFR"),  as set forth in  Appendix A
hereto in  connection  with the  servicing of the  asset-backed  securitizations
backed by  residential  mortgage  loans  serviced  by the  Asserting  Party (the
"Applicable  Servicing  Criteria").  This report covers all residential mortgage
loan  securitization   transactions  occurring  after  December  31,  2005  (the
"Platform").

The Asserting  Party has assessed its compliance  with the Applicable  Servicing
Criteria for the Reporting period and has identified three material instances of
noncompliance  with servicing  criteria set forth in Section  229.1122(d)(1)(i),
Section 229.1122(d)(2)(i), and Section 229.1122(d)(2)(iv),  respectively, of the
CFR with respect to the Platform.  Specifically,  for the period from January 1,
2006  through  December  31,  2006 the  Asserting  Party  (a) did not  institute
policies and procedures to monitor any  performance or other triggers and events
of default in accordance  with the transaction  agreements,  (b) did not process
payments into the  appropriate  custodial bank accounts within two business days
of receipt or per the related transaction  agreement,  and (c) did not establish
separately  maintained  custodial  accounts in  accordance  with the  applicable
transaction agreements. The Asserting Party has further concluded that, with the
exception  of  the  aforementioned  material  instances  of  noncompliance,  the
Asserting  Party has complied,  in all material  respects,  with the  Applicable
Servicing  Criteria as of December  31, 2006 and for the period from  January 1,
2006 through December 31, 2006.

Pricewaterhouse  Coopers LLP, an independent  public accounting firm, has issued
an  attestation  report on the  assessment  of  compliance  with the  Applicable
Servicing Criteria for the Reporting Period.

SunTrust Mortgage, Inc.

/s/ John R. Purcell, Jr.
-----------------------------
Senior Vice President - Manager, Servicing Division

Dated:  February 27, 2007


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                                   APPENDIX A

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           <c>              <c>
----------------------------------------------------------------------------   -------------------------   --------------
                                                                                      APPLICABLE            INAPPLICABLE
                                                                                      SERVICING             SERVICING
                            SERVICING CRITERIA                                        CRITERIA              CRITERIA
----------------------------------------------------------------------------   -------------------------   --------------
                                                                                             Performed by
                                                                                             Vendor(s)
                                                                                             for which
                                                                               Performed     SunTrust
                                                                               Directly by   Mortgage,
                                                                               SunTrust      Inc. is the
                                                                               Mortgage,     Responsible
   Reference                         Criteria                                  Inc.          Party
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                               General Servicing Considerations

                  Policies and procedures are instituted to monitor any
                  performance or other triggers and events of default in
1122(d)(1)(i)     accordance with the transaction agreements.                       x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(1)(ii)    such servicing activities.                                        x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Any requirements in the transaction agreements to maintain
1122(d)(1)(iii)   a back-up servicer for the mortgage loans are maintained.                                      x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(1)(iv)    terms of the transaction agreements.                              x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                              Cash Collection and Administration
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(2)(i)     transaction agreements.                                           x(1)                         x(2)
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Disbursements made via wire transfer on behalf of an
                  obligor or to an investor are made only by authorized
1122(d)(2)(ii)    personnel.                                                        x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(2)(iii)   approved as specified in the transaction agreements.              x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(2)(iv)    transaction agreements.                                           x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(2)(v)     13k-1(b)(1) of the Securities Exchange Act.                       x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Unissued checks are safeguarded so as to prevent
1122(d)(2)(vi)    unauthorized access.                                              x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(2)(vii)   agreements.                                                       x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                              Investor Remittances and Reporting
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(3)(i)     serviced by the Servicer.                                         x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Amounts due to investors are allocated and remitted in
                  accordance with timeframes, distribution priority and
1122(d)(3)(ii)    other terms set forth in the transaction agreements.              x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(3)(iii)   agreements.                                                       x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Amounts remitted to investors per the investor reports
                  agree with cancelled checks, or other form of payment, or
1122(d)(3)(iv)    custodial bank statements.                                        x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                                   Pool Asset Administration
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Collateral or security on mortgage loans is maintained as
                  required by the transaction agreements or related mortgage
1122(d)(4)(i)     loan documents.                                                                                x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Mortgage loan and related documents are safeguarded as
1122(d)(4)(ii)    required by the transaction agreements.                                                        x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Any additions, removals or substitutions to the asset pool
                  are made, reviewed and approved in accordance with any
1122(d)(4)(iii)   conditions or requirements in the transaction agreements.         x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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 with the related mortgage loan
1122(d)(4)(iv)    documents.                                                        x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  The Servicer's records regarding the mortgage loans agree
                  with the Servicer's records with respect to an obligor's
1122(d)(4)(v)     unpaid principal balance.                                         x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(4)(vi)    and related pool asset documents.                                 x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(4)(vii)   transaction agreements.                                           x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(4)(viii)  unemployment).                                                    x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Adjustments to interest rates or rates of return for
                  mortgage loans with variable rates are computed based on
1122(d)(4)(ix)    the related mortgage loan documents.                              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
1122(d)(4)(x)     agreements.
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(4)(xi)    number of days specified in the transaction agreements.           x(3)                         x(4)
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(4)(xii)   omission.                                                         x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  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
1122(d)(4)(xiii)  specified in the transaction agreements.                          x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Delinquencies, charge-offs and uncollectible accounts are
                  recognized and recorded in accordance with the transaction
1122(d)(4)(xiv)   agreements.                                                       x
----------------  ----------------------------------------------------------  ------------   -----------   --------------
                  Any external enhancement or other support, identified in
                  Item 1114(a)(1) through (3) or Item 1115 of Regulation AB,
1122(d)(4)(xv)    is maintained as set forth in the transaction agreements.                                      x
-------------------------------------------------------------------------------------------------------------------------
x(1) The Asserting Party is responsible for this criteria except as it pertains to lockbox payments.
x(2) Another party is responsible for the lockbox component of this criterion.
x(3) The Asserting Party is responsible for this criteria except as it pertains to insurance payments.
x(4) Another party is responsible for the insurance payments component of this criterion.

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