Exhibit
      33.1











[LOGO
                OMITTED] CountrywideHOME
                LOANS2900
                Madera RoadSimi
                Valley, California 93065-6298(805)
                955-1000








ASSESSMENT
      OF COMPLIANCE WITH APPLICABLE SERVICING CRITERIA




Countrywide
      Financial Corporation and certain of its subsidiaries, including its direct
      and
      indirect wholly-owned subsidiaries, Countrywide Home Loans, Inc. (CHL),
      Countrywide Tax Services Corporation, Newport Management Corporation, and
      Countrywide Home Loans Servicing, LP, a wholly-owned subsidiary of CHL
      (collectively the "Company") provides this platform-level assessment, for which
      Countrywide Financial Corporation and such subsidiaries participated in
      servicing functions, as such term is described under Title 17, Section 229.1122
      of the Code of Federal Regulations ("Item 1122 of Regulation AB"), of compliance
      in respect of the following Applicable Servicing Criteria specified in Item
      1122(d) of Regulation AB promulgated by the Securities and Exchange Commission
      in regard to the following servicing platform for the following
      period:




Platform:
      publicly-issued (i.e., registered with the Securities and Exchange Commission
      pursuant to the Securities Act of 1933, as amended) residential mortgage-backed
      securities (securities collateralized by residential mortgage loans, including
      prime, alternative loan products, sub-prime, HELOC and closed seconds) issued
      on
      or after January 1, 2006 for which the Company provides cash collection and
      administration, investor remittances and reporting (except for those activities
      relating to trustee and paying agent services), and pool asset administration
      (except for those activities relating to custodial operations of pool assets
      and
      related documents), collectively "Servicing Functions" and for which the related
      issuer has a fiscal year end of December 31, 2006. The platform excludes any
      transactions issued by any government sponsored enterprise for which the Company
      provides Servicing Functions.




Period:
      as of and for the year ended December 31, 2006.




Applicable
      Servicing Criteria: all servicing criteria set forth in Item 1122(d), to the
      extent required in the related agreements, except for the following paragraphs:
      1122(d)(1)(iii), 1122(d)(3)(i)(B), only as it relates to information other
      than
      that contained in the monthly remittance report delivered by the servicer to
      the
      master servicer, trustee, and/or bond administrator, 1122(d)(3)(i)(D), only
      as
      it relates to the agreeing with investors' records as to the total unpaid
      principal balance and number of pool assets serviced by the servicer,
      1122(d)(3)(ii), only as it relates to amounts other than amounts remitted by
      the
      servicer to the master servicer, trustee, and/or bond administrator,
      1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(i) and 1122(d)(4)(ii), only as
      1122(d)(4)(i) and 1122(d)(4)(ii) relate to the custodial operations of the
      pool
      assets and related documents (collateral file) by the document custodian
      responsible for such functions for the related transaction, and 1122(d)(4)(xv),
      only as it relates to Item 1115 of Regulation AB (derivative
      transactions).











With
      respect to the Platform and the Period, the Company provides the following
      assessment of compliance in respect of the Applicable Servicing
      Criteria:




1.
      The
      Company is responsible for assessing its compliance with the Applicable
      Servicing Criteria.




2.
      The
      Company has assessed compliance with the Applicable Servicing
      Criteria.




3.
      Other
      than as identified on Schedule A hereto, as of and for the Period, the Company
      was in material compliance with the Applicable Servicing Criteria.




KPMG
      LLP,
      an independent registered public accounting firm, has issued an attestation
      report with respect to the Company's foregoing assessment of
      compliance.











COUNTRYWIDE
              FINANCIAL CORPORATIONBy:
            /s/ Steve
              BaileySteve
              BaileyIts:
            Senior
              Managing Director and Chief Executive Officer,
              Loan AdministrationDated:
            February
              28, 2007By:
            s/
              Kevin MeyersKevin
              MeyersIts:
            Managing
              Director and Chief Financial Officer, 
              Countrywide Home Loans, Inc. LoanAdministrationDated:
            February
              28, 2007


















Schedule
      A





Material
      Instances of Noncompliance





No
      material instances of noncompliance: the Company has complied, in all material
      respects, with the applicable servicing criteria as of and for the year ended
      December 31, 2006.