EXHIBIT 33.7

           Report on Assessment of Compliance with Servicing Criteria
                       for Year End December 31, 2006 of
                Countrywide Home Loans Servicing LP, as Servicer


Countrywide Home Loans
2900 Madera Road
Simi 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,  L.P.,  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 CORPORATION

                By:    /s/ Steve Bailey
                       -----------------------------------------------------
                Its:   Senior Managing Director and Chief Executive Officer,
                       Loan Administration

                Dated: February 28, 2007


                By:    /s/ Kevin Meyers
                       -----------------------------------------------------
                Its:   Managing Director and Chief Financial Officer,
                       Countrywide Home Loans, Inc. Loan Administration

                Dated: 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.