**Report
        on
        Assessment of Compliance with Regulation AB Servicing Criteria**
  1.
            Pursuant
                to Subpart 229.1100 - Asset Backed Securities, 17 C.F.R.
                §§229.1100-229.1123 ("Regulation
                AB").
                Regulus Group LLC, for itself and its wholly-owned subsidiaries
                (individually and collectively "Regulus"),
                is responsible for assessing its compliance with the servicing criteria
                applicable to the remittance processing services it provides to customers
                who are issuers or servicers of asset backed securities transactions
                and
                who have requested confirmation of Regulus' compliance in connection
                with
                loan and/or receivables portfolios that include pool assets for asset
                backed securities transactions (the "Platform").
                Remittance processing is a service whereby check payments that are
                remitted by mail to a post office box are collected, processed through
                a
                highly
                automated data capture system, and prepared for deposit to a bank
                account
                held by the beneficiary of the
                payment.  2.
            The
                servicing criteria set forth in Item 1122(d)of Regulation AB were
                used in
                Regulus' assessment of compliance. Regulus has concluded that the
                servicing criteria set forth in Items 1122(d)(2)(i) and 1122(d)(4)(iv)
                of
                Regulation AB are applicable to the servicing activities
                it performs with respect to the Platform (such criteria the "Applicable
                Servicing Criteria").
                Regulus has concluded that the remainder of the servicing criteria
                set
                forth in Item
                1122(d) of Regulation AB are inapplicable to the activities it performs
                with respect to
                the Platform because Regulus does not participate in the servicing
                activities referenced by
                such servicing
                criteria.  3.
            As
                of and for the year ending December 31, 2006, Regulus has complied
                in all
                material respects with the Applicable Servicing Criteria set forth
                in Item
                1122(d) of Regulation AB.  4.
            KPMG
                LLP, a registered public accounting firm, has issued an attestation
                report
                on Regulus'
                assessment of compliance with the Applicable Servicing Criteria as
                of and
                forthe
                year ending December 31, 2006. A copy of that attestation report
                is
                attached heretoas
                Exhibit A.   /s/
        Kimberlee Clark
 Kimberlee
        Clark
 Chief
        Financial Officer
  February
        22, 2007
    860
        LATOUR
        COURT   ¦   NAPA, CA   ¦ 
 94558   ¦   TEL: 707.254.4000  
¦   FAX: 707.254.4070   ¦   REGULUSGROUP.COM 
 
   
  **KPMG
                  LLP**1601
                  Market StreetPhiladelphia,
                  PA 19103-2499
  Report
          of Independent Registered Public Accounting Firm
  The
          Board
          of Members
 Regulus
          Group LLC:
  We
          have
          examined management's assessment for those customers that management has
          informed us
          have
          requested confirmation of compliance, included in the accompanying Report
          on Assessment
          of Compliance with Regulation AB Servicing Criteria, that Regulus Group
          LLC
          complied with the servicing criteria set forth in Item 1122(d)(2)(i) and
          1122(d)(4)(iv) of the Securities
          and Exchange Commission's Regulation AB for remittance processing services
          to those
          issuers of asset backed securities and servicers of loan and/or receivables
          portfolios that include
          pool assets for asset backed securities transactions (the Platform) as
          of and
          for the year ended
          December 31, 2006. Regulus Group LLC has determined that the remainder
          of the servicing
          criteria are not applicable to the activities it performs with respect
          to the
          Platform as of and
          for
          the year ended December 31, 2006. Management is responsible for the Company's compliance
          with those servicing criteria. Our responsibility is to express an opinion
          on management's
          assessment about the Company's compliance based on our examination.
  Our
          examination was conducted in accordance with the standards of the Public
          Company Accounting
          Oversight Board (United States) and, accordingly, included examining, on
          a test basis,
          evidence about the Company's compliance with the servicing criteria specified
          above and performing
          such other procedures as we considered necessary in the circumstances.
          Our examination
          included testing of less than all of the individual asset-backed transactions
          and securities
          that comprise the Platform, testing of less than all of the servicing activities
          related to the
          Platform, and determining whether the Company processed those selected
          transactions and performed those selected activities in compliance with
          the
          servicing criteria. Furthermore, our procedures
          were limited to the selected transactions and servicing activities performed
          by
          the Company
          during the period covered by this report. Our procedures were not designed
          to determine
          whether errors may have occurred either prior to or subsequent to our tests
          that
          may have
          affected the balances or amounts calculated or reported by the Company
          during
          the period covered
          by this report for the selected transactions or any other transactions.
          We
          believe that our examination
          provides a reasonable basis for our opinion. Our examination does not provide
          a legal
          determination on the Company's compliance with the servicing
          criteria.
  In
          our
          opinion, management's assessment that the Company complied with the
          aforementioned servicing
          criteria as of and for the year ended December 31, 2006 is fairly stated,
          in all
          material respects.
  /s/
          KPMG LLP
 Philadelphia,
          PA
 February
          22, 2007