EXHIBIT 33.3

           Report on Assessment of Compliance with Servicing Criteria
                         for Year End December 31, 2006
             of Deutsche Bank National Trust Company, as Custodian




                                                                     Appendix I

                      MANAGEMENT'S ASSERTION OF COMPLIANCE

Management  of the Trust &  Securities  Services  department  of  Deutsche  Bank
National  Trust Company and Deutsche Bank Trust Company  Americas  (collectively
the  "Company")  is  responsible  for  assessing  compliance  with the servicing
criteria  set  forth  in  Item  1122(d)  of  Regulation  AB  promulgated  by the
Securities and Exchange Commission. Management has determined that the servicing
criteria are  applicable in regard to the  servicing  platform for the period as
follows:

Platform:  Publicly-issued (i.e., transaction-level reporting required under the
Securities  Exchange  Act  of  1934,  as  amended)  residential  mortgage-backed
securities and other asset-backed  securities issued on or after January 1, 2006
for which the Company  provides  trustee,  securities  administration  or paying
agent services,  excluding any publicly issued transactions  sponsored or issued
by any government sponsored entity (the "Platform").

Applicable  Servicing  Criteria:  All servicing criteria set forth Item 1122(d),
except   for   the   following   criteria:   1122(d)(2)(iii),    1122(d)(4)(iv),
1122(d)(4)(v), 1122(d)(vi), 1122(d)(4)(vii),  1122(d)(4)(viii),  1122(d)(4)(ix),
1122(d)(4)(x),    1122(d)(4)(xi),    1122(d)(4)(xii),    1122(d)(4)(xiii)    and
1122(d)(4)(xiv),  which  management  has  determined  are not  applicable to the
activities  the Company  performs with respect to the Platform (the  "Applicable
Servicing Criteria").

Period: Twelve months ended December 31, 2006 (the "Period").

Management's  interpretation  of Applicable  Servicing  Criteria:  The Company's
management has determined that servicing criteria  1122(d)(1)(iii) is applicable
only with respect to its continuing obligation to act as, or locate a, successor
servicer under the circumstances referred to in certain governing documents.  It
is management's  interpretation  that Deutsche Bank Trust Company America has no
other active back-up servicing responsibilities in regards to 1122(d)(1)(iii) as
of and for the Period.

Third  parties  classified  as  vendors:  With  respect  to  servicing  criteria
1122(d)(2)(i), 1122(d)(4)(i), and 1122(d)(4)(ii), management has engaged various
vendors to perform the  activities  required by these  servicing  criteria.  The
Company's  management  has  determined  that these vendors are not  considered a
"servicer"  as  defined  in Item  1101(j) of  Regulation  AB, and the  Company's
management has elected to take responsibility for assessing  compliance with the
servicing  criteria  applicable  to each vendor as permitted  by  Interpretation
17.06 of the SEC Division of Corporation  Finance  Manual of Publicly  Available
Telephone   Interpretations    ("Interpretation   17.06").   As   permitted   by
Interpretation  17.06,   management  has  asserted  that  it  has  policies  and
procedures in place to provide reasonable assurance that the vendor's activities
comply in all material respects with the servicing  criteria  applicable to each
vendor.  The Company's  management is solely responsible for determining that it
meets the SEC requirements to apply Interpretation 17.06 for vendors and related
criteria.

With respect to the Platform,  the Company's  management  provides the following
assertion of compliance with respect to the Applicable Servicing Criteria:

1.   The  Company's  management  is  responsible  for  assessing  the  Company's
     compliance with the Applicable Servicing Criteria as of and for the Period.

2.   The  Company's  management  has  assessed  compliance  with the  Applicable
     Servicing  Criteria,  including  servicing criteria for which compliance is
     determined based on Interpretation  17.06 as described above, as of and for
     the Period. In performing this assessment, management used the criteria set
     forth by the  Securities  and Exchange  Commission in paragraph (d) of Item
     1122 of Regulation AB.

3.   Based  on such  assessment,  as of and  for the  Period,  the  Company  has
     complied, in all material respects, with the Applicable Servicing Criteria.

KPMG LLP, a registered public accounting firm, has issued an attestation  report
with respect to the  management's  assertion of compliance  with the  Applicable
Servicing Criteria as of and for the Period.

                        DEUTSCHE BANK NATIONAL TRUST COMPANY

                        By: /s/ Gary R. Vaughan
                        ------------------------------------
                                Gary R. Vaughan
                                Its: Managing Director

                        By: /s/ David Co
                        ------------------------------------
                                David Co
                                Its: Director

                        By: /s/ Jose Sicilia
                        ------------------------------------
                                Jose Sicilia
                                Its: Managing Director

                        By: /s/ Kevin Fischer
                        ------------------------------------
                                Kevin Fischer
                                Its: Vice President

                        By: /s/ Robert Frier
                        ------------------------------------
                                Robert Frier
                                Its: Director


                        DEUTSCHE BANK TRUST COMPANY AMERICAS

                        By: /s/ Kevin C. Weeks
                        ------------------------------------
                                Kevin C. Weeks
                                Its: Managing Director

                        By: /s/ Jonna Kaufman
                        ------------------------------------
                                Jonna Kaufman
                                Its: Director