Exhibit 33.1

Certification Regarding Compliance with
Applicable Servicing Criteria

|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|-- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|1. | USAA Federal
  Savings Bank (FSB) is responsible for assessing compliance with the
  servicing criteria applicable to it under paragraph (d) of Item 1122 of
  Regulation AB, as of December 31, 2006 and for the period from February 22,
  2006 through December 31, 2006 (the Reporting Period), as set forth in
  Appendix A hereto. The transactions covered by this report include
  asset-backed securities transactions for which FSB acted as servicer
  involving retail auto loans other than transactions consummated prior to the
  effectiveness of Regulation AB (the Platform);
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|2. | Except as
  set forth in paragraph 4 below, FSB used the criteria set forth in paragraph
  (d) of Item 1122 of Regulation AB to assess the compliance with the
  applicable servicing criteria;                                                                                                                                                                                                                                                                                                                                                                                                      
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|3. | The criteria
  listed in the columns titled Inapplicable Servicing Criteria on Appendix A
  hereto are inapplicable to FSB based on the activities it performs with
  respect to the Platform;                                                                                                                                                                                                                                                                                                                                                                                                     
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|4. | FSB has
  complied, in all material respects, with the applicable servicing criteria as
  of December 31, 2006 and for the Reporting Period with respect to the
  Platform taken as a whole, except as described on Appendix B hereto; and                                                                                                                                                                                                                                                                                                                                                           
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|5. | Ernst &
  Young LLP, an independent registered public accounting firm, has issued an
  attestation report for the Platform on FSBs assessment of compliance with
  the applicable servicing criteria for the Reporting Period.                                                                                                                                                                                                                                                                                                                                                                      

|                 |                                                   | 
|---------------- | ------------------------------------------------- | 
|                 | USAA FEDERAL
  SAVINGS BANK                      
|                 |                                                  
|                 | /s/ FRITZ D.
  BOHNE                             
|                 |                                                   | 
|                 | By:                                               | 
|                 |                                                   | 
|                 |                                                  
|                 | Name: Fritz
  D. Bohne                           
|                 | Title: Vice
  President, Senior Financial Officer
|                 |                                                   | 
|March
  29, 2007 |                                                  

---



APPENDIX A

|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|-------------------- |  | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------------ |  | ------------------------------------------------------------------------- |  | --------------------------------------------------------------------------------------------------- |  | ----------------------------------------------------------------------------------
|SERVICING
  CRITERIA |  | APPLICABLE
  
  SERVICING CRITERIA                                                                                                                                                                                                                                      |  | INAPPLICABLE
  SERVICING 
  CRITERIA
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                          
|Reference            |  | Criteria                                                                                                                                                                                                                                                                |  | Performed
  Directly
  by
  FSB      |  | Performed
  by
  Vendor(s)
  for which
  FSB is the
  Responsible
  Party |  | Performed
  by
  subservicer(s)
  or vendor(s)
  for which
  FSB is NOT
  the
  Responsible
  Party |  | NOT
  performed by
  FSB or by
  subservicer(s)
  or vendor(s)
  retained by
  FSB
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  | General
  Servicing Considerations                                                                                                                                                                                                                                      |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(1)(i)        |  | Policies and procedures are instituted to monitor
  any performance or other triggers and events of default in accordance with
  the transaction agreements.                                                                                                            |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(1)(ii)       |  | 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 such servicing activities.                                                                |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(1)(iii)      |  | Any requirements in the transaction agreements to
  maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                     |  |                                      |  |                                                                           |  |                                                                                                     |  | X                                                                                 
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(1)(iv)       |  | 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 terms of the transaction agreements. |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  | Cash Collection and Administration                                                                                                                                                                                                                                      |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(2)(i)        |  | Payments on pool assets 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 transaction agreements.                     |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(2)(ii)       |  | Disbursements made via wire transfer on behalf of an
  obligor or to an investor are made only by authorized personnel.                                                                                                                                                 |  | X                                    |  |                                                                           |  | X                                                                                                   |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(2)(iii)      |  | 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 approved as specified in
  the transaction agreements.                                         |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                         |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(2)(iv)       |  | 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 transaction agreements.             |  |                                      |  |                                                                           |  | X                                                                                                   |  |                                                                                   

---



|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|-------------------- |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------------ |  | ------------------------------------------------------------------------- |  | --------------------------------------------------------------------------------------------------- |  | ----------------------------------------------------------------------------------
|SERVICING
  CRITERIA |  | APPLICABLE
  
  SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  | INAPPLICABLE
  SERVICING 
  CRITERIA
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                          
|Reference            |  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  | Performed
  Directly
  by
  FSB      |  | Performed
  by
  Vendor(s)
  for which
  FSB is the
  Responsible
  Party |  | Performed
  by
  subservicer(s)
  or vendor(s)
  for which
  FSB is NOT
  the
  Responsible
  Party |  | NOT
  performed by
  FSB or by
  subservicer(s)
  or vendor(s)
  retained by
  FSB
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(2)(v)        |  | 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 13k-1(b)(1) of the Securities
  Exchange Act.                                                                                                                                                                                                                                                                                                                              |  |                                      |  |                                                                           |  | X                                                                                                   |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(2)(vi)       |  | Unissued checks are safeguarded so as to prevent
  unauthorized access.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |  |                                      |  |                                                                           |  |                                                                                                     |  | X                                                                                 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(2)(vii)      |  | 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 agreements. |  | X                                    |  |                                                                           |  | X                                                                                                   |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  | Investor Remittances and Reporting                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(3)(i)        |  | 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 pool assets serviced by the Servicer.                                                |  | X                                    |  |                                                                           |  | X                                                                                                   |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(3)(ii)       |  | Amounts due to investors are allocated and remitted
  in accordance with timeframes, distribution priority and other terms set
  forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  |                                      |  |                                                                           |  | X                                                                                                   |  |                                                                                   

---



|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|-------------------- |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------------ |  | ------------------------------------------------------------------------- |  | --------------------------------------------------------------------------------------------------- |  | ----------------------------------------------------------------------------------
|SERVICING
  CRITERIA |  | APPLICABLE
  
  SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                     |  | INAPPLICABLE
  SERVICING 
  CRITERIA
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                          
|Reference            |  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                               |  | Performed
  Directly
  by
  FSB      |  | Performed
  by
  Vendor(s)
  for which
  FSB is the
  Responsible
  Party |  | Performed
  by
  subservicer(s)
  or vendor(s)
  for which
  FSB is NOT
  the
  Responsible
  Party |  | NOT
  performed by
  FSB or by
  subservicer(s)
  or vendor(s)
  retained by
  FSB
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(3)(iii)      |  | 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 agreements.                                                                                                                                                                                                                                    |  |                                      |  |                                                                           |  | X                                                                                                   |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(3)(iv)       |  | Amounts remitted to investors per the investor
  reports agree with cancelled checks, or other form of payment, or custodial
  bank statements.                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  | X                                                                                                   |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  | Pool Asset Administration                                                                                                                                                                                                                                                                                                                                                                                              |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(i)        |  | Collateral or security on pool assets is maintained
  as required by the transaction agreements or related mortgage loan documents.                                                                                                                                                                                                                                                                                    |  | X                                    |  |                                                                           |  | X                                                                                                   |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(ii)       |  | pool asset and related documents are safeguarded as
  required by the transaction agreements                                                                                                                                                                                                                                                                                                                           |  | X                                    |  |                                                                           |  | X                                                                                                   |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(iii)      |  | Any additions, removals or substitutions to the
  asset pool are made, reviewed and approved in accordance with any conditions
  or requirements in the transaction agreements.                                                                                                                                                                                                                                        |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(iv)       |  | Payments on pool assets, including any payoffs, made
  in accordance with the related pool asset 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 pool asset documents. |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(v)        |  | The Servicers records regarding the pool assets
  agree with the Servicers records with respect to an obligors unpaid
  principal balance.                                                                                                                                                                                                                                                                          |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(vi)       |  | Changes with respect to the terms or status of an
  obligors pool assets (e.g., loan modifications or re-agings) are made,
  reviewed and approved by authorized personnel in accordance with the
  transaction agreements and related pool asset documents.                                                                                                                                                          |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(vii)      |  | 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 transaction agreements.                                                                                                         |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   

---



|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|-------------------- |  | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------------ |  | ------------------------------------------------------------------------- |  | --------------------------------------------------------------------------------------------------- |  | ----------------------------------------------------------------------------------
|SERVICING
  CRITERIA |  | APPLICABLE
  
  SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  | INAPPLICABLE
  SERVICING 
  CRITERIA
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |                                      |  |                                                                          
|Reference            |  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |  | Performed
  Directly
  by
  FSB      |  | Performed
  by
  Vendor(s)
  for which
  FSB is the
  Responsible
  Party |  | Performed
  by
  subservicer(s)
  or vendor(s)
  for which
  FSB is NOT
  the
  Responsible
  Party |  | NOT
  performed by
  FSB or by
  subservicer(s)
  or vendor(s)
  retained by
  FSB
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(viii)     |  | Records documenting collection efforts are
  maintained during the period a pool asset 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 pool assets
  including, for example, phone calls, letters and payment rescheduling plans
  in cases where delinquency is deemed temporary (e.g., illness or
  unemployment).                                                                        |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(ix)       |  | Adjustments to interest rates or rates of return for
  pool assets with variable rates are computed based on the related pool asset
  documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  |                                      |  |                                                                           |  |                                                                                                     |  | X                                                                                 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(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 pool asset 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 pool
  asset documents and state laws; and (C) such funds are returned to the
  obligor within 30 calendar days of full repayment of the related pool assets,
  or such other number of days specified in the transaction agreements. |  |                                      |  |                                                                           |  |                                                                                                     |  | X                                                                                 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(xi)       |  | 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 number of days specified in
  the transaction agreements.                                                                                                                                                                                           |  |                                      |  |                                                                           |  |                                                                                                     |  | X                                                                                 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(xii)      |  | 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 omission.                                                                                                                                                                                                                                                                                                                                                           |  |                                      |  |                                                                           |  |                                                                                                     |  | X                                                                                 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(xiii)     |  | 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 specified in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                       |  |                                      |  |                                                                           |  |                                                                                                     |  | X                                                                                 

---



|                     |  |                                                                                                                                                                                   |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|-------------------- |  | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------------ |  | ------------------------------------------------------------------------- |  | --------------------------------------------------------------------------------------------------- |  | ----------------------------------------------------------------------------------
|SERVICING
  CRITERIA |  | APPLICABLE
  
  SERVICING CRITERIA                                                                                                                                                |  | INAPPLICABLE
  SERVICING 
  CRITERIA
|                     |  |                                                                                                                                                                                   |  |                                      |  |                                                                          
|Reference            |  | Criteria                                                                                                                                                                          |  | Performed
  Directly
  by
  FSB      |  | Performed
  by
  Vendor(s)
  for which
  FSB is the
  Responsible
  Party |  | Performed
  by
  subservicer(s)
  or vendor(s)
  for which
  FSB is NOT
  the
  Responsible
  Party |  | NOT
  performed by
  FSB or by
  subservicer(s)
  or vendor(s)
  retained by
  FSB
|                     |  |                                                                                                                                                                                   |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(xiv)      |  | Delinquencies, charge-offs and uncollectible
  accounts are recognized and recorded in accordance with the transaction
  agreements.                                              |  | X                                    |  |                                                                           |  |                                                                                                     |  |                                                                                   
|                     |  |                                                                                                                                                                                   |  |                                      |  |                                                                           |  |                                                                                                     |  |                                                                                   
|1122(d)(4)(xv)       |  | Any external enhancement or other support, identified
  in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained
  as set forth in the transaction agreements. |  |                                      |  |                                                                           |  |                                                                                                     |  | X                                                                                 

---



APPENDIX B

Material Instances of Noncompliance

During the Reporting Period, FSB has identified the
following material instances of noncompliance with the servicing criteria
applicable to it under paragraph (d) of Item 1122 of Regulation AB.

CFR Item 1122(d)(3)(i): The First Priority Principal
Payment in the monthly servicing reports filed as exhibits in two Reports on
Form 10-D was not calculated accurately. In addition, one Report on Form 10-D
required to be filed with the Commission was not timely filed.

Remediation Efforts

Processes have been corrected to ensure the First
Priority Principal Payment is calculated accurately for presentation in the
monthly servicing reports. In addition, processes have been improved to ensure
Reports on Form 10-D are filed timely.

---