EXHIBIT 33.1

ACS EDUCATION SERVICES, INC
MANAGEMENTS ASSESSMENT OF COMPLIANCE
WITH REGULATION AB SERVICING CRITERIA

ACS Education Services
Management Assessment

Management of Affiliated Computer Services, Inc. (ACS) Education
Services is responsible for assessing compliance with the applicable servicing
criteria set forth in Item 1122(d) of Regulation AB of the Securities and
Exchange Commission relating to the servicing of student loan backed security
transactions (the Platform), except for servicing criteria noted in Appendix A
as N/A, which ACS Education Services has determined are not
applicable to the activities it performs with respect to the Platform as of and
for the year ended December 31, 2006. Appendix B identifies the individual
asset-backed transactions and securities defined by management as constituting
the Platform.

With respect to servicing criteria 1122(d)(2)(i) and
1122(d)(4)(iv), management has engaged a vendor to perform the activities
required by the servicing criteria. ACS Education Services management has
determined that the vendor is not considered a servicer as defined
in Item 1101(j) of Regulation AB, and ACS Education Services management
has elected to take responsibility for assessing compliance with the servicing
criteria applicable to the 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, ACS Education Services management has asserted that
it has policies and procedures in place designed to provide reasonable assurance
that the vendors activities comply in all material respects with the
servicing criteria applicable to the vendors. ACS Education Services
management is solely responsible for determining that it meets the SEC
requirements to apply Interpretation 17.06 for the vendors and related
criteria.

ACS Education Services management has assessed the
effectiveness of the ACS Education Services compliance with the applicable
servicing criteria as of and for the year ended December 31, 2006. In making
this assessment, management used the criteria set forth by the Securities and
Exchange Commission in paragraph (d) of Item 1122 of Regulation AB.

Based on such assessment, management believes that, as of and
for the year ended December 31, 2006, ACS Education Services has complied in all
material respects with the servicing criteria set forth in Item 1122(d) of
Regulation AB of the Securities and Exchange Commission relating to the
servicing of the Platform, except for the material noncompliance with servicing
criterion 1122(d)(1)(iv) related to ACS Education Service having fidelity bond
and errors omissions policy coverage amounts and deductible levels below the
amounts required by the CLC Servicing Agreement during the year ended December
31, 2006. ACS Education Services has taken corrective action to increase the
amount of coverage and adjust the deductible levels to meet the CLC Servicing
Agreement requirements.

KPMG
LLP, a registered public accounting firm, has issued an attestation report with respect to
managements assessment of compliance with the applicable servicing criteria
as of and for the year ended December 31, 2006.

| | /s/ Meta Gonzalez
Meta Gonzalez, Sr. Vice PresidentMarch 28, 2007
             Date
| | -----------------------------------------------------------------------------------

Education Services
2277 East 220th Street  Long Beach, CA 90810
310.513.2700

Appendix A

SERVICING CRITERIA ADDRESSED IN ACS EDUCATION SERVICES' MANAGEMENT ASSESSMENT

Definitions:

X  Servicing criteria subject to assessment
N/A  Nonapplicable

`Reg AB Reference  Servicing Criteria                                                            Applicability
-------------------------------------------------------------------------------------------------------------------
                    General Servicing  Considerations
--------------------------------------------------------------------------------------------------------------------
  1122(d)(1)(i)     Policies and procedures are instituted to monitor any performance or                X
                    other triggers and events of default in accordance with the
                    transaction agreements.
--------------------------------------------------------------------------------------------------------------------
  1122(d)(1)(ii)    If any material servicing activities are outsourced to third                        X
                    parties, policies and procedures are instituted to monitor the third
                    party's performance and compliance with such servicing activities.
--------------------------------------------------------------------------------------------------------------------
  1122(d)(1)(iii)   Any requirements in the transaction agreements to maintain a back-up               N/A
                    servicer for the Pool Assets are maintained.
--------------------------------------------------------------------------------------------------------------------
  1122(d)(1)(iv)    A fidelity bond and errors and omissions policy is in effect on the                 X
                    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.
--------------------------------------------------------------------------------------------------------------------
                    Cash Collection and Administration
--------------------------------------------------------------------------------------------------------------------
   1122(d)(2)(i)    Payments on pool assets are deposited into the appropriate custodial bank           X
                    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.
--------------------------------------------------------------------------------------------------------------------
   1122(d)(2)(ii)   Disbursements made via wire transfer on behalf of an obligor or to an               X
                    investor are made only by authorized personnel.
--------------------------------------------------------------------------------------------------------------------
   1122(d)(2)(iii)  Advances of funds or guarantees regarding collections, cash flows or               N/A
                    distributions, and any interest or other fees charged for such advances,
                    are made, reviewed and approved as specified in the transaction agreements.
--------------------------------------------------------------------------------------------------------------------
   1122(d)(2)(iv)   The related accounts for the transaction, such as cash reserve accounts            N/A
                    or accounts established as a form of over collateralization, are
                    separately maintained (e.g., with respect to commingling of cash) as
                    set forth in the transaction agreements.
--------------------------------------------------------------------------------------------------------------------
   1122(d)(2)(v)    Each custodial account is maintained at a federally insured depository              X
                    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.
--------------------------------------------------------------------------------------------------------------------
   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                X
                    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.
 -------------------------------------------------------------------------------------------------------------------
                    Investor Remittances and Reporting
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(3)(i)    Reports to investors, including those to be filed with the Commission,             N/A
                    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.
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(3)(ii)   Amounts due to investors are allocated and remitted in accordance with             N/A
                    timeframes, distribution priority and other terms set forth in the
                    transaction agreements.
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(3)(iii)  Disbursements made to an investor are posted within two business days to           N/A
                    the Servicer's investor records, or such other number of days specified
                    in the transaction agreements.
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(3)(iv)   Amounts remitted to investors per the investor reports agree with                  N/A
                    cancelled checks, or other form of payment, or custodial bank
                    statements.
 -------------------------------------------------------------------------------------------------------------------
                    Pool Asset Administration
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(4)(i)    Collateral or security on pool assets is maintained as required by                  X
                    the transaction agreements or related pool asset documents.
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(4)(ii)   Pool assets and related documents are safeguarded as required by the                X
                    transaction agreements.
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(4)(iii)  Any additions, removals or substitutions to the asset pool are made,               N/A
                    reviewed and approved in accordance with any conditions or
                    requirements in the transaction agreements.
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(4)(iv)   Payments on pool assets, including any payoffs, made in accordance with             X
                    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.
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(4)(v)    The Servicer's records regarding the pool assets agree with the                     X
                    Servicer's records with respect to an obligor's unpaid principal
                    balance.
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(4)(vi)   Changes with respect to the terms or status of an obligor's pool assets             X
                    (e.g., loan modifications or reagings) are made, reviewed and approved by
                    authorized personnel in accordance with the transaction agreements and
                    related pool asset documents.
 -------------------------------------------------------------------------------------------------------------------
   1122(d)(4)(vii)  Loss mitigation or recovery actions (e.g., forbearance plans,                       X
                    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.
 -------------------------------------------------------------------------------------------------------------------
  1122(d)(4)(viii)   Records documenting collection efforts are maintained during the period            X
                     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).
--------------------------------------------------------------------------------------------------------------------
  1122(d)(4)ix)      Adjustments to interest rates or rates of return for pool assets with              X
                     variable rates are computed based on the related pool asset documents.
--------------------------------------------------------------------------------------------------------------------
  1122(d)(4)(x)      Regarding any funds held in trust for an obligor (such as escrow                  N/A
                     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.
--------------------------------------------------------------------------------------------------------------------
  1122(d)(4)(xi)     Payments made on behalf of an obligor (such as tax or insurance                   N/A
                     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.
--------------------------------------------------------------------------------------------------------------------
  1122(d)(4)(xii)    Any late payment penalties in connection with any payment to be made             N/A
                     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.
--------------------------------------------------------------------------------------------------------------------
  1122(d)(4)(xiii)   Disbursements made on behalf of an obligor are posted within two                  N/A
                     business days to the obligor's records maintained by the servicer, or
                     such other number of days specified in the transaction agreements.
--------------------------------------------------------------------------------------------------------------------
  1l22(d)(4)(xiv)    Delinquencies, charge-offs and uncollectible accounts are recognized               X
                     and recorded in accordance with the transaction agreements.
--------------------------------------------------------------------------------------------------------------------
  1122(d)(4)(xv)     Any external enhancement or other support, identified in Item 1114(a)(1)          N/A
                     through (3) or Item 1115 of Regulation AB, is maintained as set forth
                     in the transaction agreements.
--------------------------------------------------------------------------------------------------------------------`

Appendix B

INDIVIDUAL ASSET-BACKED
TRANSACTIONS AND SECURITIES DEFINED AS THE PLATFORM ADDRESSED IN ACS EDUCATION SERVICES
MANAGEMENT ASSESSMENT

`Lender Name                        Deal Date               Deal Number
-----------------------------------------------------------------------------
    Wachovia                           06/29/2006               I9233

                                       07/29/2006               I9368

                                       08/21/2006               I9457

                                       09/19/2006               I9570

                                       10/18/2006               I9663

                                       12/20/2006               I9872

    College Loan Corporation           04/24/2006               I8847

    GCO Education Loan Corp.           01/17/2006               I8666

                                       02/07/2006               I8749

                                       03/24/2006               I8926

                                       04/11/2006               I8965

                                       06/14/2006               I9184

                                       07/18/2006               I9338

                                       09/26/2006               I9517

                                       12/11/2006               I9822

                                       12/21/2006               I9869`