EX-34.1


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Report of Independent Registered Public Accounting Firm






The Board of Directors and Shareholder


KeyCorp Real Estate Capital Markets, Inc.




We have examined management's assertion, included in the accompanying


Management's Assertion on Compliance with Regulation AB Criteria, that KeyCorp


Real Estate Capital Markets, Inc. (the Company) complied with the servicing


criteria set forth in Item 1122 (d) of the Securities and Exchange Commission's


Regulation AB for the commercial real estate mortgage loans platform (the


Platform) as of and for the year ended December 31, 2011, and except for Item


1122 (d)(3)(i), 1122 (d)(3)(ii), 1122 (d)(3)(iii) and 1122 (d)(3)(iv), which


the Company has determined are not applicable to the activities performed by


them with respect to the servicing platform covered by this report. Refer to


Attachment A of management's assertion for the asset backed transactions


covered by this platform. Management is responsible for the Company's


compliance with those servicing criteria. Our responsibility is to express an


opinion on management's assertion about the Company's compliance with the


servicing criteria based on our examination.




Our examination was conducted in accordance with attestation standards


established by the American Institute of Certified Public Accountants, as


adopted by the Public Company Accounting Oversight Board (United States) and,


accordingly, included examining, on a test basis, evidence about the Company's


compliance with the applicable servicing criteria and performing such other


procedures as we considered necessary in the circumstances. Our examination


included testing of less than all of the individual asset backed transactions


and securities that comprise the platform, testing of less than all of the


servicing activities related to the Platform and determining whether the


Company processed those selected transactions and performed those selected


activities in compliance with the servicing criteria. Furthermore, our


procedures were limited to the selected transactions and servicing activities


performed by the Company during the period covered by this report. Our


procedures were not designed to determine whether errors may have occurred


either prior to or subsequent to our tests that may have affected the balances


or amounts calculated or reported by the Company during the period covered by


this report for the selected transactions or any other transactions. Although


the Company is responsible for assessing compliance with Sections 1122


(d)(1)(ii) and 1122 (d)(1)(iii) of Regulation AB, there were no servicing


activities performed by the Company during the year ended December 31, 2011


that required these servicing criteria to be complied with. We believe that our


examination provides a reasonable basis for our opinion. Our examination does


not provide a legal determination on the Company's compliance with the


servicing criteria.




In our opinion, management's assertion that the Company complied with the


aforementioned servicing criteria as of and for the year ended December 31,


2011 for the commercial real estate mortgage loans platform is fairly stated,


in all material respects.




/s/ Ernst & Young LLP




February 27, 2012






A member firm of Ernst & Young Global Limited