EX-33.5


(logo) WELLS FARGO




Brian W. Bartlett


Executive Vice President


and Business Manager




Corporate Trust Services


MAC N2702-011


9062 Old Annapolis Road


Columbia, MD 21045


410 884-2087


410 715-1690 Fax


brian.bartlett@wellsfargo.com




Wells Fargo Bank, N.A.






ASSESSMENT OF COMPLIANCE WITH THE APPLICABLE SERVICING CRITERIA




Corporate Trust Services division of Wells Fargo Bank, National Association (the


"Company") is responsible for assessing compliance with the servicing criteria


set forth in Item 1122(d) of Regulation AB promulgated by the Securities and


Exchange Commission. The Company has determined that the servicing criteria are


applicable in regards to the servicing platform for the period as follows:




Platform: Publicly-issued (i.e., transaction-level reporting initially required


under the Securities Exchange Act of 1934, as amended) and certain


privately-issued (i.e., for which transaction-level reporting is required


pursuant to contractual obligation) residential mortgage-backed securities,


commercial mortgage-backed securities and other asset-backed securities, for


which the Company provides master servicing, trustee, securities administration


or paying agent services, excluding any such securities issued by any agency or


instrumentality of the U.S. government (other than the Federal Deposit Insurance


Company) or any government sponsored entity, and further excluding the


transactions issued prior to 2006 for which Wells Fargo outsources all material


servicing activities (as defined by Regulation AB)(the "Platform").




Applicable Servicing Criteria: All servicing criteria set forth in Item


1122(d), to the extent required in the related transaction agreements, or


required by the Item 1122(d) servicing criteria in regards to the activities


performed by the Company, except for the following criteria: 1122(d)(4)(ii),


1122(d)(4)(iv), 1122(d)(4)(v), 1122(d)(4)(viii), 1122(d)(4)(ix),


1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii) and 1122(d)(4)(xiii), which


Management has determined are not applicable to the activities the Company


performs with respect to the Platform ("the Applicable Servicing Criteria").




Period: As of and for the twelve months ended December 31, 2011 (the "Period").




Third parties classified as vendors: With respect to servicing criterion


1122(d)(4)(i), the Company has engaged a vendor to handle certain Uniform


Commercial Code filing functions required by the servicing criterion. The


Company has determined that this vendor is not considered a "servicer" as


defined in Item 1101(j) of Regulation AB, and the Company elects to take


responsibility for assessing compliance with the portion of the servicing


criterion applicable to this vendor as permitted by Interpretation 17.06 of the


SEC Division of Corporation Finance Manual of Publicly Available Telephone


Interpretations ("Interpretation 17.06"). The Company has policies and


procedures in place to provide reasonable assurance that the vendor's


activities comply in all material respects with the servicing criterion


applicable to the vendor. The Company is solely responsible for determining


that it meets the SEC requirements to apply Interpretation 17.06 for the vendor


and related criterion.




With respect to the Platform and the Period, the Company provides the following


assessment of compliance with respect to the Applicable Servicing Criteria:




1. The Company is responsible for assessing its compliance with the Applicable


Servicing Criteria.




2. The Company has assessed compliance with the Applicable Servicing Criteria,


including the servicing criterion for which compliance is determined based on


Interpretation 17.06 as described above. In performing this assessment,


management used the criteria set forth by the Securities and Exchange


Commission in paragraph (d) of Item 1122 of Regulation AB.




3. Based on such assessment, the Company has complied, in all material respects


with the Applicable Servicing Criteria, except as described in Schedule A


hereto.




4. Schedule B hereto includes Management's discussion of the exceptions noted in


Schedule A, including remediation efforts taken by the Company.




KPMG LLP, an independent registered public accounting firm, has issued an


attestation report on the Company's compliance with the Applicable Servicing


Criteria for the Period.






WELLS FARGO BANK, National Association




By: /s/ Brian Bartlett


Brian Bartlett




Its: Executive Vice President




Dated: February 27, 2012






(page)






Schedule A




Material Instances of Noncompliance by the Company




Management's assessment of compliance with the Applicable Servicing Criteria


set forth by the Securities and Exchange Commission in paragraph (d) of Item


1122 of Regulation AB as of December 31, 2011 and for the Period, disclosed


that material noncompliance occurred with servicing criteria 1122(d)(3)(i)(B)


and 1122(d)(3)(ii), as fol1ows:




* With respect to servicing criterion 1122(d)(3)(i)(B), certain reports to


investors did not provide information calculated in accordance with the terms


specified in the transaction agreements.




* With respect to servicing criterion 1122(d)(3)(ii), certain amounts due to


investors were not allocated and remitted in accordance with timeframes,


distribution priority and other terms set forth in the transaction agreements.






Schedule B




Management's Discussion on Material Instances of Noncompliance by the Company




Disclosure: During the Period, (i) certain amounts allocated and remitted to


investors were not calculated in accordance with the terms specified in the


transaction agreements, and (ii) certain reports to investors did not provide


information calculated in accordance with the terms specified in the


transaction agreements with respect to waterfall calculations and/or reporting


disclosures. As part of its assessment of compliance with the Applicable


Servicing Criteria, Management identified that in certain instances the


material noncompliance reported in Schedule A hereto was attributable to errors


in the models impacting payments to investors and reporting disclosures,


including those for a subset of RMBS transactions in the Platform that contain


multi-group features, herein referred to as "Subject Transactions". As


Management has determined the modeling errors for Subject Transactions to be


the most significant issue resulting in material instances of noncompliance,


Management's analysis of this issue's impact on the Platform for the Period is


described below in the "Scope".




Scope: Management reviewed all of the distributions to investors during the


Period for the Subject Transactions and all of the models used to prepare


reports to investors for the Subject Transactions and determined that (i) the


total dollar amount of payment errors in excess of $5,000 for any particular


distribution during the Period when aggregating the payment errors for each


affected CUSIP, herein referred to as "Disclosed Errors", for the Subject


Transactions represented approximately one one-thousandth of one percent


(.001%) of the total dollar amount allocated and remitted to investors in all


transactions across the Platform during the Period, (ii) the tranches with


payment errors above $200 for the Subject Transactions with Disclosed Errors


comprised less than one-tenth of one percent (0.1%) of the number of tranches in


the Platform as of December 31, 2011, (iii) there were 17 Subject Transactions


with Disclosed Errors comprising less than one percent (1%) of the total number


of transactions in the Platform as of December 31, 2011, and (iv) 340 of the


Subject Transactions, including those transactions with Disclosed Errors,


required model revisions.




Remediation: For each of the instances of material noncompliance identified by


Management, including Subject Transactions, adjustments have been made to the


waterfall models, as applicable so that the models, in all material respects,


are expected to prepare the investor reports in accordance with the terms


specified in the transaction agreements. Revisions also have been made so that


the investor reports associated with the instances of material noncompliance


are expected to provide information that is, in all material respects,


calculated in accordance with the terms specified in the transaction


agreements.