----

| 1.   | The      Company is responsible for assessing its compliance with the Applicable      Servicing Criteria. |
|----------------|-----------------------------------------------------------------------------------------------------------|

| 2.   | The      Company assessed compliance with the Applicable Servicing Criteria. In      performing this assessment, management used the criteria set forth by the      Securities and Exchange Commission in paragraph (d) of Item 1122 of      Regulation AB. |
|----------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

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

----

----

| The      Bank of New YorkThe      Bank of New York Trust       Company, N.A. |   | The Bank of New      York |   |
|-----------------------------------------------------------------------------------|--------|---------------------------|--------|

| /s/ Patrick J.      Tadie |   | /s/ Samir      Pandiri  |   |
|---------------------------|--------|-------------------------|--------|
| Patrick J.      Tadie     |   | Samir    Pandiri        |   |
| Authorized      Officer   |   | Authorized      Officer |   |

----

----

| REG      AB REFERENCE | SERVICING      CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | APPLICABLE      TO PLATFORM | NOT      APPLICABLETO      PLATFORM |
|-----------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------|-------------------------------------|
|                  | 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                           |                                |
| 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 over collateralization, are separately      maintained (e.g., with respect to commingling of cash) as set forth in the      transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | X                           |                                |
| 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                           |                                |

----

----

| REG      AB REFERENCE | SERVICING      CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | APPLICABLE      TO PLATFORM | NOT      APPLICABLETO      PLATFORM |
|-----------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------|-------------------------------------|
|                  | 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                           |                                |
| 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                           |                                |
| 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 aqreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | 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                           |                                |
| 1122(d)(4)(ii)        | [pool      asset] and related documents, are safeguarded as required by the      transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | 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                                   |

----

----

| REG      AB REFERENCE | SERVICING      CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | APPLICABLE      TO PLATFORM | NOT      APPLICABLETO      PLATFORM |
|-----------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------|-------------------------------------|
| 1122(d)(4)(viii)      | Records      documenting collection efforts are maintained 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 oh 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                                   |
| 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                           |                                |

----