Exhibit 33.1

[logo]                                                  Corporate Trust Services
                                                        MAC N2702-011
                                                        9062 Old Annapolis Road
                                                        Columbia, MD 21045
                                                        410 884-2000
                                                        410 715-2380 Fax

                                                        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) 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
publicly issued transactions issued by any agency or instrumentality of the
U.S. government 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, 2007 (the "Period").

Third parties classified as vendors: With respect to servicing criteria
1122(d)(4)(i), the Company has engaged various vendors to handle certain Uniform
Commercial Code filing functions required by the servicing criteria ("vendors").
The Company has determined that none of the vendors is 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 criteria applicable
to each 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 criteria applicable to each vendor. The Company is
solely responsible for determining that it meets the SEC requirements to apply
Interpretation 17.06 for the vendors and related criteria.

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 servicing criteria for which compliance is determined based on
Interpretation 17.06 as described above, as of and for the Period. 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.

KPMG LLP, a registered public accounting firm, has issued an attestation report
with respect to the Company's assessment of compliance as of and for the Period.

                                          WELLS FARGO BANK, NATIONAL ASSOClATION

                                          By:     /s/ Brian Bartlett
                                                  ------------------------------
                                                  Brian Bartlett

                                          Its:    Executive Vice President

                                          Dated:  February 29, 2008