EX-33.1
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Assessment Regarding Compliance with Applicable Servicing Criteria


1.   Bank of America, National Association (the "Servicer") is responsible for
     assessing compliance by it with the servicing criteria applicable to it
     under paragraph (d) of Item 1122 of Regulation AB, as of December 31, 2007
     and for the period from January 1, 2007 through December 31, 2007 (the
     "Reporting Period"), as set forth in Appendix A hereto, in connection with
     asset-backed securities transactions involving commercial mortgage loan
     transactions that involved an offer or sale of asset-backed securities that
     were required to be registered on or after January 1, 2006 with the
     Securities and Exchange Commission pursuant to the Securities Act of 1933
     (the "Platform");

2.   The Servicer engaged certain vendors (the "Vendors") to perform certain
     specific limited or scripted activities during the Reporting Period,
     related to portions of the servicing criteria as set forth in Appendix A
     hereto (such portions of the servicing criteria include and only include,
     Item 1122(d)(2)(i) (only with respect to standard lockbox processing by
     depositing checks into the appropriate account indicated by the Servicer)
     and Item 1122(d)(4)(xi) (only with respect to verifying outstanding tax
     payments and processing such tax payments pursuant to the Servicer's
     direction)). The Servicer has elected to take responsibility for assessing
     compliance with the portion of the servicing criteria performed by such
     Vendors;

3.   Except as set forth in paragraph 4 below, the Servicer used the criteria
     set forth in paragraph (d) of Item 1122 of Regulation AB to assess the
     compliance with the applicable servicing criteria;

4.   The criteria in Items 1122(d)(1)(iii), 1122(d)(2)(ii) (other than with
     respect to obligors as disbursements are not made to investors),
     1122(d)(3)(i), 1122(d)(3)(ii), 1122(d)(3)(iii), 1122(d)(3)(iv),
     1122(d)(4)(ii), 1122(d)(4)(vii), 1122(d)(4)(viii) (other than for the
     period prior to a servicing transfer event (as defined in the transaction
     agreements)) and 1122(d)(4)(xv) (other than with respect to those items
     identified in Item 1114(a)(1)), of Regulation AB are inapplicable to the
     Servicer based on the activities it performs with respect to the Platform;

5.   The Servicer has complied, in all material respects with the applicable
     servicing criteria for the Reporting Period with respect to the Platform;

6.   The Servicer has not identified and is not aware of any material instance
     of noncompliance by the Vendors with the applicable servicing criteria for
     the Reporting Period with respect to the Platform;

7.   The Servicer has not identified any material deficiency in its policies and
     procedures to monitor the compliance by the Vendors with the applicable
     servicing criteria for the Reporting Period with respect to the Platform;
     and


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8. PricewaterhouseCoopers LLP, an independent registered public accounting firm,
has issued an attestation report on the Servicer's assessment of compliance with
the applicable servicing criteria as of December 31, 2007 and for the Reporting
Period.

February 27, 2008

BANK OF AMERICA, NATIONAL
ASSOCIATION

By: /s/ Janice M. Smith
Name: Janice M. Smith
Title: Managing Director


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APPENDIX A

<TABLE>
<CAPTION>
                                                                       APPLICABLE SERVICING
                             SERVICING CRITERIA                             CRITERIA

Reference                        Criteria                         Servicer            Vendor
<S>                                <C>                              <C>                <C>

                   General Servicing Considerations

1122(d)(1)(i)      Policies and procedures are instituted            X
                   to monitor any performance or other
                   triggers and events of default in
                   accordance with the transaction
                   agreements.

1122(d)(1)(ii)     If any material servicing activities              X
                   are outsourced to third 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 servicer
                   for the mortgage loans are maintained.

1122(d)(1)(iv)     A fidelity bond and errors and                    X
                   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.



                   Cash Collection and Administration

1122(d)(2)(i)      Payments on mortgage loans are deposited          X                  X (only with respect
                   into the appropriate custodial bank                                  to standard lockbox
                   accounts and related bank clearing                                   processing by
                   accounts no more than two business days                              depositing checks
                   following receipt, or such other number                              into the appropriate
                   of days specified in the transaction                                 account indicated by
                   agreements.                                                          the Servicer)

1122(d)(2)(ii)     Disbursements made via wire transfer on           X (only with
                   behalf of an obligor or to an investor are        respect to
                   made only by authorized personnel.                obligors as
                                                                     disbursements
                                                                     are not made
                                                                     to investors)

1122(d)(2)(iii)    Advances of funds or guarantees                   X
                   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.

1122(d)(2)(iv)     The related accounts for the                      X
                   transaction, such as cash reserve
                   accounts or accounts established as a
                   form of overcollateralization, 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           X
                   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.

1122(d)(2)(vi)     Unissued checks are safeguarded so as             X
                   to prevent unauthorized access.

1122(d)(2)(vii)    Reconciliations are prepared on a                 X
                   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.

<CAPTION>
                                                                       APPLICABLE SERVICING
                             SERVICING CRITERIA                             CRITERIA

Reference                        Criteria                         Servicer            Vendor
<S>                                <C>                              <C>                <C>

                   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 mortgage
                   loans serviced by the Servicer.



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.

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
                   agreements.

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.



                   Pool Asset Administration

1122(d)(4)(i)      Collateral or security on mortgage loans          X
                   is maintained as required by the
                   transaction agreements or related mortgage
                   loan documents.

1122(d)(4)(ii)     Mortgage loan and related documents are
                   safeguarded as required by the
                   transaction agreements.

1122(d)(4)(iii)    Any additions, removals or                        X
                   substitutions to the asset pool are made,
                   reviewed and approved in accordance with
                   any conditions or requirements in the
                   transaction agreements.

1122(d)(4)(iv)     Payments on mortgage loans, including any         X
                   payoffs, made in accordance with related
                   mortgage loan 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 mortgage loan documents.

1122(d)(4)(v)      The Servicer's records regarding the              X
                   mortgage loans agree with the Servicer's
                   records with respect to an obligor's
                   unpaid principal balance.

1122(d)(4)(vi)     Changes with respect to the terms or              X
                   status of an obligor's mortgage loans (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.

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.

1122(d)(4)(viii)   Records documenting collection efforts            X (only for the
                   are maintained during the period a mortgage       period prior to
                   loan is delinquent in accordance with             a servicing
                   the transaction agreements. Such records          transfer event
                   are maintained on at least a monthly              (as defined in
                   basis, or such other period specified in          the transaction
                   the transaction agreements, and describe          agreements))
                   the entity's activities in monitoring
                   delinquent mortgage loans 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            X
                   of return for mortgage loans with variable
                   rates are computed based on the related
                   mortgage loan documents.

<CAPTION>
                                                                       APPLICABLE SERVICING
                             SERVICING CRITERIA                             CRITERIA

Reference                        Criteria                         Servicer            Vendor
<S>                                <C>                              <C>                <C>

1122(d)(4)(x)      Regarding any funds held in trust for             X
                   an obligor (such as escrow accounts): (A)
                   such funds are analyzed, in accordance
                   with the obligor's mortgage loan 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 mortgage loan
                   documents and state laws; and (C) such
                   funds are returned to the obligor within
                   30 calendar days of full repayment of the
                   related mortgage loans, or such other number
                   of days specified in the transaction
                   agreements.


1122(d)(4)(xi)     Payments made on behalf of an obligor             X                  X (only with respect
                   (such as tax or insurance payments) are                              to verifying
                   made on or before the related penalty or                             outstanding tax
                   expiration dates, as indicated on the                                payments and processing
                   appropriate bills or notices for such                                such tax payments
                   payments, provided that such support has                             pursuant to the
                   been received by the servicer at least 30                            Servicer's direction)
                   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                     X
                   connection with any payment to be made 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                X
                   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.

1122(d)(4)(xiv)    Delinquencies, charge-offs and                    X
                   uncollectible accounts are recognized and
                   recorded in accordance with the
                   transaction agreements.

1122(d)(4)(xv)     Any external enhancement or other                 X (only with
                   support identified in Item                        respect to those
                   1114(a)(1) through (3) or Item 1115 of            items identified
                   Regulation AB, is maintained as set               in Item
                   forth in the transaction agreements.              1114(a)(1))

</TABLE>