Exhibit 33.1.2
 
 MANAGEMENT’S
ASSERTION OF COMPLIANCE
 
 Management
of the Agency and Trust division of Citibank, N.A. (or “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.
 
 Management
has determined that the servicing criteria set forth in Item 1122(d) of
Regulation AB are applicable in regard 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 issued on or after January 1,
2006, for which the Company provides the following servicing functions (the
“Platform”):
 
 ·
              paying
      agent, securities administration and trustee;
or
 ·
              securities
      administration and paying agent; or
 ·
              paying
      agent and trustee; or
 ·
              paying
      agent
 
 Applicable Servicing
Criteria:  All servicing criteria set forth in Item 1122(d), to
the extent required by Item 1122(d) servicing criteria in regards to the
activities performed by the Company with respect to the Platform as to any
transaction, except for the following servicing criteria: 1122(d)(1)(i),
1122(d)(1)(iii)-1122(d)(1)(iv), 1122(d)(2)(iii), 1122(d)(4)(i)-1122(d)(4)(ii)
and 1122(d)(4)(iv)-1122(d)(4)(xiv), which management has determined are not
applicable to the activities the Company performs with respect to the Platform
(the “Applicable Servicing Criteria”).
 
 Period:  Twelve
months ended December 31, 2008 (the “Period”).
 
 With
respect to the Platform as of and for the Period, the Company’s management
provides the following assertion of compliance with respect to the Applicable
Servicing Criteria:
  ·
              The
      Company’s management is responsible for assessing the Company’s compliance
      with the Applicable Servicing
Criteria.
  ·
              The
      Company’s management has assessed compliance with the Applicable Servicing
      Criteria.  In making this assessment, management used the
      criteria set forth by the Securities and Exchange Commission in paragraph
      (d) of Item 1122 of Regulation AB.
  ·
              Based
      on such assessment, other than as set forth in Appendix A
      hereto, 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 compliance with the Applicable Servicing Criteria as of
and for the Period.
 
 CITIBANK,
      N.A.By:
                  /s/ Karen
      MontbachIts:
                  Managing Director -
  OTS
 
 Dated:
February 27, 2009
  
  Appendix
A
 
 Material Instances of
Noncompliance
  
 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.With respect to certain transactions for which the
transaction documents require that funds be deposited into the custodial bank
accounts on the day funds are received by the Company, funds were not deposited
into the custodial bank accounts in accordance with the terms of the transaction
documents.
 
 Management
Response
 
 
 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.  Management believes the process in place ensures
with reasonable certainty that although certain funds received by the Company
were not deposited in accordance with the timing required by the transaction
agreements, these funds were deposited into the custodial account such that any
payments to any security holder or to any transaction party were unaffected by
the aforementioned delay.