Exhibit 33.1

Certification Regarding Compliance with
Applicable Servicing Criteria

|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|-- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|1. | USAA Federal
  Savings Bank (FSB) is responsible for assessing compliance with the
  servicing criteria applicable to it under paragraph (d) of Item 1122 of
  Regulation AB, as of December 31, 2006 and for the period from February 22,
  2006 through December 31, 2006 (the Reporting Period), as set forth in
  Appendix A hereto. The transactions covered by this report include
  asset-backed securities transactions for which FSB acted as servicer
  involving retail auto loans other than transactions consummated prior to the
  effectiveness of Regulation AB (the Platform);
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|2. | Except as
  set forth in paragraph 4 below, FSB used the criteria set forth in paragraph
  (d) of Item 1122 of Regulation AB to assess the compliance with the
  applicable servicing criteria;                                                                                                                                                                                                                                                                                                                                                                                                      
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|3. | The criteria
  listed in the columns titled Inapplicable Servicing Criteria on Appendix A
  hereto are inapplicable to FSB based on the activities it performs with
  respect to the Platform;                                                                                                                                                                                                                                                                                                                                                                                                     
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|4. | FSB has
  complied, in all material respects, with the applicable servicing criteria as
  of December 31, 2006 and for the Reporting Period with respect to the
  Platform taken as a whole,except as described on Appendix B
  hereto; and                                                                                                                                                                                                                                                                                                                                                          
|   |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|5. | Ernst &
  Young LLP, an independent registered public accounting firm, has issued an
  attestation report for the Platform on FSBs assessment of compliance with
  the applicable servicing criteria for the Reporting Period.                                                                                                                                                                                                                                                                                                                                                                      

| |                                                   | 
| | ------------------------------------------------- | 
| | USAA FEDERAL
  SAVINGS BANK                      
| |                                                  
| | /s/ FRITZ D.
  BOHNE                             
|
| | By:                                               | 
|
| | Name: Fritz
  D. Bohne                           
| | Title: Vice
  President, Senior Financial Officer

March 29,
  2007

---



APPENDIX A

|                     |  |                                                                                                                                                                                                                                                                           |  |                                      |  |                                                                           |  |                                                                                                   |  |                                                                                    | 
|-------------------- |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------------ |  | ------------------------------------------------------------------------- |  | ------------------------------------------------------------------------------------------------- |  | ---------------------------------------------------------------------------------- | 
|SERVICING
  CRITERIA |  | APPLICABLE
  
  SERVICING CRITERIA                                                                                                                                                                                                                                        |  | INAPPLICABLE
  SERVICING 
  CRITERIA | 
|                     |  |                                                                                                                                                                                                                                                                           |  |                                      |  |                                                                           | 
|Reference            |  | Criteria                                                                                                                                                                                                                                                                  |  | Performed
  Directly
  by
  FSB      |  | Performed
  by
  Vendor(s)
  for which
  FSB is the
  Responsible
  Party |  | Performed
  by
  subservicer(s)
  or vendor(s)
  for which
  FSB is NOT
  the Responsible
  Party |  | NOT
  performed by
  FSB or by
  subservicer(s) or vendor(s) 
  retained by 
  FSB | 
|                     |  |                                                                                                                                                                                                                                                                           |  |                                      |  |                                                                           |  |                                                                                                   |  |                                                                                    | 
|                    
|                     |  | 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                                    |  |                                                                           |  | 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 overcollateralization, are separately maintained
  (e.g., with respect to commingling of cash) as set forth in the transaction
  agreements.             |  |                                      |  |                                                                           |  | X                                                                                                 |  |                                                                                    | 

---



|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                            |  |                                                                                                   |  |                                                                                    | 
|-------------------- |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------------ |  | -------------------------------------------------------------------------- |  | ------------------------------------------------------------------------------------------------- |  | ---------------------------------------------------------------------------------- | 
|SERVICING
  CRITERIA |  | APPLICABLE
  
  SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |  | INAPPLICABLE
  SERVICING 
  CRITERIA | 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                            | 
|Reference            |  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |  | Performed
  Directly
  by
  FSB      |  | Performed
  by
  Vendor(s)
  for which 
  FSB is the
  Responsible
  Party |  | Performed
  by
  subservicer(s)
  or vendor(s)
  for which
  FSB is NOT
  the Responsible
  Party |  | NOT
  performed by
  FSB or by
  subservicer(s) or vendor(s) 
  retained by 
  FSB | 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                            |  |                                                                                                   |  |                                                                                    | 
|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                                    |  |                                                                            |  | X                                                                                                 |  |                                                                                    | 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |  |                                      |  |                                                                            |  |                                                                                                   |  |                                                                                    | 
|                     |  | 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                                    |  |                                                                            |  | 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                                                                                                 |  |                                                                                   

---



|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                          |  |                                      |  |                                                                            |  |                                                                                                   |  |                                                                                    | 
|-------------------- |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |  | ------------------------------------ |  | -------------------------------------------------------------------------- |  | ------------------------------------------------------------------------------------------------- |  | ---------------------------------------------------------------------------------- | 
|SERVICING
  CRITERIA |  | APPLICABLE
  
  SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                       |  | INAPPLICABLE
  SERVICING 
  CRITERIA | 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                          |  |                                      |  |                                                                            | 
|Reference            |  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                 |  | Performed
  Directly
  by
  FSB      |  | Performed
  by
  Vendor(s)
  for which 
  FSB is the
  Responsible
  Party |  | Performed
  by
  subservicer(s)
  or vendor(s)
  for which
  FSB is NOT
  the Responsible
  Party |  | NOT
  performed by
  FSB or by
  subservicer(s) or vendor(s) 
  retained by 
  FSB | 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                          |  |                                      |  |                                                                            |  |                                                                                                   |  |                                                                                    | 
|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.                                                                                                                                                                                                                                    |  |                                      |  |                                                                            |  | 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                                    |  |                                                                            |  | X                                                                                                 |  |                                                                                    | 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                          |  |                                      |  |                                                                            |  |                                                                                                   |  |                                                                                    | 
|1122(d)(4)(ii)       |  | pool asset
  and related documents are safeguarded as required by the transaction
  agreements                                                                                                                                                                                                                                                                                                                           |  | X                                    |  |                                                                            |  | 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                                    |  |                                                                            |  |                                                                                                   |  |                                                                                    | 

---



|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  |                                      |  |                                                                            |  |                                                                                                  |  |                                                                                    | 
|-------------------- |  | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------------ |  | -------------------------------------------------------------------------- |  | ------------------------------------------------------------------------------------------------ |  | ---------------------------------------------------------------------------------- | 
|SERVICING
  CRITERIA |  | APPLICABLE
  
  SERVICING CRITERIA                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |  | INAPPLICABLE
  SERVICING 
  CRITERIA | 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  |                                      |  |                                                                            | 
|Reference            |  | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  | Performed
  Directly
  by
  FSB      |  | Performed
  by
  Vendor(s)
  for which 
  FSB is the
  Responsible
  Party |  | Performed
  by
  subservicer(s)
  or vendor(s)
  for which
  FSB is NOT
  theResponsible
  Party |  | NOT
  performed by
  FSB or by
  subservicer(s) or vendor(s) 
  retained by 
  FSB | 
|                     |  |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |  |                                      |  |                                                                            |  |                                                                                                  |  |                                                                                    | 
|1122(d)(4)(viii)     |  | Records
  documenting collection efforts are maintained during the period a pool asset
  is delinquent in 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 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.                                                                                                                                                                                                                                                                                                                                                             |  |                                      |  |                                                                            |  |                                                                                                  |  | 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                                                                                  | 

---



|                     |  |                                                                                                                                                                                     |  |                                      |  |                                                                            |  |                                                                                                   |  |                                                                                    | 
|-------------------- |  | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |  | ------------------------------------ |  | -------------------------------------------------------------------------- |  | ------------------------------------------------------------------------------------------------- |  | ---------------------------------------------------------------------------------- | 
|SERVICING
  CRITERIA |  | APPLICABLE
  
  SERVICING CRITERIA                                                                                                                                                  |  | INAPPLICABLE
  SERVICING 
  CRITERIA | 
|                     |  |                                                                                                                                                                                     |  |                                      |  |                                                                            | 
|Reference            |  | Criteria                                                                                                                                                                            |  | Performed
  Directly
  by
  FSB      |  | Performed
  by
  Vendor(s)
  for which 
  FSB is the
  Responsible
  Party |  | Performed
  by
  subservicer(s)
  or vendor(s)
  for which
  FSB is NOT
  the Responsible
  Party |  | NOT
  performed by
  FSB or by
  subservicer(s) or vendor(s) 
  retained by 
  FSB | 
|                     |  |                                                                                                                                                                                     |  |                                      |  |                                                                            |  |                                                                                                   |  |                                                                                    | 
|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                                                                                  | 

---



APPENDIX B

Material Instances
of Noncompliance

During the Reporting Period, FSB has identified the
following material instances of noncompliance with the servicing criteria
applicable to it under paragraph (d) of Item 1122 of Regulation AB.

| |                                                                                                                                                                                                                                                                                     
| | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
| | CFR Item 1122(d)(3)(i): The First Priority Principal
  Payment in the monthly servicing reports filed as exhibits in two Reports on
  Form 10-D was not calculated accurately. In addition, one Report on Form 10-D
  required to be filed with the Commission was not timely filed.

Remediation
Efforts

Processes have been corrected to ensure the First
Priority Principal Payment is calculated accurately for presentation in the
monthly servicing reports. In addition, processes have been improved to ensure
Reports on Form 10-D are filed timely.

---