**Report
        on
        Assessment of Compliance with Regulation AB Servicing Criteria**
  1.
            Pursuant
                to Subpart 229.1100 - Asset Backed Securities, 17 C.F.R.
                §§229.1100-229.1123 ("Regulation
                AB").
                Regulus Group LLC, for itself and its wholly-owned subsidiaries
                (individually and collectively "Regulus"),
                is responsible for assessing its compliance with the servicing criteria
                applicable to the remittance processing services it provides to customers
                who are issuers or servicers of asset backed securities transactions
                and
                who have requested confirmation of Regulus' compliance in connection
                with
                loan and/or receivables portfolios that include pool assets for asset
                backed securities transactions (the "Platform").
                Remittance processing is a service whereby check payments that are
                remitted by mail to a post office box are collected, processed through
                a
                highly
                automated data capture system, and prepared for deposit to a bank
                account
                held by the beneficiary of the
                payment.  2.
            The
                servicing criteria set forth in Item 1122(d)of Regulation AB were
                used in
                Regulus' assessment of compliance. Regulus has concluded that the
                servicing criteria set forth in Items 1122(d)(2)(i) and 1122(d)(4)(iv)
                of
                Regulation AB are applicable to the servicing activities
                it performs with respect to the Platform (such criteria the "Applicable
                Servicing Criteria").
                Regulus has concluded that the remainder of the servicing criteria
                set
                forth in Item
                1122(d) of Regulation AB are inapplicable to the activities it performs
                with respect to
                the Platform because Regulus does not participate in the servicing
                activities referenced by
                such servicing
                criteria.  3.
            As
                of and for the year ending December 31, 2006, Regulus has complied
                in all
                material respects with the Applicable Servicing Criteria set forth
                in Item
                1122(d) of Regulation AB.  4.
            KPMG
                LLP, a registered public accounting firm, has issued an attestation
                report
                on Regulus'
                assessment of compliance with the Applicable Servicing Criteria as
                of and
                forthe
                year ending December 31, 2006. A copy of that attestation report
                is
                attached heretoas
                Exhibit A.  /s/
        Kimberlee Clark
 Kimberlee
        Clark
 Chief
        Financial Officer
  February
        22, 2007
   860
        LATOUR COURT   ¦   NAPA,
        CA   ¦   94558   ¦   TEL:
        707.254.4000   ¦   FAX: 707.254.4070  
¦   REGULUSGROUP.COM
   
  
  **KPMG
                LLP**1601
                Market StreetPhiladelphia,
                PA 19103-2499
  Report
        of Independent Registered Public Accounting Firm
  The
        Board
        of Members
 Regulus
        Group LLC:
  We
        have
        examined management's assessment for those customers that management has
        informed us
        have
        requested confirmation of compliance, included in the accompanying Report
        on Assessment
        of Compliance with Regulation AB Servicing Criteria, that Regulus Group LLC
        complied with the servicing criteria set forth in Item 1122(d)(2)(i) and
        1122(d)(4)(iv) of the Securities
        and Exchange Commission's Regulation AB for remittance processing services
        to those
        issuers of asset backed securities and servicers of loan and/or receivables
        portfolios that include
        pool assets for asset backed securities transactions (the Platform) as of
        and
        for the year ended
        December 31, 2006. Regulus Group LLC has determined that the remainder of
        the servicing
        criteria are not applicable to the activities it performs with respect to
        the
        Platform as of and
        for
        the year ended December 31, 2006. Management is responsible for the Company's compliance
        with those servicing criteria. Our responsibility is to express an opinion
        on management's
        assessment about the Company's compliance based on our examination.
  Our
        examination was conducted in accordance with the standards of the Public
        Company Accounting
        Oversight Board (United States) and, accordingly, included examining, on
        a test basis,
        evidence about the Company's compliance with the servicing criteria specified
        above and performing
        such other procedures as we considered necessary in the circumstances. Our examination
        included testing of less than all of the individual asset-backed transactions
        and securities
        that comprise the Platform, testing of less than all of the servicing activities
        related to the
        Platform, and determining whether the Company processed those selected
        transactions and performed those selected activities in compliance with the
        servicing criteria. Furthermore, our procedures
        were limited to the selected transactions and servicing activities performed
        by
        the Company
        during the period covered by this report. Our procedures were not designed
        to determine
        whether errors may have occurred either prior to or subsequent to our tests
        that
        may have
        affected the balances or amounts calculated or reported by the Company during
        the period covered
        by this report for the selected transactions or any other transactions. We
        believe that our examination
        provides a reasonable basis for our opinion. Our examination does not provide
        a legal
        determination on the Company's compliance with the servicing
        criteria.
  In
        our
        opinion, management's assessment that the Company complied with the
        aforementioned servicing
        criteria as of and for the year ended December 31, 2006 is fairly stated,
        in all
        material respects.
   Philadelphia,
        PA
 February
        22, 2007
  KPMG
                    LLP, a U.S. limited liability partnership, is the
                    U.S.member
                    firm of KPMG International, a Swiss cooperative