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         T R O U B L E D   C O M P A N Y   R E P O R T E R

              Sunday, August 9, 2009, Vol. 13, No. 219

                            Headlines



ACADEMIC FINANCE: Fitch Maintains Ratings on Various Student Loans
ATLANTIS FUNDING: Moody's Downgrades Ratings on Various Classes
ATRIUM IV: Moody's Downgrades Ratings on Various Classes of Notes
ATRIUM V: Moody's Downgrades Ratings on Various Classes of Notes
BANC OF AMERICA: S&P Downgrades Ratings on 12 2005-4 Securities

BEAR STEARNS: Fitch Downgrades Ratings on 14 2007-TOP26 Certs.
BEAR STERNS: Moody's Affirms Ratings on Nine 2005-PWR9 Certs.
BEAR STEARNS: S&P Downgrades Ratings on 13 2006-BBA7 Certificates
BEAR STEARNS: S&P Downgrades Ratings on 15 2007-TOP28 Securities
BOUNTIFUL: S&P Junks Rating on Series 98 Revenue Bonds

BRAZOS STUDENT: Fitch Maintains Ratings on Various Student Loans
C-BASS MORTGAGE: Moody's Cuts Ratings on Nine 2006-SC1 Tranches
CAPMARK VI: S&P Downgrades Ratings on Six Classes of Notes to 'D'
CARLYLE CREDIT: Moody's Downgrades Ratings on Two Classes of Notes
CARLYLE HIGH: Moody's Downgrades Ratings on Various Classes

CENT CDO: Moody's Downgrades Ratings on Four Classes of Notes
CITIGROUP MORTGAGE: Moody's Puts Ratings on Resecuritized Certs.
COMM 2004-LNB3: DBRS Downgrades Class O Ratings to C
CREDIT SUISSE: Fitch Takes Rating Actions on 2007-C1 Certs.
CREDIT SUISSE: Fitch Takes Rating Actions on 2007-C5 Certs.

CREDIT SUISSE: Fitch Takes Rating Actions on 2008-C1 Certs.
CREDIT SUISSE: Moody's Takes Rating Actions on 2007-C1 Certs.
CREDIT SUISSE: S&P Downgrades Ratings on Two 2005-TFL3 Certs.
E*TRADE ABS: Moody's Downgrades Ratings on Class A-2 to 'Ba1'
EDINVEST COMPANY: Fitch Maintains Ratings on Student Loans

EDUCATIONAL FUNDING: Fitch Keeps Ratings on Various Student Loans
EDUCATIONAL FUNDING: Fitch Maintains Ratings on Student Loans
FEDERATED STUDENT: Fitch Maintains Ratings on Student Loan ABS
FIRST 2004-I: Moody's Downgrades Ratings on Two Classes of Notes
FIRST 2004-II: Moody's Downgrades Ratings on Two Classes of Notes

FIRST DOMINION: Moody's Downgrades Ratings on Various Classes
FIRST NATIONAL: S&P Assigns Initial Ratings on $690.79 Mil. Notes
FRANKLIN AUTO: S&P Downgrades Ratings on Two Classes of Notes
GE COMMERCIAL MORTGAGE: DBRS Downgrades Two Classes to C-
GE COMMERCIAL: S&P Downgrades Ratings on 14 2005-C1 Securities

GMAC COMMERCIAL: Fitch Takes Rating Actions on 14 2006-C1 Certs.
GREENWICH CAPITAL: S&P Downgrades Ratings on Three 2005-FL3 Certs.
HALCYON STRUCTURED: Moody's Downgrades Ratings on 2007-2 Notes
HALCYON STRUCTURED: Moody's Downgrades Ratings on Two Classes
HOSPITAL AUTHORITY: Fitch Cuts Rating on $12.7 Mil. Bonds to 'BB-'

ING INVESTMENT: Moody's Downgrades Ratings on Two Classes of Notes
JEFFERSON COUNTY: S&P Corrects Ratings on Revenue Bonds to 'C'
JEFFERSON COUNTY: S&P Keeps 'C' Underlying Rating on Various Bonds
JP MORGAN: Fitch Takes Rating Actions on 25 2007-LDP10 Certs.
JP MORGAN: Moody's Affirms Ratings on Eight 2008-C2 Certs.

LB-UBS COMMERCIAL: Fitch Takes Rating Actions on 2007-C1 Certs.
LEHMAN BROS: S&P Downgrades Ratings on Five 2004-LLF C5 Certs.
LIGHTPOINT CLO: Moody's Downgrades Ratings on Two Classes of Notes
MADISON AVENUE: Moody's Cuts Ratings on Class A Notes to 'Ba2'
MAGNOLIA FINANCE: Moody's Downgrades Ratings on 2006-7 Notes

MASTR ASSET: Moody's Downgrades Ratings on 2-A-2 Tranche
MAX CMBS: S&P Downgrades Ratings on 22 Classes of Notes
MERRILL LYNCH: Moody's Reviews Ratings on Series 2005-MCP1 Certs.
MISSISSIPPI HIGHER: Fitch Retains Ratings on Various Student Loans
MKP CBO: Moody's Downgrades Ratings on Class A-1 Notes to 'Ba1'

MKP CBO: Moody's Downgrades Ratings on Two Classes of Notes
MLMT COMMERCIAL: Fitch Downgrades Ratings on 15 2007-C1 Certs.
MORGAN STANLEY: S&P Downgrades Ratings on Class M 2005-XLF Certs.
MORGAN STANLEY: S&P Withdraws 'CC+' Rating on Class IIIB Notes
MOUNTAIN CAPITAL: Moody's Downgrades Ratings on Various Classes

MOUNTAIN CAPITAL: Moody's Downgrades Ratings on Various Notes
MRU STUDENT: S&P Downgrades Ratings on Two Classes of Notes
NEW YORK STATE DORMITORY: S&P Junks Ratings on Bonds
RACERS SERIES: Moody's Junks Ratings on 2001-12-E Trust From 'B2'
RESIDENTIAL REINSURANCE: S&P Cuts Ratings on Catastrophe Bonds

RYLAND MORTGAGE: Moody's Downgrades Ratings on 11 Certificates
SATURN VENTURES: Moody's Downgrades Ratings on Three Classes
SIGNATURE 6: Moody's Downgrades Ratings on Two Classes of Notes
SIGNATURE 7: Moody's Downgrades Ratings on Three Classes of Notes
SIGNUM VERMILION: Moody's Downgrades Ratings on 2007-1 Notes

ST JAMES: Moody's Downgrades Ratings on Various Classes of Notes
STARTS LTD: S&P Withdraws 'B+' Rating on Series 2007-30 Notes
STRAITS GLOBAL: Moody's Downgrades Ratings on Two Classes
TBW ALT-A: Moody's Corrects Ratings on Seven Tranches
TIERS BRISBANE: Moody's Downgrades Ratings on 2007-34 Notes

VERMEER FUNDING: Moody's Downgrades Ratings on Two Classes
WACHOVIA BANK: S&P Affirms Ratings on Six 2005-WHALE5 Certs.
WESTWOOD CDO: Moody's Downgrades Ratings on Various Classes

* S&P Puts Ratings on 29 Tranches on CreditWatch Negative
* S&P Rakes Rating Actions on 10 Emerging Market Transactions



                            *********

ACADEMIC FINANCE: Fitch Maintains Ratings on Various Student Loans
------------------------------------------------------------------
Fitch Ratings currently maintains ratings on student loan asset-
backed securities issued by Academic Finance Corporation under an
Amended and Restated Indenture, dated as of June 1, 2006, between
AFC and U.S. Bank National Association, as Trustee and Eligible
Lender Trustee.  AFC has requested that Fitch confirm its existing
ratings on the securities issued under the Indenture upon the
adoption and effectiveness of a supplemental indenture (the
Supplement).  Consistent with its statements on policies regarding
rating confirmations in structured finance transactions
(January 13, 2009) and student loan confirms (May 8, 2009), Fitch
is treating this request as a notification.

The Supplement allows AFC to purchase outstanding auction-rate
securities issued under the Indenture at a price less than par
which includes the remaining principal balance plus 100% of the
accrued and unpaid interest.  Funds deposited into the Principal
Distribution Fund held under the Indenture, which are currently
used to pay down securities at par plus accrued interest, would
become available at the direction of AFC to purchase securities
from investors, who voluntarily elect to sell their securities at
a discount.  Any securities so purchased by AFC would be
immediately tendered to the Trustee for cancellation.  Based on
the information provided, Fitch has determined that the execution
and delivery of the Supplement and the changes to the Indenture
contained in the Supplement will not have an impact on the
existing ratings on the securities issued under the Indenture.
This determination only addresses the effect of the Supplement and
its changes on the current ratings assigned by Fitch to the
securities issued under the Indenture.  It does not address
whether this change is permitted by the terms of the documents nor
does it address whether it is in the best interests of, or
prejudicial to, some or all of the holders of the securities
listed.

Based on the trust estate's balance sheet as of March 31, 2009,
investors who choose to sell their securities at a discount may
positively increase the senior and total parity ratios of the
trust estate.  The subordination level for the senior securities
would increase as well.  In addition, the composition of the loan
pool held under the Indenture and the weighted average coupon rate
of the securities are not expected to change materially.

The ratings assigned by Fitch are based on the documents and
information provided to Fitch by AFC and other parties and the
receipt of final closing documents.  Fitch relies on all these
parties for the accuracy of such information and documents.  Fitch
did not audit or verify the truth or accuracy of such information.

Fitch currently rates the student loan asset-backed securities,
which include auction-rate securities issued under the Indenture
by AFC:

Academic Finance Corporation (2005 Indenture)

  -- $31,900,000 senior series 2005 A-1 notes 'AAA';
  -- $53,800,000 senior series 2006 A-1 notes 'AAA';
  -- $14,100,000 subordinate series 2005 B-1 notes 'BB'.


ATLANTIS FUNDING: Moody's Downgrades Ratings on Various Classes
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Atlantis Funding Ltd.:

  -- US$782,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Notes Due 2015, Downgraded to A2; previously on
     October 25, 2007 Assigned Aaa;

  -- US$23,500,000 Class A-2 Second Priority Senior Secured
     Floating Rate Notes Due 2015, Downgraded to Baa3; previously
     on March 4, 2009 Aa2 Placed Under Review for Possible
     Downgrade;

  -- US$42,500,000 Class B Third Priority Mezzanine Secured
     Deferrable Floating Rate Notes Due 2015, Downgraded to Ba3;
     previously on March 23, 2009 Downgraded to Ba1 and Placed
     Under Review for Possible Downgrade;

  -- US$21,500,000 Class C Fourth Priority Mezzanine Secured
     Deferrable Floating Rate Notes Due 2015, Downgraded to Caa3;
     previously on March 23, 2009 Downgraded to B1 and Placed
     Under Review for Possible Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," the application
of certain stresses with respect to the default probabilities
associated with certain Moody's credit estimates, and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
second lien loans will be below their historical averages,
consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, an increase in the proportion of securities
from issuers rated Caa1 and below, and failure of the Class C
overcollateralization test.  The weighted average rating factor
has increased over the last year and is currently 2892 as of the
last trustee report, dated July 16, 2009.  Based on the same
report, defaulted securities total about $58 million, accounting
for roughly 7.2% of the collateral balance, and securities rated
Caa1 or lower make up approximately 7% of the underlying
portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Atlantis Funding Ltd., issued in October of 2007, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


ATRIUM IV: Moody's Downgrades Ratings on Various Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Atrium IV:

  -- US$387,000,000 Class A1-a Floating Rate Notes Due 2019,
     Downgraded to A1; previously on June 29, 2005 Assigned Aaa;

  -- US$7,000,000 Class A1-b Fixed Rate Notes Due 2019, Downgraded
     to A1; previously on June 29, 2005 Assigned Aaa;

  -- US$100,000,000 Class A2 Delayed Draw Floating Rate Notes Due
     2019, Downgraded to A1; previously on June 29, 2005 Assigned
     Aaa;

  -- US$28,000,000 Class A3 Deferrable Floating Rate Notes Due
     2019, Downgraded to Baa2, previously on March 18, 2009 Aa2
     Placed Under Review for Possible Downgrade;

  -- US$35,000,000 Class B Deferrable Floating Rate Notes Due
     2019, Downgraded to Ba2, previously on March 18, 2009
     Downgraded to Ba1and Placed Under Review for Possible
     Downgrade;

  -- US$27,500,000 Class C Floating Rate Notes Due 2019,
     Downgraded to Caa2, previously on March 18, 2009 Downgraded
     to B1 and Placed Under Review for Possible Downgrade;

  -- US$8,000,000 Class D-1 Floating Rate Notes Due 2019,
     Downgraded to Ca, previously on March 18, 2009 Downgraded to
     Caa2 and Placed Under Review for Possible Downgrade;

  -- US$3,500,000 Class D-2 Fixed Rate Notes Due 2019, Downgraded
     to Ca, previously on March 18, 2009 Downgraded to Caa2 and
     Placed Under Review for Possible Downgrade;

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," the application
of certain stresses with respect to the default probabilities
associated with certain Moody's credit estimates and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
second lien loans will be below their historical averages,
consistent with Moody's research.  Moody's has also applied
resecuritization stress factors to default probability assumptions
for structured finance asset collateral as described in the press
release titled "Moody's updates its key assumptions for rating
structured finance CDOs," published on December 11, 2008.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, an increase in the proportion of securities
from issuers rated Caa1 and below, and failure of Class D Par
Value Test.  The weighted average rating factor has steadily
increased over the last year and is currently 2889 versus a test
level of 2520 as of the last trustee report, dated June 1, 2009.
Based on the same report, defaulted securities total about
$69 million, accounting for roughly 11% of the collateral balance,
and securities rated Caa1 or lower make up approximately 12% of
the underlying portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Atrium IV, issued in June 8, 2005, is a collateralized loan
obligation backed primarily by a portfolio of [senior secured
loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


ATRIUM V: Moody's Downgrades Ratings on Various Classes of Notes
----------------------------------------------------------------
Moody's Investors Service announced that it downgraded the ratings
of these notes issued by Atrium V:

  -- Class A-1 Floating Rate Notes Due 2020, Downgraded to A1;
     previously on July 27, 2006 Assigned Aaa;

  -- Class A-2b Floating Rate Notes Due 2020, Downgraded to A2;
     previously on March 4, 2009 Aa1 Placed Under Review for
     Possible Downgrade;

  -- Class A-3a Floating Rate Notes Due 2020, Downgraded to Aa1;
     previously on July 27, 2006 Assigned Aaa;

  -- Class A-3b Floating Rate Notes Due 2020, Downgraded to A2;
     previously on March 4, 2009 Aa1 Placed Under Review for
     Possible Downgrade;

  -- Class A-4 Floating Rate Notes Due 2020, Downgraded to Baa1;
     previously on March 4, 2009 Aa2 Placed Under Review for
     Possible Downgrade;

  -- Class B Deferrable Floating Rate Notes Due 2020, Downgraded
     to Ba2; previously on March 17, 2009 Downgraded to Ba1 and
     Placed Under Review for Possible Downgrade;

  -- Class C Deferrable Floating Rate Notes Due 2020, Downgraded
     to Caa1; previously on March 17, 2009 Downgraded to B1 and
     Placed Under Review for Possible Downgrade;

  -- Class D Deferrable Floating Rate Notes Due 2020, Downgraded
     to Ca; previously on March 17, 2009 Downgraded to Caa2 and
     Placed Under Review for Possible Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," the application
of certain stresses with respect to the default probabilities
associated with certain Moody's credit estimates, and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds and second lien loans will be below
their historical averages, consistent with Moody's research.
Moody's has also applied resecuritization stress factors to
default probability assumptions for structured finance asset
collateral as described in the press release titled "Moody's
updates its key assumptions for rating structured finance CDOs,"
published on December 11, 2008.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities and an increase in the proportion of
securities from issuers rated Caa1 and below.  The weighted
average rating factor has increased over the last year and is
currently 2947 versus a test level of 2650 as of the last trustee
report, dated June 15, 2009.  Based on the same report, defaulted
securities total about $97 million, accounting for roughly 11% of
the collateral balance, and securities rated Caa1 or lower make up
approximately 12% of the underlying portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Atrium V, issued in July 20, 2006, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


BANC OF AMERICA: S&P Downgrades Ratings on 12 2005-4 Securities
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 12
classes of commercial mortgage-backed securities from Banc of
America Commercial Mortgage Inc.'s series 2005-4 and removed them
from CreditWatch with negative implications, where they were
placed June 26, 2009.  In addition, S&P affirmed its ratings on 12
classes from the same transaction and removed four of them from
CreditWatch negative.

The downgrades follow S&P's analysis of the transaction using
S&P's recently released U.S. conduit and fusion CMBS criteria,
which was the primary driver of the rating actions.  S&P's
analysis included a review of the credit characteristics of all
the loans in the pool.  Using servicer-provided financial
information, S&P calculated an adjusted debt service coverage
(DSC) of 1.46x and a loan-to-value ratio of 97%.  S&P further
stressed the loans' cash flows under S&P's 'AAA' scenario to yield
a weighted average DSC of 0.99x and an LTV of 126%.  The implied
defaults and loss severity under the 'AAA' scenario were 61.6% and
31.9%, respectively.  The lowered ratings on the subordinate
classes also reflect S&P's expectations for credit support erosion
upon the eventual resolution of two of the loans with the special
servicer that S&P consider credit-impaired.

The affirmed ratings on the principal and interest certificates
reflect credit enhancement levels that, in S&P's opinion, provide
adequate support through various stress scenarios.  S&P affirmed
the ratings on the interest-only (IO) certificates based on S&P's
current criteria.  S&P published a request for comment proposing
changes to the IO criteria on June 1, 2009 .  After finalizing
our criteria review, S&P may revise its current criteria.  Any
change in S&P's criteria may affect outstanding ratings, including
the ratings on the IO certificates S&P affirmed.

                          Credit Concerns

Eleven loans ($257.1 million, 16.7%) in the pool are currently
with the special servicer, LNR Partners Inc.  A breakdown of the
specially serviced loans by payment status is: one loan is 90-plus
days delinquent ($2.3 million), while the remaining loans are
current or in their grace periods ($254.8 million).  Two of the
specially serviced assets are top 10 loans and have balances
greater than 5% of the total pool balance.  The Renaissance
Baltimore Harborplace loan (7%) was transferred in July 2009
following a borrower request for debt relief.  The Peachtree Mall
loan (6%) was transferred in April 2009 following the General
Growth Properties bankruptcy filing.  S&P continue to monitor the
developments relating to the GGP bankruptcy and will take rating
actions as S&P determine necessary.

                       Transaction Summary

As of the July 2009 remittance report, the collateral pool
consisted of 125 loans with an aggregate trust balance of
$1.54 billion, slightly lower than the balance of $1.59 billion at
issuance.  The master servicer for the transaction, Bank of
America N.A., reported financial information for 98% of the pool.
Ninety-eight percent of the financial information was full-year
2008 data.  S&P calculated a weighted average DSC of 1.46x for the
pool based on the reported figures.  Two loans ($7.2 million,
0.5%) in the pool are delinquent, and 11 are currently in special
servicing.  The transaction has not experienced any principal
losses to date.  Thirty-four loans are on the master servicer's
watchlist, including two of the top 10 loans.  Seventeen loans
($244.9 million, 16%) have reported DSCs below 1.10x, and 11 of
these loans ($198.4 million, 13%) have reported DSCs of less than
1.0x.

                    Summary Of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$717.1 million (47%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC for the top 10 loans of 1.40x,
compared to 1.46x at issuance.  The largest and ninth-largest
loans in the pool (10%) have a reported DSC under 1.0x and appear
on the master servicer's watchlist.  S&P's adjusted DSC and LTV
for the top 10 loans were 1.22x and 93%, respectively.

Standard & Poor's stressed the loans with the special servicer and
the remaining loans in the pool according to S&P's updated
conduit/fusion criteria.  The resultant credit enhancement levels
support the lowered and affirmed ratings.

       Ratings Lowered And Removed From Creditwatch Negative

             Banc of America Commercial Mortgage Inc.
   Commercial mortgage pass-through certificates series 2005-4

                  Rating
                  ------
     Class     To        From           Credit enhancement (%)
     -----     --        ----           ----------------------
     A-5B      AA        AAA/Watch Neg                   20.63
     A-J       A         AAA/Watch Neg                   14.31
     B         A-        AA/Watch Neg                    12.25
     C         BBB+      AA-/Watch Neg                   11.22
     D         BBB       A/Watch Neg                      9.28
     E         BBB-      A-/Watch Neg                     8.12
     F         BB+       BBB+/Watch Neg                   6.83
     G         BB        BBB/Watch Neg                    5.67
     H         BB-       BBB-/Watch Neg                   4.13
     J         B+        BB+/Watch Neg                    3.61
     K         B+        BB/Watch Neg                     3.09
     L         B         BB-/Watch Neg                    2.58

      Ratings Affirmed And Removed From Creditwatch Negative

             Banc of America Commercial Mortgage Inc.
   Commercial mortgage pass-through certificates series 2005-4

                  Rating
                  ------
     Class     To        From           Credit enhancement (%)
     -----     --        ----           ----------------------
     A-5A      AAA       AAA/Watch Neg                   30.55
     M         B         B/Watch Neg                      2.32
     N         B-        B-/Watch Neg                     1.93
     O         CCC+      CCC+/Watch Neg                   1.55

                         Ratings Affirmed

             Banc of America Commercial Mortgage Inc.
   Commercial mortgage pass-through certificates series 2005-4

     Class     Rating                   Credit enhancement (%)
     -----     ------                   ----------------------
     A-1       AAA                                       20.63
     A-2       AAA                                       20.63
     A-3       AAA                                       20.63
     A-4       AAA                                       20.63
     A-SB      AAA                                       20.63
     A-1A      AAA                                       20.63
     XP        AAA                                         N/A
     XC        AAA                                         N/A

                       N/A - Not applicable.


BEAR STEARNS: Fitch Downgrades Ratings on 14 2007-TOP26 Certs.
--------------------------------------------------------------
Fitch Ratings downgrades and removes from Rating Watch Negative 14
classes and revises Rating Outlooks on 14 classes of commercial
mortgage pass-through certificates from Bear Stearns Commercial
Mortgage Securities Trust 2007-TOP26.

The downgrades are the result of loss expectations and reflect
Fitch's prospective views regarding commercial real estate market
value and cash flow declines.  Fitch forecasts potential losses of
2.8% for this transaction, should market conditions not recover.
The rating actions are based on losses of 2.1%, including 100% of
the losses associated with term defaults and any losses associated
with maturities within the next five years.  Given the significant
term to maturity, Fitch's actions only account for 25% of the
losses associated with maturities beyond five years.  The bonds
with Negative Outlooks indicate classes that may be downgraded in
the future should full potential losses be realized.

Fitch analyzed the transaction and calculated expected losses by
assuming cash flows on each of the properties decline 15% from
year-end (YE) 2007 and property values decline 35% from issuance.
These loss estimates were reviewed in more detail for loans
representing 40.8% of the pool and, in certain cases, revised
based on additional information and/or property characteristics.

Approximately 14.2% of the mortgages mature within the next five
years: 1.3% in 2011, 9.6% in 2012, 1.3% in 2013, and 2% in 2014.
In 2017, 64.8% of the pool is scheduled to mature.  None of the
largest 15 loans are scheduled to mature before 2014.

Fitch identified 20 Loans of Concern (5.6%) within the pool, three
of which (3.7%) are specially serviced.  Of the specially serviced
loans, one (0.3% of the pool) is current.  One of the Fitch Loans
of Concern (3.1%) is within the transaction's top 15 loans, and is
specially serviced.

The largest specially serviced loan is the Viad Corporate Center
loan (3.1% of the pool) which transferred to special servicing in
March 2009.  A major tenant vacated in April 2009, which resulted
in an approximate occupancy of 82%.  The property's DSCR (partial
year, through March 2009 adjusted to the new 82% occupancy) is
1.15 times (x).  The borrower has cited a substantial decrease in
market value of the property as reason for the default.  The
special servicer entered into a 90-day forbearance agreement in
June 2009 while the borrower continues its efforts to find a new
capital partner.

Thirteen of the loans within the top 15 (29.9%) are expected to
default at maturity, with loss severities ranging from less than
1% to 13.3%.  The largest contributors to loss are: Viad Corporate
Center (3.1% of the pool), 909 A Street (2.3%), and Overlook II
(1.5%).  Most of the transaction's recognized losses in this
review are attributed to the Viad Corporate Center.

The 909 A Street loan is secured by a 210,186 square foot (sf)
office property located in Tacoma, WA.  The property is 100%
occupied by the Russell Investment Group (RIG).  RIG's lease
expiration occurs in 2013 however, RIG has a five-year extension
option.  The servicer reported YE 2008 debt service coverage ratio
(DSCR) was 1.62x.

The Overlook II loan is secured by a 254,658 sf office property
located in Atlanta, GA.  The property is currently 90% occupied
which is in-line with occupancy at securitization (92.7%).  Major
tenants include Carecentric (8.6% of NRA), Insurance Office of
America (8.6%), and Nissan North America (8.5%).  The servicer
reported YE 2008 DSCR was 1.44x.

Fitch downgrades and removes from Rating Watch Negative these
classes:

  -- $160.6 million class A-J to 'AA' from 'AAA'; Outlook
     Negative;

  -- $42.1 million class B to 'A' from 'AA'; Outlook Negative;

  -- $18.4 million class C to 'A' from 'AA-'; Outlook Negative;

  -- $29 million class D to 'BBB' from 'A'; Outlook Negative;

  -- $15.8 million class E to 'BBB-' from 'A-'; Outlook Negative;

  -- $18.4 million class F to 'BB' from 'BBB+'; Outlook Negative;

  -- $18.4 million class G to 'B' from 'BBB'; Outlook Negative;

  -- $18.4 million class H to 'B-' from 'BBB-'; Outlook Negative;

  -- $2.6 million class J to 'B-' from 'BB+'; Outlook Negative;

  -- $2.6 million class K to 'B-' from 'BB'; Outlook Negative;

  -- $5.3 million class L to 'CCC/RR6' from 'BB-'; Outlook
     Negative;

  -- $2.6 million class M to 'CCC/RR6' from 'B+'; Outlook
     Negative;

  -- $5.3 million class N to 'CCC/RR6' from 'B'; Outlook Negative;

  -- $2.6 million class O to 'CCC/RR6' from 'B-'; Outlook
     Negative.

Fitch also affirms these classes:

  -- $52 million class A-1 at 'AAA'; Outlook Stable;
  -- $177 million class A-2 at 'AAA'; Outlook Stable;
  -- $65.4 million class A-3 at 'AAA'; Outlook Stable;
  -- $78 million class A-AB at 'AAA'; Outlook Stable;
  -- $991.9 million class A-4 at 'AAA'; Outlook Stable;
  -- $148.7 million class A-1A at 'AAA'; Outlook Stable;
  -- $210.6 million class A-M at 'AAA'; Outlook Stable;
  -- Interest-only class X-1 at 'AAA'; Outlook Stable;
  -- Interest-only class X-2 at 'AAA'; Outlook Stable.

Fitch does not rate the $15.8 million class P.


BEAR STERNS: Moody's Affirms Ratings on Nine 2005-PWR9 Certs.
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings of nine classes and
downgraded 15 classes of Bear Sterns Commercial Mortgage
Corporation, Commercial Mortgage Pass-Through Certificates, Series
2005-PWR9.  The downgrades are due to higher expected losses for
the pool resulting from increased leverage and anticipated losses
from loans in special servicing.  On May 21, 2009, Moody's placed
15 classes on review for possible downgrade due to an increase in
loans in special servicing.  This action concludes the review

As of the July 13, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 4% to
$2.1 billion from $2.2 billion at securitization.  The
Certificates are collateralized by 198 mortgage loans ranging in
size from less than 1% to 7% of the pool, with the top 10 loans
representing 30% of the pool.  Two loans, representing 1% of the
pool, have investment grade underlying ratings.  Nine loans,
representing 5% of the pool, have defeased and are collateralized
by U.S. government securities.

Thirty-two loans, representing 16% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.

The pool has not experienced any losses since securitization.
Eleven loans, representing 10% of the pool, are currently in
special servicing.  The largest specially serviced loan is Trilogy
Towers, the largest loan in the pool, which is now known as Towers
at Wyncote, ($135.7 million -- 6.6%).  This loan is secured by a
1,086 unit apartment complex located north of Philadelphia in
Wyncote, Pennsylvania.  The loan was transferred to special
servicing in April 2009 due to imminent default.  The borrowing
entity had been funding monthly cash flow deficits of upwards of
$300,000 since 2007.  The property's net operating income ("NOI")
has declined over 50% since securitization due to decreased rental
income and increased operating expenses.  The property was 87%
occupied as of February 2009 compared to 84% at last review and
92% at securitization.  The borrower is negotiating a possible
modification of the loan which could include a significant
infusion of equity.  Moody's estimates a potential $55.7 million
loss for this loan (41% loss severity) based on the property's
current performance.  However, this loss may not be realized if
the loan is modified and transferred back to the master servicer.
The remaining ten specially serviced loans are a mix of hotel,
industrial and retail.  Moody's estimates an aggregate loss of
approximately $16.8 million (41% loss severity on average) for the
remaining specially serviced loans.

Moody's was provided with year-end or partial year-end 2008
operating results for 96% of the pool.  Moody's loan to value
ratio is 102%, excluding specially serviced loans, compared to 97%
at Moody's last review in July 2007.  Moody's stressed debt
service coverage ratio, excluding specially serviced loans, is
1.02X compared to 1.03X at last review.  Moody's stressed DSCR is
based on Moody's net cash flow and a 9.25% stressed rate applied
to the loan balance.

Moody's uses a variation of the Herfindahl index to measure
diversity of loan size, where a higher number represents greater
diversity.  Loan concentration has an important bearing on
potential rating volatility, including the risk of multiple-notch
downgrades under adverse circumstances.  The credit neutral Herf
score is 40.  The pool, excluding defeased loans and loans with
underlying ratings, has a Herf score of 55, essentially the same
as last review.

The largest loan with an underlying rating is the Lakeside II Loan
($16.3 million -- 0.8%), which is secured by a 130,265 square foot
office property located in Chantilly, Virginia.  The property is
100.0% occupied by Integic Corporation through September 2012.
Moody's current underlying rating and stressed DSCR are Baa3 and
1.34X, respectively, compared to Baa3 and 1.32X at last review.

The second loan with an underlying rating is the 200 Glen Cove
Road Loan ($12.2 million -- 0.6%), which is secured by a 151,450
square foot retail center located in Carle Place (Nassau County),
New York.  The center was 83% occupied as of December 2008
compared to 85% at last review and 93% at securitization.
Financial performance has been negatively impacted by the decline
in occupancy.  Moody's underlying rating and stressed DSCR are
Baa2 and 1.46X, respectively, compared to Baa1 and 1.48X at last
review.

The top three performing conduit loans represent 11% of the pool.
The largest loan is the DRA - Ahwatukee Foothill Towne Center Loan
($108.9 million -- 5.3%), which is secured by a 671,300 square
foot retail center located in Phoenix, Arizona.  The property was
97% leased as of December 2008, essentially the same as at last
review.  The center is shadow anchored by Target.  The loan is
interest only and matures in August 2010.  Moody's LTV and
stressed DSCR are 110% and 0.88X, respectively, compared to 111%
and 0.85X at last review.

The second largest loan is the Boston Design Center Loan
($70.1 million -- 3.4%), which is secured by a leasehold interest
in a 552,344 square foot retail/showroom/office design center
located in Boston, Massachusetts.  The property is subject to a
ground lease which expires in 2035 with renewal options for an
additional 25 years.  The property was 95% occupied as of February
2009, essentially the same as last review.  Moody's LTV and
stressed DSCR are 93% and 1.01X, respectively, compared to 91% and
1.04X at last review.

The third largest loan is Riverside at the James Loan
($55.3 million -- 2.7%), which is secured by a 263,000 Class A
office building located in Richmond, Virginia.  The property is
89% occupied as of December 2008.  The property was 88% leased as
of December 2008 compared to 91% at securitization.  The largest
tenant is Troutman Sanders LLP which leases 54% of the property
through April 2021.  Moody's LTV and stressed DSCR are 103% and
1.00X, respectively, compared to 106% and 0.97X at last review.

Moody's rating action is:

  -- Class A-1, $29,204,510, affirmed at Aaa; previously affirmed
     at Aaa on 7/6/2007

  -- Class A-2, $358,810,000, affirmed at Aaa; previously affirmed
     at Aaa on 7/6/2007

  -- Class A-3, $45,825,000, affirmed at Aaa; previously affirmed
     at Aaa on 7/6/2007

  -- Class A-AB, $100,000,000, affirmed at Aaa; previously
     affirmed at Aaa on 7/6/2007

  -- Class A-4A, $768,026,000, affirmed at Aaa; previously
     affirmed at Aaa on 7/6/2007

  -- Class A-4B, $109,718,000, affirmed at Aaa; previously
     affirmed at Aaa on 7/6/2007

  -- Class A-1-A, $222,917,563, affirmed at Aaa; previously
     affirmed at Aaa on 7/6/2007

  -- Class X-1, Notional, affirmed at Aaa; previously affirmed at
     Aaa on 7/6/2007

  -- Class X-2, Notional, affirmed at Aaa; previously affirmed at
     Aaa on 7/6/2007

  -- Class A-J, $166,811,000, downgraded to Aa1 from Aaa;
     previously Aaa, on review for possible downgrade on 5/21/2009

  -- Class B, $13,452,000, downgraded to Aa2 from Aa1; previously
     Aa1, on review for possible downgrade on 5/21/2009

  -- Class C, $34,976,000, downgraded to A1 from Aa2; previously
     Aa2, on review for possible downgrade on 5/21/2009

  -- Class D, $24,215,000, downgraded to A2 from Aa3; previously
     Aa3, on review for possible downgrade on 5/21/2009

  -- Class E, $29,595,000, downgraded to Baa1 from A2; previously
     A2, on review for possible downgrade on 5/21/2009

  -- Class F, $21,524,000, downgraded to Baa2 from A3; previously
     A3, on review for possible downgrade on 5/21/2009

  -- Class G, $26,905,000, downgraded to Ba1 from Baa1; previously
     Baa1, on review for possible downgrade on 5/21/2009

  -- Class H, $21,524,000, downgraded to Ba2 from Baa2; previously
     Baa2, on review for possible downgrade on 5/21/2009

  -- Class J, $24,214,000, downgraded to B1 from Baa3; previously
     Baa3, on review for possible downgrade on 5/21/2009

  -- Class K, $5,381,000, downgraded to B2 from Ba1; previously
     Ba1, on review for possible downgrade on 5/21/2009

  -- Class L, $8,072,000, downgraded to B3 from Ba2; previously
     Ba2, on review for possible downgrade on 5/21/2009

  -- Class M, $10,716,000, downgraded to Caa1 from Ba3; previously
     Ba3, on review for possible downgrade on 5/21/2009

  -- Class N, $8,072,000, downgraded to Caa2 from B1; previously
     B1, on review for possible downgrade on 5/21/2009

  -- Class P, $8,071,000, downgraded to Caa3 from B2; previously
     B2, on review for possible downgrade on 5/21/2009

  -- Class Q, $5,381,000, downgraded to Caa3 from B3; previously
     B3, on review for possible downgrade on 5/21/2009


BEAR STEARNS: S&P Downgrades Ratings on 13 2006-BBA7 Certificates
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on all 13
classes of commercial mortgage pass-through certificates from Bear
Stearns Commercial Mortgage Securities Inc.'s series 2006-BBA7.

The lowered ratings reflect S&P's revaluation of the remaining
loans in the pool, which considered actual and potential property
performance declines, as well as concerns regarding the borrower's
ability to refinance the loan by its October 2010 final maturity.
S&P's analysis factored in S&P's expectation that average 2009
revenue per available room in the lodging industry would decline
between 14% and 16%, as S&P noted in a recent article, and also
considered conditions of the local lodging markets.

The distribution of interest proceeds to the interest-only classes
X-1B and X-3 from series 2006-BBA7 are made pro rata to class A-1.
S&P downgraded classes X-1B and X-3 accordingly.  S&P published a
request for comment proposing changes to S&P's interest-only
criteria on June 1, 2009.  After finalizing S&P's criteria review,
S&P may revise its current criteria.  Any change in S&P's criteria
may affect outstanding ratings, including the ratings on the X-1B
and X-3 certificates S&P lowered.

The larger of the two remaining loans in the pool is the Columbia
Sussex Portfolio loan, with a whole-loan and trust balance of
$550.0 million (93.1% of the remaining pool balance).  In
addition, the borrower's equity interests in the collateral
properties secure a $513.3 million mezzanine loan.  The floating-
rate loan provided for interest-only payments during the initial
two-year term and amortizes on a 25-year schedule thereafter.
Fourteen first mortgages encumbering full-service hotel
properties, including 11 fee interests and three leasehold
interests encompassing 5,821 rooms, secure the loan.  The
portfolio is diversified across 10 states, the District of
Columbia, and Canada.

At issuance the portfolio was branded by 10 Wyndham flags, two
Marriott flags, one Sheraton flag, and one Westin flag.  The
sponsor invested $175.5 million ($30,181 per key) as part of a
plan to reflag 13 of the 14 properties (six Westin flags, three
Hilton flags, two Sheraton flags, and two Marriott flags); the
Wyndham Chicago Downtown will continue to remain a Wyndham hotel.
The master servicer, Bank of America, reported a debt service
coverage (DSC) of 2.61x and 65% occupancy for the year ended
December 31, 2008.  Based on S&P's cash flow analysis on a review
of the borrower's operating statements for the 12 months ended
December 31, 2008, and the borrower's 2009 budget, S&P derived an
adjusted valuation that is 40% below S&P's value at issuance.  The
decline in S&P's adjusted valuation is due primarily to lower
actual and expected revenue.  The loan is scheduled to mature on
October 12, 2009, with one 12-month extension option.  According
to the master servicer, the loan is expected to meet its extension
requirements.

The Citigroup Property Investors Hilton portfolio is the second
remaining loan and has a trust and whole-loan balance of
$40.5 million (6.9% of the remaining pool).  In addition, the
borrower's equity interests in the collateral properties secure a
$28.0 million mezzanine loan.  The floating-rate loan provided for
interest-only payments during the initial two-year term and
amortizes on a 25-year schedule thereafter.  First mortgages
encumbering the fee interests in five cross-collateralized and
cross-defaulted hotels encompassing a total of 944 rooms secure
this loan.  Four of the properties (767 rooms, 81.3% of total
rooms) are flagged largely as limited-service Hilton Garden Inns,
and the remaining property (177 rooms, 18.7%) is flagged as a
Homewood Suites, which is Hilton's upscale, extended-stay brand.
Built between 1999 and 2002, the properties are located in major
metropolitan markets in Florida, Georgia, Illinois, California,
and Colorado.

According to the master servicer, Bank of America, this loan was
transferred to the special servicer, also Bank of America, on
July 24, 2009, due to imminent default.  The borrower informed the
master servicer that it was unwilling to fund the July 2009
shortfall.  The special servicer did not provide details on the
workout given the date of the transfer.  The master servicer
reported a DSC of 2.80x and 72% occupancy for the year ended
December 31, 2008.  Based on S&P's cash flow analysis on a review
of the borrower's operating statements for the 12 months ended
December 31, 2008, and the borrower's 2009 budget, S&P derived an
adjusted valuation that is 31% below S&P's value at issuance.  The
decline in S&P's adjusted valuation is due primarily to lower
actual and expected revenue.  The loan is scheduled to mature on
October 12, 2009, with one 12-month extension option.

      Ratings Lowered And Removed From Creditwatch Negative

         Bear Stearns Commercial Mortgage Securities Inc.
  Commercial mortgage pass-through certificates series 2006-BBA7

                                 Rating
                                 ------
            Class              To       From
            -----              --       ----
            A-1                AA       AAA/Watch Neg
            A-2                BBB      AAA/Watch Neg
            B                  BB+      AA+/Watch Neg
            C                  BB       AA/Watch Neg
            D                  B+       AA-/Watch Neg
            E                  B        A+/Watch Neg
            F                  B        A/Watch Neg
            G                  B-       A-/Watch Neg
            H                  CCC+     BBB+/Watch Neg
            J                  CCC      BBB/Watch Neg
            K                  CCC-     BBB-/Watch Neg
            X-1B               AA       AAA/Watch Neg
            X-3                AA       AAA/Watch Neg


BEAR STEARNS: S&P Downgrades Ratings on 15 2007-TOP28 Securities
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 15
classes of commercial mortgage-backed securities from Bear Stearns
Commercial Mortgage Securities Trust 2007-TOP28 and removed them
from CreditWatch with negative implications, where they were
placed June 26, 2009.  In addition, S&P affirmed its ratings on
eight classes from the same transaction and removed six of them
from CreditWatch negative.

The downgrades follow S&P's analysis of the transaction using
S&P's recently released U.S. conduit and fusion CMBS criteria,
which was the primary driver of the rating actions.  S&P's
analysis included a review of the credit characteristics of all of
the loans in the pool.  Using servicer-provided financial
information, S&P calculated an adjusted debt service coverage of
1.53x and a loan-to-value ratio of 98.8%.  S&P further stressed
the loans' cash flows under S&P's 'AAA' scenario to yield a
weighted average DSC of 0.97x and an LTV of 132.9%.  The implied
defaults and loss severity under the 'AAA' scenario were 77.9% and
31.3%, respectively.  The DSC and LTV calculations exclude two
credit impaired loans (0.7%).  S&P estimated losses for these
loans, which are included in the 'AAA' scenario implied default
and loss figures.

S&P affirmed the ratings on the interest-only certificates based
on S&P's current criteria.  S&P published a request for comment
proposing changes to the IO criteria on June 1, 2009.  After S&P
finalizes its criteria review, S&P may revise its current
criteria.  Any change in S&P's criteria may impact outstanding
ratings, including the ratings on the IO certificates S&P
affirmed.

                          Credit concerns

There are no delinquent or specially serviced loans as of the July
2009 remittance date.

                       Transaction summary

As of the July 2009 remittance report, the collateral pool
consisted of 209 loans with an aggregate trust balance of
$1.75 billion, which was slightly lower than the balance of
$1.76 billion at issuance.  The master servicer for the
transaction is Wells Fargo Bank N.A.  Financial information was
provided for 100.0% of the pool, and 98.7% of the financial
information was full-year 2008 data.  S&P calculated a weighted
average DSC of 1.55x for the pool based on the reported figures.
S&P's adjusted DSC and LTV were 1.53x and 98.8%, respectively.
The transaction has not experienced any principal losses to date.
Thirty-two loans are on the master servicer's watchlist, including
one of the top 10 loans.  Twenty loans ($117.2 million, 1.7%) have
a reported DSC below 1.10x, and 13 of these loans ($79.1 million,
0.7%) have a reported DSC of less than 1.0x.

                     Summary of top 10 loans

The top 10 exposures have an aggregate outstanding balance of
$639.8 million (36.6%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC for the top 10 loans of 1.56x,
compared with 1.61x at issuance.  The eighth-largest loan in the
pool ($29.0 million, 1.7%) appears on the master servicer's
watchlist.  S&P's adjusted DSC and LTV for the top 10 loans were
1.54x and 91.1%, respectively.

Standard & Poor's stressed the loans in the pool according to
S&P's updated conduit/fusion criteria.  The resultant credit
enhancement levels support the lowered and affirmed ratings.

      Ratings Lowered And Removed From Creditwatch Negative

   Bear Stearns Commercial Mortgage Securities Trust 2007-TOP28
          Commercial mortgage pass-through certificates

                  Rating
                  ------
      Class      To    From             Credit enhancement (%)
      -----      --    ----             ----------------------
      A-M        A+    AAA/Watch Neg                     17.12
      A-J        BBB+  AAA/Watch Neg                     10.58
      B          BBB   AA/Watch Neg                       8.81
      C          BBB-  AA-/Watch Neg                      7.93
      D          BB+   A/Watch Neg                        6.29
      E          BB    A-/Watch Neg                       5.04
      F          BB-   BBB+/Watch Neg                     4.03
      G          B+    BBB/Watch Neg                      2.90
      H          B     BBB-/Watch Neg                     2.01
      J          B     BB+/Watch Neg                      1.89
      K          B-    BB/Watch Neg                       1.76
      L          B-    BB-/Watch Neg                      1.64
      M          B-    B+/Watch Neg                       1.38
      N          CCC+  B/Watch Neg                        1.13
      O          CCC+  B-/Watch Neg                       1.01

      Ratings Affirmed And Removed From Creditwatch Negative

   Bear Stearns Commercial Mortgage Securities Trust 2007-TOP28
          Commercial mortgage pass-through certificates

                  Rating
                  ------
      Class      To    From             Credit enhancement (%)
      -----      --    ----             ----------------------
      A-1        AAA   AAA/Watch Neg                     27.19
      A-2        AAA   AAA/Watch Neg                     27.19
      A-3        AAA   AAA/Watch Neg                     27.19
      A-AB       AAA   AAA/Watch Neg                     27.19
      A-4        AAA   AAA/Watch Neg                     27.19
      A-1A       AAA   AAA/Watch Neg                     27.19

                         Ratings Affirmed

   Bear Stearns Commercial Mortgage Securities Trust 2007-TOP28
          Commercial mortgage pass-through certificates

          Class      Rating        Credit enhancement (%)
          -----      ------        ----------------------
          X-1        AAA                              N/A
          X-2        AAA                              N/A

                       N/A - Not applicable.


BOUNTIFUL: S&P Junks Rating on Series 98 Revenue Bonds
------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on
Bountiful, Utah's collateral mortgage revenue bonds series 98 to
'CC' from 'BBB' and removed the rating from CreditWatch with
negative implications where it was placed July 1, 2009.  The
outlook is developing.  This action follows Standard & Poor's
July 28, 2009, downgrade of Ambac Assurance Corp. to CC/Developing
from BBB/Watch Neg.

The affected issue receives partial support in the form of
guaranteed investment contracts or investment agreements from
Ambac Assurance Corp. for the debt service reserve fund.
According to current criteria, Standard & Poor's considers whether
monies deposited in the DSRF, which is generally sized in the
amount of at least six to 12 months' debt service, are invested
in investment grade securities rated 'BBB-' or higher, and will be
available to pay debt service in the event of a shortfall.
Because AMBAC is currently rated below investment grade, its
rating is no longer consistent with S&P's minimum rating level for
DSRF investments.


BRAZOS STUDENT: Fitch Maintains Ratings on Various Student Loans
----------------------------------------------------------------
Fitch Ratings currently maintains ratings on student loan asset-
backed securities issued by Brazos Student Finance Corporation
under an Amended and Restated Indenture, dated as of October 1,
2007, between BSFC and U.S. Bank National Association, as Trustee
and Eligible Lender Trustee.  BSFC has requested that Fitch
confirm its existing ratings on the securities issued under the
Indenture upon the adoption and effectiveness of a supplemental
indenture (the Supplement).  Consistent with its statements on
policies regarding rating confirmations in structured finance
transactions (January 13, 2009) and student loan confirms (May 8,
2009), Fitch is treating this request as a notification.

The Supplement allows BSFC to purchase outstanding auction rate
securities issued under the Indenture at a price less than par
which includes the remaining principal balance plus 100% of the
accrued and unpaid interest.  Funds deposited into the note
redemption fund held under the Indenture, which are currently used
to pay down securities at par plus accrued interest, would become
available at the direction of BSFC to purchase securities from
investors, who voluntarily elect to sell their securities at a
discount.  Any securities so purchased by BSFC would be
immediately tendered to the Trustee for cancellation.  Based on
the information provided, Fitch has determined that the execution
and delivery of the Supplement and the changes to the Indenture
contained in the Supplement will not have an impact on the
existing ratings on the securities issued under the Indenture.
This determination only addresses the effect of the Supplement and
its changes on the current ratings assigned by Fitch to the
securities issued under the Indenture.  It does not address
whether this change is permitted by the terms of the documents nor
does it address whether it is in the best interests of, or
prejudicial to, some or all of the holders of the securities
listed.

Based on the trust estate's balance sheet as of March 31, 2009,
investors who choose to sell their securities at a discount may
positively increase the senior and total parity ratios of the
trust estate.  The subordination level for the senior securities
would increase as well.  In addition, the composition of the loan
pool held under the Indenture and the weighted average coupon rate
of the securities are not expected to change materially.

The ratings assigned by Fitch are based on the documents and
information provided to Fitch by BSFC and other parties and the
receipt of final closing documents.  Fitch relies on all these
parties for the accuracy of such information and documents.  Fitch
did not audit or verify the truth or accuracy of such information.

The student loan asset-backed securities, which include auction
rate securities issued under the Indenture by BSFC, are currently
rated by Fitch:

Brazos Student Finance Corporation. (2003-2 Indenture)

  -- $8,000,000 senior series 2003 A-7 notes 'AAA';
  -- $83,400,000 senior series 2003 A-8 notes 'AAA';
  -- $70,850,000 senior series 2007 A-1 notes 'AAA';
  -- $70,850,000 senior series 2007 A-2 notes 'AAA';
  -- $70,750,000 senior series 2007 A-3 notes 'AAA';
  -- $60,750,000 senior series 2007 A-4 notes 'AAA';
  -- $30,400,000 senior series 2007 A-5 notes 'AAA';
  -- $41,700,000 subordinate series 2003 B-2 notes 'BB';
  -- $31,700,000 subordinate series 2003 B-3 notes 'BB'.


C-BASS MORTGAGE: Moody's Cuts Ratings on Nine 2006-SC1 Tranches
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of nine
tranches issued by C-BASS Mortgage Loan Asset-Backed Certificates,
Series 2006-SC1 due to higher projected pool losses in relation to
remaining tranche-specific credit protection.  Underlying
securities' collateral consists primarily of small size commercial
loans.

Moody's final rating actions are based on current ratings, level
of credit enhancement, collateral performance and updated pool-
level loss expectations relative to current level of credit
enhancement.  Moody's actions took into consideration timing of
tranche repayment and allocation of losses (if any).

Complete rating actions are:

Issuer: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2006-SC1

  -- Cl. A, Downgraded to Aa3; previously on 6/16/2006 Assigned
     Aaa

  -- Cl. M-1, Downgraded to Baa1; previously on 6/16/2006 Assigned
     Aa2

  -- Cl. M-2, Downgraded to Baa2; previously on 6/16/2006 Assigned
     Aa3

  -- Cl. M-3, Downgraded to Baa3; previously on 6/16/2006 Assigned
     A2

  -- Cl. M-4, Downgraded to Ba2; previously on 6/16/2006 Assigned
     A3

  -- Cl. M-5, Downgraded to B1; previously on 6/16/2006 Assigned
     Baa2

  -- Cl. B-1, Downgraded to Caa1; previously on 6/16/2006 Assigned
     Baa3

  -- Cl. B-2, Downgraded to Ca; previously on 6/16/2006 Assigned
     Ba1

  -- Cl. B-3, Downgraded to C; previously on 6/16/2006 Assigned
     Ba2


CAPMARK VI: S&P Downgrades Ratings on Six Classes of Notes to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D' on
six classes of notes issued by Capmark VI Ltd., a hybrid
collateralized debt obligation transaction, following the
liquidation of the collateral in the portfolio.  S&P subsequently
withdrew its ratings on these tranches.

S&P lowered its ratings to 'D' because the transaction did not
have sufficient proceeds to pay back par payments to the
noteholders after making the termination payments on the credit
default swap contract.

The deal had triggered an event of default, after which the
controlling noteholders voted to accelerate the maturity of the
notes and liquidate the collateral assets.

The current rating actions follow notice from the trustee that the
liquidation of the portfolio assets is complete and that the
available proceeds have been distributed to the noteholders.

                          Rating Actions

                          Capmark VI Ltd.

                                 Rating
                                 ------
                Class       To    Interim    From
                -----       --    -------    ----
                CreditFac.  NR    D          CC
                A-1         NR    D          CC
                A-2         NR    D          CC
                B           NR    D          CC
                C           NR    D          CC
                Income Nts  NR    D          CC

                         NR - Not rated.


CARLYLE CREDIT: Moody's Downgrades Ratings on Two Classes of Notes
------------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Carlyle Credit Partners Financing
I, Ltd.:

  -- US$332,000,000 Class A Senior Secured Floating Rate Notes due
     2020, Downgraded to Aa1; previously on April 1, 2008 Assigned
     Aaa;

  -- US$15,000,000 Class B Senior Secured Floating Rate Notes due
     2020, Downgraded to Aa3; previously on March 4, 2009 Aa2
     Placed Under Review for Possible Downgrade.

In addition, Moody's has confirmed the ratings of these notes:

  -- US$45,000,000 Class C Secured Deferrable Floating Rate Notes
     due 2020, Confirmed at Ba3; previously on March 20, 2009
     Downgraded to Ba3 and Placed Under Review for Possible
     Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
second lien loans will be below their historical averages,
consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, and an increase in the proportion of
securities from issuers rated Caa1 and below.  The weighted
average rating factor has steadily increased over the last year
and is currently 2706 as of the last trustee report, dated
July 13, 2009.  Based on the same report, defaulted securities
total about $8.4 million, accounting for roughly 2% of the
collateral balance, and securities rated Caa1 or lower make up
approximately 2.5% of the underlying portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Carlyle Credit Partners Financing I, Ltd., issued on April 1,
2008, is a collateralized loan obligation backed primarily by a
portfolio of senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


CARLYLE HIGH: Moody's Downgrades Ratings on Various Classes
-----------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Carlyle High Yield Partners VII,
Ltd.:

  -- US$206,000,000 Class A-1 Floating Rate Notes Due 2019,
     Downgraded to A2; previously on September 21, 2005 Assigned
     Aaa;

  -- US$87,000,000 Class A-2-A Floating Rate Notes Due 2019,
     Downgraded to Aa1; previously on September 21, 2005 Assigned
     Aaa;

  -- US$13,000,000 Class A-3 Floating Rate Notes Due 2019,
     Downgraded to A3; previously on March 4, 2009 Aa1 Placed
     Under Review for Possible Downgrade;

  -- US$14,800,000 Class B Floating Rate Notes Due 2019,
     Downgraded to Baa3; previously on March 4, 2009 Aa2 Placed
     Under Review for Possible Downgrade;

  -- US$21,200,000 Class C Floating Rate Deferrable Notes Due
     2019, Downgraded to Ba3; previously on March 18, 2009
     Downgraded to Ba1 and Placed Under Review for Possible
     Downgrade;

  -- US$16,000,000 Class D-1 Floating Rate Deferrable Notes Due
     2019, Downgraded to Ca; previously on March 18, 2009
     Downgraded to B1 and Placed Under Review for Possible
     Downgrade;

  -- US$8,000,000 Class D-2 Fixed Rate Deferrable Notes Due 2019,
     Downgraded to Ca; previously on March 18, 2009 Downgraded to
     B1 and Placed Under Review for Possible Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds and second lien loans will be below
their historical averages, consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, an increase in the proportion of securities
from issuers rated Caa1 and below, and failure of the diversity
test, WARF test, Class C overcollateralization test, Class D
overcollateralization test, and the Caa/CCC limitation test.  The
weighted average rating factor has steadily increased over the
last year and is currently 2893 versus a test level of 2710 as of
the last trustee report, dated July 3, 2009.  Based on the same
report, defaulted securities total about $22 million, accounting
for roughly 5.7% of the collateral balance, and securities rated
Caa1 or lower make up approximately 12.5% of the underlying
portfolio.  Additionally, interest payments on the Class D Notes
are presently being deferred as a result of the failure of the
Class C overcollateralization test.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Carlyle High Yield Partners VII, Ltd., issued on September 21,
2005, is a collateralized loan obligation backed primarily by a
portfolio of senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


CENT CDO: Moody's Downgrades Ratings on Four Classes of Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Cent CDO 14 Limited:

  -- US$110,000,000 Class A-1 Senior Term Notes due 2021,
     Downgraded to Aa2; previously on March 6, 2007 Assigned Aaa;

  -- US$26,250,000 Class A-2b Senior Term Notes due 2021,
     Downgraded to Aa3; previously on March 4, 2009 Aa1 Placed
     Under Review for Possible Downgrade;

  -- US$33,750,000 Class B Senior Floating Rate Notes due 2021,
     Downgraded to A3; previously on March 4, 2009 Aa2 Placed
     Under Review for Possible Downgrade;

  -- US$12,500,000 Class E Deferrable Junior Floating Rate Notes
     due 2021, Downgraded to Caa3; previously on March 13, 2009
     Downgraded to Caa2 and Placed Under Review for Possible
     Downgrade.

In addition, Moody's has confirmed the ratings of these notes:

  -- US$ 24,375,000 Class C Deferrable Mezzanine Floating Rate
     Notes due 2021, Confirmed at Ba1; previously on March 13,
     2009 Downgraded to Ba1 and Placed Under Review for Possible
     Downgrade;

  -- US$18,750,000 Class D Deferrable Mezzanine Floating Rate
     Notes due 2021, Confirmed at B1; previously on March 13, 2009
     Downgraded to B1 and Placed Under Review for Possible
     Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds and second lien loans will be below
their historical averages, consistent with Moody's research.
Moody's has also applied resecuritization stress factors to
default probability assumptions for structured finance asset
collateral as described in the press release titled "Moody's
updates its key assumptions for rating structured finance CDOs,"
published on December 11, 2008.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, and an increase in the proportion of
securities from issuers rated Caa1 and below.  The weighted
average rating factor has increased over the last year and is
currently 2919 as of the last trustee report, dated July 8, 2009.
Based on the same report, defaulted securities total about
$37 million, accounting for roughly 7.8% of the collateral
balance, and securities rated Caa1 or lower make up approximately
9.5% of the underlying portfolio.

Moody's also observes that the transaction is exposed to mezzanine
and junior CLO tranches in the underlying portfolio.  The majority
of these CLO tranches are currently assigned low speculative-grade
ratings and carry depressed market valuations that may herald poor
recovery prospects in the event of default.  Additionally, Moody's
noted that the portfolio includes a material concentration in CLO
securities that are issued by affiliates of the collateral
manager, which Moody's views as potentially exposing the notes to
additional correlation risk.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Cent CDO 14 Limited, issued on March 6, 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


CITIGROUP MORTGAGE: Moody's Puts Ratings on Resecuritized Certs.
----------------------------------------------------------------
Moody's Investors Service has assigned the below-mentioned ratings
to the Certificates as the "Resecuritized Certificates" issued in
connection with Citigroup Mortgage Loan Trust 2009-7 as the
"Resecuritized Transaction".

Classes 1A1 and 1A2 are backed by Class A1 as the "Underlying
Certificate1" issued by HSI Asset Securitization Corporation Trust
2007-NC1.  The Underlying Certificate1 is backed primarily by
first -lien, adjustable-rate, subprime residential mortgage loans.
Class 1A1 is a senior class whereas Class 1A2 is a subordinate
class which receives principal payment after Class 1A1 but absorbs
losses before Class 1A1.  Additionally, Class 1A2 is an "accrual
certificate," i.e. it accrues the interest that would have been
paid to it.  Cashflows generated due to such accrual of interest
on Class 1A2 is used to pay down Class 1A1 certificate.

Classes 5A1 and 5A2 are backed by Class A-2 (the "Underlying
Certificate2") issued by CWALT, Inc. Mortgage Pass-Through
Certificates, Series 2005-60T1.  The Underlying Certificate2 is
backed primarily by first-lien, adjustable-rate, Alt-A residential
mortgage loans.  Class 5A1 is a senior class whereas Class 5A2 is
a subordinate class which receives principal payment after Class
5A1 but absorbs losses before Class 5A1.  Additionally, Class 5A2
is an "accrual certificate," i.e. it accrues the interest that
would have been paid to it.  Cashflows generated due to such
accrual of interest on Class 5A2 is used to pay down Class 5A1
certificate.

The ratings on the resecuritized certificates address the ultimate
payment of promised interest and principal on the rated
certificates and do not address any other amounts that may be
payable on the certificates.

On September 22, 2008, Moody's announced that it will assign a
rating to any security issued by a resecuritization transaction
backed by one or more RMBS only after first reviewing the ratings
(and, if appropriate, taking rating actions) on the RMBS
underlying the resecuritization.  This review would be in addition
to its normal surveillance of the underlying transactions

When assigning the ratings on the Resecuritized Certificates
Moody's first updated rating specific-stress prepayment and loss
assumptions on the remaining pools of mortgages remaining in each
of the underlying transaction.  The updated assumptions
considered, among other things, mortgage pool's past performance,
its collateral attributes, macro economic assumptions and Moody's
negative performance outlook on the RMBS sector.  Second, multiple
cash flow scenarios were run, assuming different combinations of
prepayment and loss timing on the underlying mortgage pools.  In
each scenario, cash flow from each of the underlying certificates
was compared to proposed structure on each of the Resecuritized
Certificates.  Third, Moody's analyzed the loss on the
Resecuritized Seniors at a rating specific stress level, and the
sensitivity of loss for the Resecuritized Seniors to changes in
prepayment and loss timing assumptions.  In Moody's opinion the
issuer's targeted levels of credit enhancement for each of the
Classes was consistent with the respective rating.

The rating on each subordinate class was based on (i) the
structure of the resecuritization transaction, (ii) the rating on
the respective underlying certificate, and (iii) the size of the
subordinate class.  The probability of default for the subordinate
class is the same as that for its underlying certificate.
However, Moody's anticipates a higher loss severity on the
subordinate class due to its subordinate position to the senior
class (both in terms of principal distribution and loss
allocation), and smaller size (when compared to underlying
certificate).  Therefore, the rating on subordinate class is lower
than the rating on the respective underlying certificate.

Because the ratings on the resecuritized certificates are linked
to the rating of the underlying certificate and their mortgage
pools performance, any rating action on the underlying
certificates may trigger a review of the ratings on the
resecuritized certificates.

Deutsche Bank National Trust Company will act as the
Administrative Trustee in the transaction.

The complete rating actions are:

Issuer: Citigroup Mortgage Loan Trust 2009-7, Resecuritization
Trust Certificates, Series 2009-7

  -- Cl. 1A1, Assigned Baa1
  -- Cl. 1A2, Assigned Ca
  -- Cl. 5A1, Assigned Aaa
  -- Cl. 5A2, Assigned C


COMM 2004-LNB3: DBRS Downgrades Class O Ratings to C
----------------------------------------------------

DBRS has downgraded Class O of COMM 2004-LNB3 to C Interest in
Arrears from CCC due to interest shortfalls.  The class will
continue to carry a Negative trend.

The change primarily reflects interest shortfalls associated with
a $2.6 million appraisal reduction taken to Broadway Place (0.4%
of the pool) and from special servicing fees within the
transaction.  To the extent that the resolution of Broadway Place
results in losses less than those anticipated by the appraisal
reduction, the impact of the interest shortfalls would be reduced.

                           *     *     *

As reported in the Troubled Company Reporter on October 31, 2008,
Moody's Investors Service upgraded the ratings of two classes,
downgraded four classes and affirmed 13 classes of COMM 2004-LNB3,
Commercial Mortgage Pass-Through Certificates as:

  -- Class A-2, $92,243,021, affirmed at Aaa
  -- Class A-3, $104,606,000, affirmed at Aaa
  -- Class A-4, $114,956,000, affirmed at Aaa
  -- Class A-5, $502,796,000, affirmed at Aaa
  -- Class A-1A, $234,062,343, affirmed at Aaa
  -- Class X, Notional, affirmed at Aaa
  -- Class B, $40,063,000, upgraded to Aaa from Aa2
  -- Class C, $16,692,000, upgraded to Aa2 from Aa3
  -- Class D, $28,378,000, affirmed at A2
  -- Class E, $25,039,000, affirmed at A3
  -- Class F, $15,023,000, affirmed at Baa1
  -- Class G, $13,354,000, affirmed at Baa2
  -- Class H, $11,685,000, affirmed at Baa3
  -- Class J, $11,685,000, affirmed at Ba1
  -- Class K, $6,677,000, affirmed at Ba2
  -- Class L, $3,339,000, downgraded to B1 from Ba3
  -- Class M, $5,008,000, downgraded to B2 from B1
  -- Class N, $5,007,000, downgraded to Caa1 from B2
  -- Class O, $5,008,000, downgraded to Caa2 from B3

Moody's upgraded Classes B and C due to overall stable pool
performance, increased credit enhancement and increased
defeasance.  Moody's downgraded Classes L, M, N and O due to
estimated losses from a specially serviced loan and increased
dispersion.


CREDIT SUISSE: Fitch Takes Rating Actions on 2007-C1 Certs.
-----------------------------------------------------------
Fitch Ratings has taken various rating actions on 19 classes of
commercial mortgage pass-through certificates from Credit Suisse
Commercial Mortgage Trust series 2007-C1.  In addition, Fitch has
assigned Rating Outlooks, as applicable.  A detailed list of
rating actions follows at the end of this release.

The downgrades are the result of loss expectations and reflect
Fitch's prospective views regarding commercial real estate market
value and cash flow declines.  Fitch forecasts potential losses of
15% for this transaction should market conditions not recover,
which is among the highest potential losses for its vintage.  The
rating actions are based on losses of 13.1%, including 100% of the
losses associated with term defaults and any losses associated
with maturities within the next five years.  Given the significant
term to maturity, Fitch's actions only account for 25% of the
losses associated with maturities beyond five years.  The bonds
with Negative Outlooks indicate classes that may be downgraded in
the future should full potential losses be realized.  Fitch
considers the Outlooks on the super-senior classes to be Stable
due to projected losses having limited impact on credit
enhancement when associated paydown is factored into the analysis.

Fitch analyzed the transaction and calculated expected losses by
assuming cash flows on each of the properties decline 15% from
year-end (YE) 2007 and property values decline 35% from issuance.
These loss estimates were reviewed in more detail for certain
loans representing 49.8% of the pool and, in some cases, revised
based on additional information and/or property characteristics.

Approximately 19% of the mortgages mature within the next five
years: 0.0% in 2010, 7.8% in 2011, 3.6% in 2012, 0.2% in 2013, and
7.3% in 2014.  In 2016 and 2017, 80% of the pool is scheduled to
mature.

Fitch identified 69 Loans of Concern (47.0%) within the pool, 21
of which (15.0%) are specially serviced.  Of the specially
serviced loans, four (4.0%) are current.  Five of the specially
serviced loans (10.1%), including four cross-collateralized and
cross-defaulted loans (4.8%), are within the transaction's top 15
loans (44.9%) by unpaid principal balance.  (Note: Fitch considers
the transaction's top 15 loan concentration to include one
portfolio of four cross-collateralized and cross defaulted loans,
in addition to 14 other individual loans, as ranked by unpaid
principal balance.)

Twelve of the top 15 loans (31.4%), including four cross-
collateralized and cross-defaulted loans (4.8%), are expected to
default or have already defaulted during the term, with loss
severities ranging from 10.1% to 49.6%.  The largest contributors
to loss are: Savoy Park (6.3%), CVI Multifamily Portfolio (5.4%),
and the four crossed loans comprising the Mansions Multifamily
Portfolio (4.8%).

The Savoy Park loan (6.3%) is secured by a multifamily complex
consisting of 1,802 units, located in the Harlem neighborhood of
New York.  As of June 4, 2009, a majority of the units remained
rent-stabilized, while approximately one-fourth of the units were
either market units or were units that are technically stabilized
but produce market-level rents.  The property continues to
generate revenues on schedule with those expected by Fitch at
issuance; however, expenses remain significantly higher (46%) than
projected.  The reported debt service coverage ratio (DSCR) was
0.57 times (x) for 2008.

The primary driver of Savoy Park's increased expenses was the
utilities line item, which has remained high due to higher fuel
prices and because the sub-metering project anticipated at
issuance had not begun as of year-end 2008.  The sub-metering
project has since received all approvals, and installations began
in July 2009.  As of the July remittance, approximately
$18.5 million in reserves remained.  At issuance, $157.5 million
of mezzanine debt was also issued to the borrower.  The loan
sponsorship consists of Apollo Real Estate Advisors, ABP Pension
Fund, and Vantage Properties.

The CVI Multifamily Portfolio loan (5.4%), sponsored by Commercial
Ventures, Inc., transferred to the special servicer on April 17,
2009 due to default on three related mezzanine loans totaling
$68.2 million.  Cash flows generated by the property continue to
service the first mortgage loan debt on an approximately break-
even basis, and a hard lockbox is in place.  The loan remains
current, and the special servicer is negotiating with the borrower
to place the properties into receivership.  At issuance, the loan
was structured with springing recourse to CVI for 11% of the total
loan amount subject to achievement of a minimum DSCR (which did
not occur).  Approximately $5.7 million in reserves remained as of
the July remittance.

The CVI Multifamily Portfolio loan is collateralized by 20
multifamily properties comprising 2,990 units, which are located
across seven metropolitan areas, including: Atlanta, GA (1);
Austin, TX (3); Charleston, SC (2); Denver, CO (2); Orlando, FL
(1); Sacramento, CA (2); and Virginia Beach, VA (9).

The Mansions Multifamily Portfolio (4.8%) is comprised of four
cross-collateralized and cross-defaulted loans, secured by four
multifamily properties located in Austin, TX (2) and Round Rock,
TX (2).  The loans transferred to the special servicer March 6,
2009 following the borrowers' request for transfer.  The four
collateral properties are described by the special servicer as
being in good condition with a strong amenities package; however,
a title search revealed several liens filed against each property.
Additionally, the portfolio-wide occupancy dropped to 64.6% as of
the time of the transfer, while the DSCR was reported at 0.57x at
that time.

The special servicer initially secured a receiver for each
property, but the receivers were dismissed when the borrowers
filed for bankruptcy in April 2009.  The special servicer
continues to work through the bankruptcies and to pursue other
available remedies, including personal recourse.  At issuance,
$20.2 million in mezzanine financing had been extended to the
borrowers.  The loans are sponsored by Chowdary Yalamanchili.

Fitch has downgraded, removed from Rating Watch Negative, and
assigned Rating Outlooks to these classes:

  -- $286.6 million class A-J to 'B-' from 'AAA'; Outlook
     Negative;

  -- $25.3 million class B to 'B-' from 'AA+'; Outlook Negative;

  -- $37.9 million class C to 'B-' from 'AA'; Outlook Negative;

  -- $33.7 million class D to 'B-' from 'AA-'; Outlook Negative;

  -- $21.1 million class E to 'B-' from 'A+'; Outlook Negative;

  -- $29.5 million class F to 'B-' from 'A'; Outlook Negative;

  -- $33.7 million class G to 'B-' from 'A-'; Outlook Negative;

  -- $37.9 million class H to 'CCC/RR6' from 'BBB+';

  -- $33.7 million class J to 'CCC/RR6' from 'BBB-';

  -- $37.9 million class K to 'CCC/RR6' from 'BB';

  -- $8.4 million class L to 'CCC/RR6' from 'BB-';

  -- $12.6 million class M to 'CCC/RR6' from 'B+';

  -- $8.4 million class N to 'CCC/RR6' from 'B';

  -- $8.4 million class O to 'CCC/RR6' from 'B-';

  -- $8.4 million class P to 'CC/RR6' from 'B-';

  -- $8.4 million class Q to 'CC/RR6' from 'CCC/DR1';

  -- $12.6 million class S to 'CC/RR6' from 'CC/DR2'.

Fitch has downgraded and revised Rating Outlooks on these classes,
as indicated:

  -- $125 million class A-MFL to 'A' from 'AAA'; Outlook to
     Negative from Stable;

  -- $212.1 million class A-M to 'A' from 'AAA'; Outlook to
     Negative from Stable.

Fitch has affirmed these classes, with a Stable Outlook:

  -- $23.9 million class A-1 at 'AAA';
  -- $139 million class A-2 at 'AAA';
  -- $98.3 million class A-AB at 'AAA';
  -- $758 million class A-3 at 'AAA';
  -- $1.321 billion class A-1A at 'AAA';
  -- $2.896 billion interest-only class A-SP at 'AAA';
  -- $3.351 billion interest-only class A-X at 'AAA'.

Fitch does not rate the $29.5 million class T certificates.


CREDIT SUISSE: Fitch Takes Rating Actions on 2007-C5 Certs.
-----------------------------------------------------------
Fitch Ratings has downgraded, removed from Rating Watch Negative,
and assigned Rating Outlooks to 16 classes of commercial mortgage
pass-through certificates from Credit Suisse Commercial Mortgage
Trust series 2007-C5.

The downgrades are the result of loss expectations and reflect
Fitch's prospective views regarding commercial real estate market
value and cash flow declines.  Fitch foresees potential losses
could reach as high as 12.2% for this transaction should market
conditions not recover.  The rating actions are based on losses of
11.0%, including 100% of the term losses and 25% of the losses
anticipated to occur at maturity; the 11.0% recognizes all of the
losses anticipated in the next five years.

Given the significant remaining term to maturity, Fitch's actions
do not account for the full magnitude of possible maturity losses.
The bonds with Negative Outlooks indicate classes that may be
downgraded in the future should full potential losses be realized.

Fitch analyzed the transaction and calculated expected losses by
assuming cash flows on each of the properties decline 15% from
year-end (YE) 2007 and property values decline 35% from issuance.
These loss estimates were reviewed in more detail for certain
loans representing 62.6% of the pool and, in some cases, revised
based on additional information and/or property characteristics.

Approximately 30.4% of the mortgages mature within the next five
years: 1.4% in 2010, 9.8% in 2011, 15.9% in 2012, 0.0% in 2013,
and 3.3% in 2014.  All losses associated with these loans are
fully recognized in the rating actions.

Fitch identified 40 Loans of Concern (22.4%) within the pool, 15
of which (7.7%) are specially serviced.  Of the specially serviced
loans, two (0.4%) are current.  Of the current loans, Savannah
Trail Apartments is expected to be transferred back to the master
servicer.  Two (3.4%) of the specially serviced loans are within
the transaction's top 15 loans (51.8%) by unpaid principal
balance.

Six of the loans (13.4%) within the top 15 are expected to default
during the term, with loss severities ranging from 12% to 51%.
The largest contributors to loss are: Allanza at the Lakes (3.1%),
Commerce Corporate Plaza (3.1%), and Palmer Rochester Portfolio
(1.8%).

Allanza at the Lakes is a 896 unit multifamily property located in
Las Vegas, NV.  The property was undergoing interior renovations
at the time of securitization, with approximately 30 units down.
The property is currently behind its projected stabilization
projections at issuance, as cash flow and occupancy remain below
initial expectations due to deteriorating market conditions.  The
market is being affected by higher unemployment and the stock of
single family homes serving as rentals.  Current reserves include
approximately $3.8 million in renovation reserves.  The servicer
reported YE 2008 debt service coverage ratio and occupancy were
1.04 times (x) and 81.3%, respectively.  Based on current
performance and anticipated declines, losses are expected prior to
the loan's maturity in 2014.

Commerce Corporate Plaza is a 746,052 square foot office building
located in the Capital Hill district of Albany, NY only one block
from the state capitol.  The property is approximately 69% leased
to investment grade rated New York State-related tenants.  The
property was being repositioned from a Class B building to a Class
A building at issuance, and the sponsor had planned on spending up
to $13 million on renovations.  As of a January 2009 rent roll the
property was approximately 96% occupied.  Currently the reserve
accounts have these balances: Leasing Costs $885,000 and
$3.3 million in an earn-out.  The servicer reported YE 2008 DSCR
was 1.10x.  Based on current performance and anticipated declines,
losses are expected prior to the loan's maturity in 2014.

The Palmer Rochester Portfolio is a mixed use portfolio located
mainly in Rochester, NY.  The portfolio includes two multifamily
properties (568 units), two mixed use properties (396,000 sf) and
one industrial building (45,000 sf).  The current reserves include
approximately $128,115 in environmental, $165,756 in replacement
and $309,148 in rollover reserves.  The loan is currently in
special servicing.  As of the YE 2008, the servicer reported a
DSCR of 0.92x.  A foreclosure action was filed and a receiver was
appointed in June 2009.  Based on current performance and
anticipated declines, losses are expected prior to the loan's
maturity in 2017.

Fitch has downgraded, removed from Rating Watch Negative and
assigned Rating Outlooks to these classes:

  -- $198.0 million class A-M to 'AA' from 'AAA'; Outlook
     Negative;

  -- $74.1 million class A-1-AM to 'AA' from 'AAA'; Outlook
     Negative;

  -- $153.5 million class A-J to 'BB' from 'AAA'; Outlook
     Negative;

  -- $57.4 million class A-1-AJ to 'BB' from 'AAA'; Outlook
     Negative;

  -- $23.8 million class B to 'B' from 'AA+'; Outlook Negative;

  -- $20.4 million class C to 'B' from 'AA'; Outlook Negative;

  -- $34.0 million class D to 'B-' from 'AA-'; Outlook Negative;

  -- $30.6 million class E to 'B-' from 'A+'; Outlook Negative;

  -- $13.6 million class F to 'B-' from 'A'; Outlook Negative;

  -- $40.8 million class G to 'B-' from 'A-'; Outlook Negative;

  -- $20.4 million class H to 'B-' from 'BBB+'; Outlook Negative;

  -- $30.6 million class J to 'B-' from 'BBB'; Outlook Negative;

  -- $23.8 million class K to 'B-' from 'BB'; Outlook Negative;

  -- $10.2 million class L to 'CCC/RR6' from 'B+';

  -- $10.2 million class M to 'CCC/RR6' from 'B';

  -- $10.2 million class N to 'CCC/RR6' from 'B-'.

Additionally, Fitch has affirmed these classes and Rating Outlooks
as indicated:

  -- $25.7 million class A-1 at 'AAA'; Outlook Stable;
  -- $315.0 billion class A-2 at 'AAA'; Outlook Stable;
  -- $161.0 million class A-3 at 'AAA'; Outlook Stable;
  -- $65.1 million class A-AB at 'AAA'; Outlook Stable;
  -- $982.5 billion class A-4 at 'AAA'; Outlook Stable;
  -- $347.2 million class A-1A at 'AAA'; Outlook Stable;
  -- Interest-only class A-SP at 'AAA'; Outlook Stable;
  -- Interest-only class A-X at 'AAA'; Outlook Stable;

Fitch does not rate these classes:

  -- $17.0 million class O;
  -- $3.4 million class P;
  -- $10.2 million class Q;
  -- $34.0 million class S;


CREDIT SUISSE: Fitch Takes Rating Actions on 2008-C1 Certs.
-----------------------------------------------------------
Fitch Ratings downgrades 15 classes, removes 16 classes from
Rating Watch Negative and assigns Rating Outlooks for Credit
Suisse Commercial Mortgage Trust, Series 2008-C1 commercial
mortgage pass-through certificates.  A detailed list of rating
actions follows at the end of this press release.

The downgrades are the result of loss expectations and reflect
Fitch's prospective views regarding commercial real estate market
value and cash flow declines.  Fitch forecasts potential losses of
9.9% for this transaction, should market conditions not recover.
The rating actions are based on losses of 6.8% including 100% of
the losses associated with term defaults and any losses associated
with maturities within the next five years.  Given the significant
term to maturity, Fitch's actions only account for 25% of the
losses associated with maturities beyond five years.  The bonds
with Negative Outlooks indicate classes that may be downgraded in
the future should full potential losses be realized.

Fitch analyzed the transaction and calculated expected losses by
assuming cash flows on each of the properties decline 15% from
year-end (YE) 2007 and property values decline 35% from issuance.
These loss estimates were reviewed in more detail for loans
representing 78.3% of the pool and, in certain cases, revised
based on additional information and/or property characteristics.

Approximately 26.9% of the mortgages are scheduled to mature
within the next five years, with all occurring in 2012.  In 2017,
50.7% of the pool is scheduled to mature.

Fitch identified 19 Loans of Concern (31.5%) within the pool, two
of which (1.0%) are specially serviced.  None of the specially
serviced loans are within the transaction's top 15 loans (75.6%)
by unpaid principal balance and one of the loans is current
(0.5%).  Four of the Fitch Loans of Concern (23.1%) are within the
transaction's top 15 loans.

Ten of the top 15 loans (49.6%) are expected to default and incur
losses during the term or at maturity, with loss severities
ranging from approximately 0.2% to 43%.  The largest contributors
to term losses by balance are: 1100 Executive Tower (10.2% of the
pool) and Radisson Hotel Dallas North (1.9%).  The two loans are
considered Fitch Loans of Concern.

1100 Executive Tower is a 372,814 square foot (sf) office property
located in Orange, CA.  At issuance, the loan was underwritten to
a stabilized cash flow based on the expectation that below-market
leases expiring during the term of the loan would be re-signed at
higher rates, providing for potential upside in future cash flows.
Based on March 2009 servicer reported financials, the property is
behind the stabilization schedule.  In 2010, 58.5% of subject's
leases expire.  In 2010, 58.5% of subject's leases, with an
average rent per square foot of $23.35, will expire.
Comparatively, the current submarket average is $19.09 psf per
Property and Portfolio Research.  The servicer reported a combined
March 2009 debt service coverage ratio and occupancy were 0.88
times (x) and 70.3%, respectively.  At issuance, occupancy at the
property was 85.0%.  The loan sponsor is Rockwood VII REIT, Inc.
and The Muller Company.  Based on current performance and
anticipated declines, losses are expected prior to the loan's
maturity in 2012.

Radisson Hotel Dallas North is secured by 294 room hotel in
Richardson, TX.  Since origination, revenue per available room has
decreased to $43.82 from $58.81.  Net operating income has also
declined 44.3% since issuance, driving DSCR to 0.90x from 1.61x.
The sponsor of the loan is the Alireza Mourirahimi and Parvin
Mosavi.  Based on current performance and further anticipated
declines, losses are expected prior to the loan's maturity in
2013.

The Fitch Loan of Concern with the largest expected loss at
maturity is Killeen Mall (9.3% of the deal), which is secured by a
386,759 sf retail mall located in Killeen, TX.  As of March 2009,
the servicer reported DSCR was 1.25x.  Occupancy has declined to
68.9% as of March 2009 from 92.4% at issuance.  The decline in
occupancy resulted from Steve & Barry's vacating their space (15%
of the net rentable area) due to corporate bankruptcy.  The
sponsor of this loan is Babcock & Brown Real Estate Holdings Inc.

Fitch downgrades and removes from Rating Watch Negative these
classes:

  -- $57.7 million class A-J to 'A' from 'AAA'; Outlook Negative;
  -- $8.9 million class B to 'BBB' from 'AA+'; Outlook Negative;
  -- $8.9 million class C to 'BBB-' from 'AA'; Outlook Negative;
  -- $12.2 million class D to 'BB' from 'AA-'; Outlook Negative;
  -- $10 million class E to 'BB' from 'A+'; Outlook Negative;
  -- $6.7 million class F to 'BB' from 'A'; Outlook Negative;
  -- $8.9 million class G to 'B' from 'A-'; Outlook Negative;
  -- $14.4 million class H to 'B-' from 'BBB+'; Outlook Negative;
  -- $6.7 million class J to 'B-' from 'BBB'; Outlook Negative;
  -- $10 million class K to 'B-' from 'BBB-'; Outlook Negative;
  -- $3.3 million class L to 'B-' from 'BB+'; Outlook Negative;
  -- $3.3 million class M to 'B-' from 'BB'; Outlook Negative;
  -- $3.3 million class N to 'B-' from 'BB-'; Outlook Negative;
  -- $1.1 million class O to 'B-' from 'B+'; Outlook Negative;
  -- $2.2 million class P to 'B-' from 'B'; Outlook Negative;

Fitch has affirmed this class and removed it from Rating Watch
Negative as indicated:

  -- $2.2 million class Q at 'B-'; Outlook Negative.

Additionally, Fitch affirms these classes:

  -- $8.3 million class A-1 at 'AAA'; Outlook Stable;
  -- $150.5 million class A-2 at 'AAA'; Outlook Stable;
  -- $22.3 million class A-AB at 'AAA'; Outlook Stable;
  -- $258 million class A-3 at 'AAA'; Outlook Stable;
  -- $98.9 million class A-1-A at 'AAA'; Outlook Stable;
  -- $367.4 million class A-1A at 'AAA'; Outlook Stable;
  -- $78.5 million class A-2FL at 'AAA'; Outlook Stable;
  -- $88.7 million class A-M at 'AAA'; Outlook Stable;
  -- Interest-only class A-X at 'AAA'; Outlook Stable.

Fitch does not rate the $16.7 million class S.


CREDIT SUISSE: Moody's Takes Rating Actions on 2007-C1 Certs.
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings of seven classes,
confirmed two classes and downgraded 17 classes of Credit Suisse
Commercial Mortgage Trust Commercial Mortgage Pass-Through
Certificates, Series 2007-C1.  The downgrades are due to interest
shortfalls and significantly higher expected losses for the pool
resulting from anticipated losses from loans in special servicing.
The A-M and A-MFL classes were confirmed based on the existing key
parameters for the deal and the current estimated losses for the
loans in special servicing.  However, if Moody's estimated losses
from loans in special servicing were to increase by an additional
$75 million, the A-M and A-MFL classes would likely be downgraded
by one to three notches.  On June 25, 2009, Moody's placed 19
classes on review for possible downgrade due to an increase in the
concentration of specially serviced loans.  This action concludes
the review.

As of the July 17, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 1% to
$3.35 billion from $3.37 billion at securitization.  The
Certificates are collateralized by 257 mortgage loans ranging in
size from less than 1% to 6% of the pool, with the top 10 loans
representing 37% of the pool.

Seventy-five loans, representing 37% of the pool, are on the
master servicer's watchlist, including five of the top ten loans
in the pool.  The watchlist includes loans which meet certain
portfolio review guidelines established as part of the Commercial
Mortgage Securities Association's monthly reporting package.  As
part of Moody's ongoing monitoring of a transaction, Moody's
reviews the watchlist to assess which loans have material issues
that could impact performance.

The pool has not experienced any losses since securitization.
Currently there are eighteen loans, representing 15% of the pool,
in special servicing.  The largest specially serviced loan is the
CVI Multifamily Apartment Portfolio Loan ($177.6 million -- 5.3%),
which is secured by 20 multifamily properties totaling 2,990
units.  The properties are located in seven markets, with the
largest concentrations in Austin, Texas and Sacramento,
California.  The loan was transferred to special servicing on
April 17, 2009, due to imminent default.  The portfolio was 88%
occupied as of December 2008 compared to 93% at securitization.
The original analysis was predicated on the borrower increasing
rents based on a comprehensive renovation program and decreasing
expenses due to improved centralized management of the portfolio.
The borrower has not been able to achieve the upside they
originally expected.  The borrower has depleted the entire
interest reserve ($18 million at securitization) and the loan is
currently less than 30 days delinquent.

The second largest specially serviced loan is the Mansions
Portfolio Loan ($160.0 million -- 4.8%), which is secured by four
multifamily properties totaling 1,417 units located in Austin and
Round Rock, Texas.  The loan was transferred to special servicing
on March 6, 2009 for imminent default.  The portfolio was 92%
occupied as of June 2009 compared to 95% at securitization.
Although occupancy has been relatively stable, financial
performance has been negatively impacted by increased rental
concessions due to Austin's weak multifamily market.  The loan is
currently 90+ days delinquent.  The remaining 16 specially
serviced loans are mostly 90+ days delinquent.  Moody's estimates
an aggregate loss of $207 million (41% severity on average) for
the specially serviced loans.

As of the most recent remittance date, the transaction has
experienced unpaid accumulated interest shortfalls totaling
$2.0 million affecting Classes M through T.  Interest shortfalls
are caused by special servicing fees, appraisal reductions and
extraordinary trust expenses.  Appraisal reductions totaling
$46.2 million have been recognized for 11 of the specially
serviced loans.  Moody's anticipates that interest shortfalls will
increase when appraisals are obtained for the two largest
specially serviced loans.

Moody's was provided with full-year 2008 operating results for 91%
of the pool.  Moody's weighted average loan to value ratio is 132%
compared to 148% at Moody's last review in February 2009.  Moody's
stressed debt service coverage ratio is 0.84X compared to 0.74X at
last review.  Moody's stressed DSCR is based on Moody's net cash
flow and a 9.25% stressed rate applied to the loan balance.

Moody's uses a variation of the Herfindahl index to measure
diversity of loan size, where a higher number represents greater
diversity.  Loan concentration has an important bearing on
potential rating volatility, including the risk of multiple-notch
downgrades under adverse circumstances.  The credit neutral Herf
score is 40 and the pool has a Herf score of 52.

The top three performing loans represent 14% of the pool.  The
largest loan is the Savoy Park Loan ($210.0 million -- 6.3%),
which is secured by seven adjacent apartment buildings totaling
1,802 units in Harlem, New York.  There is also $157.5 million of
mezzanine debt held outside the trust.  At securitization, the
borrower's plan was to increase value through renovations and the
deregulation of rent-stabilized units, which was expected to
increase rental income.  However, a slower than anticipated pace
of conversion and deterioration in market fundamentals have
challenged the borrower's original plan.  As of June 2009, 88% of
the units were rent stabilized compared to 91% at securitization.
As of July 2009, the remaining interest reserve was approximately
$2 million, down from $30 million at securitization.  The most
recent DSCR based on first quarter 2009 annualized net operating
income is 0.79X.  The loan is on the master servicer's watchlist
due to low DSCR.  Moody's expects that this loan will ultimately
be transferred to special servicing but Moody's are uncertain as
to when this might happen.  Moody's LTV and stressed DSCR are 155%
and 0.66X, respectively, compared to 140% and 0.77X at last
review.

The second largest loan is the City Place Loan ($145.1 million --
4.3%), which is secured by a mixed use property consisting of open
air retail (626,000 square feet), office (73,000 square feet),
multifamily (54 units), and a theater (50,000 square feet).  The
overall occupancy as of March 2009 was 86% compared to 95% at
securitization.  In addition to the decline in occupancy,
operating expenses have increased approximately 25% from 2007 to
2008.  The loan is on the master servicer's watchlist due to a
decrease in DSCR.  Moody's LTV and stressed DSCR are 198% and
0.52X, respectively, compared to 121% and 0.85X at last review.

The third largest loan is the Koger Center Loan ($115.5 million --
3.4%), which is secured by an 850,000 square foot office complex
in Tallahassee, Florida.  The largest tenant is the State of
Florida, occupying 68% of the net rentable area ("NRA") through
October 2019.  Although the property was fully occupied as of
March 2009, operating expenses are up 9% from 2007 to 2008.  The
loan is on the master servicer's watchlist due to low DSCR.
Moody's LTV and stressed DSCR are 153% and 0.67X, respectively,
compared to 140% and 0.73X at last review.

Moody's rating action is:

  -- Class A-1, $23,930,203, affirmed at Aaa; previously affirmed
     at Aaa on 2/6/2009

  -- Class A-2, $139,000,000, affirmed at Aaa; previously affirmed
     at Aaa on 2/6/2009

  -- Class A-AB, $98,301,000, affirmed at Aaa; previously affirmed
     at Aaa on 2/6/2009

  -- Class A-3, $758,000,000, affirmed at Aaa; previously affirmed
     at Aaa on 2/6/2009

  -- Class A-1-A, $1,320,717,691, affirmed at Aaa; previously
     affirmed at Aaa on 2/6/2009

  -- Class A-X, Notional, affirmed at Aaa; previously affirmed at
     Aaa on 2/6/2009

  -- Class A-SP, Notional, affirmed at Aaa; previously affirmed at
     Aaa on 2/6/2009

  -- Class A-M, $212,148,000, confirmed at Aaa; previously placed
     on review for possible downgrade on 6/25/2009

  -- Class A-MFL, $125,000,000, confirmed at Aaa; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class A-J, $286,576,000, downgraded to A3 from A2; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class B, $25,286,000, downgraded to Baa1 from A3; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class C, $37,929,000, downgraded to Baa2 from Baa1;
     previously placed on review for possible downgrade 6/25/2009

  -- Class D, $33,715,000, downgraded to Baa3 from Baa2;
     previously placed on review for possible downgrade on
     6/25/2009

  -- Class E, $21,071,000, downgraded to Ba1 from Baa3; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class F, $29,501,000, downgraded to Ba2 from Ba1; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class G, $33,715,000, downgraded to B2 from Ba3; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class H, $37,929,000, downgraded to Caa1 from B2; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class J, $33,714,000, downgraded to Caa1 from B3; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class K, $37,930,000, downgraded to Caa2 from Caa1;
     previously placed on review for possible downgrade on
     6/25/2009

  -- Class L, $8,428,000, downgraded to Caa3 from Caa2; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class M, $12,643,000, downgraded to Ca from Caa2; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class N, $8,429,000, downgraded to Ca from Caa2; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class O, $8,429,000, downgraded to Ca from Caa3; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class P, $8,428,000, downgraded to Ca from Caa3; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class Q, $8,429,000, downgraded to C from Caa3; previously
     placed on review for possible downgrade on 6/25/2009

  -- Class S, $12,643,000, downgraded to C from Ca; previously
     placed on review for possible downgrade on 6/25/2009


CREDIT SUISSE: S&P Downgrades Ratings on Two 2005-TFL3 Certs.
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class K and L commercial mortgage pass-through certificates from
Credit Suisse First Boston Mortgage Securities Corp.'s series
2005-TFL3.  Concurrently, S&P affirmed its ratings on two other
classes and removed all four ratings from CreditWatch with
negative implications, where they were placed April 7, 2009.

The lowered and affirmed ratings reflect S&P's revaluation of the
remaining loan, which considered actual and potential property
performance declines as well as concerns regarding the borrower's
ability to refinance the loan by its July 2010 final maturity.

As of the July 2009 remittance report, the Sir Francis Drake loan
was the only remaining loan in the pool, with a trust balance of
$37.4 million.  The whole-loan balance is $68.5 million, which
consists of a $37.4 million senior participation and a
$31.1 million junior participation held outside the trust.  The
loan is secured by a 417-room full-service hotel in San Francisco,
which underwent renovations that were substantially completed in
March 2007.  While the hotel initially exhibited improved
operating performance following the completion of the renovations,
performance has since declined based on the borrower's operating
statements for the trailing 12 months ended May 31, 2009.  Based
on this information and the borrower's 2009 budget, Standard &
Poor's derived an adjusted valuation that is 38% below S&P's value
at issuance.  The decline in S&P's adjusted valuation is due
primarily to lower actual and expected revenues.  S&P's analysis
factored in its expectation that average 2009 revenue per
available room in the lodging industry would decline between 14%
and 16%, as S&P noted in a recent article.

Additionally, the loan matures on July 9, 2010, its final maturity
date, following its recent final extension.  If the borrower is
unable to pay off the loan, an event of default will occur, which
will trigger the master servicer to transfer the loan to the
special servicer, Wachovia Bank N.A.  Wachovia has indicated that
any special servicing and/or workout fees related to this loan
will be absorbed by the subordinate junior participation first.
S&P will continue to monitor this situation and will take rating
actions as warranted.

      Ratings Lowered And Removed From Creditwatch Negative

       Credit Suisse First Boston Mortgage Securities Corp.
  Commercial mortgage pass-through certificates series 2005-TFL3

                            Rating
                            ------
                  Class   To       From
                  -----   --       ----
                  K       BB+      BBB/Watch Neg
                  L       B+       BBB-/Watch Neg

     Ratings Affirmed And Removed From Creditwatch Negative

      Credit Suisse First Boston Mortgage Securities Corp.
  Commercial mortgage pass-through certificates series 2005-TFL3

                            Rating
                            ------
                  Class   To       From
                  -----   --       ----
                  J       A        A/Watch Neg
                  A-X-1   AAA      AAA/Watch Neg


E*TRADE ABS: Moody's Downgrades Ratings on Class A-2 to 'Ba1'
-------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of one class of notes issued by E*Trade ABS CDO I, Ltd.
The note affected by the rating action is:

* Class A-2 Second Priority Senior Secured Floating Rate Notes,
  Downgraded to Ba1; previously on 2/26/2009 Downgraded to Baa3

E*Trade ABS CDO I, Ltd., is a collateralized debt obligation
backed primarily by a portfolio of residential mortgage backed
securities and other types of assets backed securities.

The rating downgrade actions reflect the continuous deterioration
in the credit quality of the underlying portfolio.  Since Moody's
last review in February the Class A/B OC ratio has fallen from
87.49% to 79.52% and defaulted assets in the portfolio have
increased from $4.3 million to $7.1 million.

The action takes into consideration the occurrence on
September 20, 2004, as reported by the Trustee, of an Event of
Default described in Section 5.1(i) of the Indenture dated
September 26, 2002.  Net Outstanding Portfolio Collateral Balance
fell below the Aggregate Principal Balance of the Notes, resulting
in an Event of Default.  As provided in Article V of the Indenture
during the occurrence and continuance of an Event of Default,
certain parties to the transaction may be entitled to direct the
Trustee to take particular actions with respect to the Collateral
and the Notes, including the sale and liquidation of the assets.
The severity of losses of certain tranches may be different
depending on the timing and outcome of a liquidation.

Moody's explained that in addition to the quantitative factors
that are explicitly modeled, qualitative factors are part of the
Moody's rating committee considerations.  These qualitative
factors include but are not limited to the structural protections
in the transaction, the recent performance of the transaction in
the current market environment, how legal risks and issues are
addressed in transaction documentation, the collateral manager's
track record, and the potential for selection bias in the
portfolio.  All information available to rating committees,
including macroeconomic forecasts, input from other Moody's
analytical groups, market factors, and judgments regarding the
nature and severity of credit stress on the transactions, may
influence the final rating decision


EDINVEST COMPANY: Fitch Maintains Ratings on Student Loans
----------------------------------------------------------
Fitch Ratings currently maintains ratings on student loan asset-
backed securities issued by EdInvest Company under an Amended and
Restated Indenture dated as of June 1, 2006, between EDI and U.S.
Bank National Association, as Trustee and Eligible Lender Trustee.
EDI has requested that Fitch confirm its existing ratings on the
securities issued under the Indenture upon the adoption and
effectiveness of a supplemental indenture (the Supplement).
Consistent with its statements on policies regarding rating
confirmations in structured finance transactions (Jan. 13, 2009)
and student loan confirms (May 8, 2009), Fitch is treating this
request as a notification.

The Supplement allows EDI to purchase outstanding auction rate
securities issued under the Indenture at a price less than par
which includes the remaining principal balance plus 100% of the
accrued and unpaid interest.  Funds deposited into the principal
distribution fund held under the Indenture, which are currently
used to pay down securities at par plus accrued interest, would
become available at the direction of EDI to purchase securities
from investors, who voluntarily elect to sell their securities at
a discount.  Any securities so purchased by EDI would be
immediately tendered to the Trustee for cancellation.  Based on
the information provided, Fitch has determined that the execution
and delivery of the Supplement and the changes to the Indenture
contained in the Supplement will not have an impact on the
existing ratings on the securities issued under the Indenture.
This determination only addresses the effect of the Supplement and
its changes on the current ratings assigned by Fitch to the
securities issued under the Indenture.  It does not address
whether this change is permitted by the terms of the documents nor
does it address whether it is in the best interests of, or
prejudicial to, some or all of the holders of the securities
listed.

Based on the trust estate's balance sheet as of March 31, 2009,
investors who choose to sell their securities at a discount may
positively increase the senior and total parity ratios of the
trust estate.  The subordination level for the senior securities
would increase as well.  In addition, the composition of the loan
pool held under the Indenture and the weighted average coupon rate
of the securities are not expected to change materially.

The ratings assigned by Fitch are based on the documents and
information provided to Fitch by EDI and other parties and the
receipt of final closing documents.  Fitch relies on all these
parties for the accuracy of such information and documents. Fitch
did not audit or verify the truth or accuracy of such information.

The student loan asset-backed securities, which include auction
rate securities issued under the Indenture by EDI, are currently
rated by Fitch:

EdInvest Company (2003 Indenture)

  -- $53,000,000 senior series 2004 A-1 notes 'AAA';
  -- $98,300,000 senior series 2005 A-1 notes 'AAA';
  -- $57,000,000 senior series 2006 A-1 notes 'AAA';
  -- $17,300,000 subordinate series 2003 B-1 notes 'B';
  -- $11,000,000 subordinate series 2004 B-1 notes 'B';
  -- $13,500,000 subordinate series 2005 B-1 notes 'B'.


EDUCATIONAL FUNDING: Fitch Keeps Ratings on Various Student Loans
-----------------------------------------------------------------
Fitch Ratings currently maintains ratings on student loan asset-
backed securities issued by Educational Funding Services, Inc.,
under an Indenture of Trust, dated as of September 1, 2005,
between EFSI and U.S. Bank National Association, as Trustee and
Eligible Lender Trustee.  EFSI has requested that Fitch confirm
its existing ratings on the securities issued under the Indenture
upon the adoption and effectiveness of a supplemental indenture.
Consistent with its statements on policies regarding rating
confirmations in structured finance transactions (January 13,
2009) and student loan confirms (May 8, 2009), Fitch is treating
this request as a notification.

The Supplement allows EFSI to purchase outstanding auction-rate
securities issued under the Indenture at a price less than par
which includes the remaining principal balance plus 100% of the
accrued and unpaid interest.  Funds deposited into the note
redemption fund held under the Indenture, which are currently used
to pay down securities at par plus accrued interest, would become
available at the direction of EFSI to purchase securities from
investors, who voluntarily elect to sell their securities at a
discount.  Any securities so purchased by EFSI would be
immediately tendered to the Trustee for cancellation.  Based on
the information provided, Fitch has determined that the execution
and delivery of the Supplement and the changes to the Indenture
contained in the Supplement will not have an impact on the
existing ratings on the securities issued under the Indenture.
This determination only addresses the effect of the Supplement and
its changes on the current ratings assigned by Fitch to the
securities issued under the Indenture.  It does not address
whether this change is permitted by the terms of the documents nor
does it address whether it is in the best interests of, or
prejudicial to, some or all of the holders of the securities
listed.

Based on the trust estate's balance sheet as of March 31, 2009,
investors who choose to sell their securities at a discount may
positively increase the senior and total parity ratios of the
trust estate.  The subordination level for the senior securities
would increase as well.  In addition, the composition of the loan
pool held under the Indenture and the weighted average coupon rate
of the securities are not expected to change materially.

The ratings assigned by Fitch are based on the documents and
information provided to Fitch by EFSI and other parties and the
receipt of final closing documents.  Fitch relies on all these
parties for the accuracy of such information and documents.  Fitch
did not audit or verify the truth or accuracy of such information.

The student loan asset-backed securities, which include auction-
rate securities issued under the Indenture by EFSI, are currently
rated by Fitch:

Educational Funding Services Inc. (2005 Indenture)

  -- $48,600,000 senior series 2005 A-2 notes 'AAA';
  -- $30,450,000 senior series 2005 A-3 notes 'AAA';
  -- $16,100,000 senior series 2006 A-1 notes 'AAA';
  -- $65,000,000 senior series 2006 A-2 notes 'AAA';
  -- $10,000,000 senior series 2006 A-3 notes 'AAA';
  -- $82,800,000 senior series 2007 A-1 notes 'AAA';
  -- $30,000,000 subordinate series 2007B-1 notes 'B'.


EDUCATIONAL FUNDING: Fitch Maintains Ratings on Student Loans
-------------------------------------------------------------
Fitch Ratings currently maintains ratings on student loan asset-
backed securities issued by Educational Funding Services, Inc.,
under an Amended and Restated Indenture, dated as of June 1, 2006,
between EFSI and U.S. Bank National Association, as Trustee and
Eligible Lender Trustee.  EFSI has requested that Fitch confirm
its existing ratings on the securities issued under the Indenture
upon the adoption and effectiveness of a supplemental indenture.
Consistent with its statements on policies regarding rating
confirmations in structured finance transactions (January 13,
2009) and student loan confirms (May 8, 2009), Fitch is treating
this request as a notification.

The Supplement allows EFSI to purchase outstanding auction rate
securities issued under the Indenture at a price less than par
which includes the remaining principal balance plus 100% of the
accrued and unpaid interest.  Funds deposited into the note
redemption fund held under the Indenture, which are currently used
to pay down securities at par plus accrued interest, would become
available at the direction of EFSI to purchase securities from
investors, who voluntarily elect to sell their securities at a
discount.  Any securities so purchased by EFSI would be
immediately tendered to the Trustee for cancellation.  Based on
the information provided, Fitch has determined that the execution
and delivery of the Supplement and the changes to the Indenture
contained in the Supplement will not have an impact on the
existing ratings on the securities issued under the Indenture.
This determination only addresses the effect of the Supplement and
its changes on the current ratings assigned by Fitch to the
securities issued under the Indenture.  It does not address
whether this change is permitted by the terms of the documents nor
does it address whether it is in the best interests of, or
prejudicial to, some or all of the holders of the securities
listed.

Based on the trust estate's balance sheet as of March 31, 2009,
investors who choose to sell their securities at a discount may
positively increase the senior and total parity ratios of the
trust estate.  The subordination level for the senior securities
would increase as well.  In addition, the composition of the loan
pool held under the Indenture and the weighted average coupon rate
of the securities are not expected to change materially.

The ratings assigned by Fitch are based on the documents and
information provided to Fitch by EFSI and other parties and the
receipt of final closing documents.  Fitch relies on all these
parties for the accuracy of such information and documents. Fitch
did not audit or verify the truth or accuracy of such information.

The student loan asset-backed securities, which include auction
rate securities issued under the Indenture by EFSI, are currently
rated by Fitch:

Educational Funding Services Inc. (2003 Indenture)

  -- $32,400,000 senior series 2004 A-1 notes 'AAA';
  -- $54,000,000 senior series 2005 A-1 notes 'AAA';
  -- $54,000,000 senior series 2005 A-2 notes 'AAA';
  -- $54,000,000 senior series 2005 A-3 notes 'AAA';
  -- $56,800,000 senior series 2005 A-4 notes 'AAA';
  -- $41,800,000 senior series 2006 A-1 notes 'AAA';
  -- $39,700,000 subordinate series 2003B-1 notes 'BB';
  -- $ 6,000,000 subordinate series 2004B-1 notes 'BB';
  -- $41,500,000 subordinate series 2005B-1 notes 'BB'.


FEDERATED STUDENT: Fitch Maintains Ratings on Student Loan ABS
--------------------------------------------------------------
Fitch Ratings currently maintains ratings on student loan asset-
backed securities issued by Federated Student Finance Corporation
under an Amended and Restated Indenture, dated as of June 1, 2006,
between FSFC and U.S. Bank National Association, as Trustee and
Eligible Lender Trustee.  FSFC has requested that Fitch confirm
its existing ratings on the securities issued under the Indenture
upon the adoption and effectiveness of a supplemental indenture.
Consistent with its statements on policies regarding rating
confirmations in structured finance transactions (January 13,
2009) and student loan confirms (May 8, 2009), Fitch is treating
this request as a notification.

The Supplement allows FSFC to purchase outstanding auction-rate
securities issued under the Indenture at a price less than par
which includes the remaining principal balance plus 100% of the
accrued and unpaid interest.  Funds deposited into the note
redemption fund held under the Indenture, which are currently used
to pay down securities at par plus accrued interest, would become
available at the direction of FSFC to purchase securities from
investors, who voluntarily elect to sell their securities at a
discount.  Any securities so purchased by FSFC would be
immediately tendered to the Trustee for cancellation.  Based on
the information provided, Fitch has determined that the execution
and delivery of the Supplement and the changes to the Indenture
contained in the Supplement will not have an impact on the
existing ratings on the securities issued under the Indenture.
This determination only addresses the effect of the Supplement and
its changes on the current ratings assigned by Fitch to the
securities issued under the Indenture.  It does not address
whether this change is permitted by the terms of the documents nor
does it address whether it is in the best interests of, or
prejudicial to, some or all of the holders of the securities
listed.

Based on the trust estate's balance sheet as of March 31, 2009,
investors who choose to sell their securities at a discount may
positively increase the senior and total parity ratios of the
trust estate.  The subordination level for the senior securities
would increase as well.  In addition, the composition of the loan
pool held under the Indenture and the weighted average coupon rate
of the securities are not expected to change materially.


FIRST 2004-I: Moody's Downgrades Ratings on Two Classes of Notes
----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by First 2004-I CLO, Ltd.:

  -- US$13,000,000 Class A-2 Senior Secured Notes Due 2016
     Downgraded to A1; previously on March 4, 2009 Aa1 Placed
     Under Review for Possible Downgrade;

  -- US$245,000,000 Class A-3 Senior Secured Notes Due 2016,
     Downgraded to Aa2; previously on July 27, 2004 Assigned Aaa.

Additionally, Moody's has confirmed the ratings of these notes:

  -- US$40,000,000 Class B Senior Secured Interest Deferrable
     Notes Due 2016, Confirmed at Ba1; previously on March 18,
     2008 Downgraded to Ba1 and Placed Under Review for Possible
     Downgrade;

  -- US$15,000,000 Class C Senior Secured Interest Deferrable
     Notes Due 2016, Confirmed at B1; previously on March 18, 2008
     Downgraded to B1 and Placed Under Review for Possible
     Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries
will be below their historical averages, consistent with Moody's
research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, and increase in the proportion of securities
from issuers rated Caa1 and below.  The weighted average rating
factor has steadily increased over the last year and is currently
2919 versus a test level of 2905 as of the last trustee report,
dated July 16, 2009.  Based on the same report, defaulted
securities total about $24.7 million, accounting for roughly 5.43%
of the collateral balance, and securities rated Caa1 or lower make
up approximately 19.73% of the underlying portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

First 2004-I CLO, Ltd., issued in July 27, 2004, is a
collateralized loan obligation, backed primarily by a portfolio of
senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


FIRST 2004-II: Moody's Downgrades Ratings on Two Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by First 2004-II CLO, Ltd.:

  -- US$50,000,000 Class A-1 Senior Secured Delayed Drawdown Notes
     Due 2016 Downgraded to Aa2; previously on December 14, 2004
     Assigned Aaa;

  -- US$250,000,000 Class A-2 Senior Secured Notes Due 2016,
     Downgraded to Aa2; previously on December 14, 2004 Assigned
     Aaa.

Additionally, Moody's has confirmed the ratings of these notes:

  -- US$30,000,000 Class B Senior Secured Interest Deferrable
     Notes Due 2016, Confirmed at Ba1; previously on March 18,
     2009 Downgraded to Ba1 and Placed Under Review for Possible
     Downgrade;

  -- US$20,000,000 Class C Senior Secured Interest Deferrable
     Notes Due 2016, Confirmed at B1; previously on March 18, 2009
     Downgraded to B1 and Placed Under Review for Possible
     Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries
will be below their historical averages, consistent with Moody's
research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, and increase in the proportion of securities
from issuers rated Caa1 and below.  The weighted average rating
factor has steadily increased over the last year and is currently
2854 versus a test level of 2910 as of the last trustee report,
dated July 7, 2009.  Based on the same report, defaulted
securities total about $23.37 million, accounting for roughly
6.47% of the collateral balance, and securities rated Caa1 or
lower make up approximately 20.04% of the underlying portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

First 2004-II CLO, Ltd., issued in December 14, 2004, is a
collateralized loan obligation, backed primarily by a portfolio of
senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


FIRST DOMINION: Moody's Downgrades Ratings on Various Classes
-------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by First Dominion Funding III:

  -- $20,000,000 Class B-1 Fixed Rate Notes Due 2014, Downgraded
     to Baa2; previously on March 4, 2009 Aa2 Placed Under Review
     for Possible Downgrade;

  -- $47,500,000 Class B-2 Floating Rate Notes Due 2014,
     Downgraded to Baa2; previously on March 4, 2009 Aa2 Placed
     Under Review for Possible Downgrade;

  -- $26,250,000 Class C Floating Rate Notes, Downgraded to Caa3;
     previously on March 4, 2009 Baa2 Placed Under Review for
     Possible Downgrade;

  -- $7,000,000 Class D-1 Fixed Rate Notes Due 2014, Downgraded to
     C; previously on March 4, 2009 Caa1 Placed Under Review for
     Possible Downgrade;

  -- $14,250,000 Class D-2 Floating Rate Notes Due 2014,
     Downgraded to C; previously on March 4, 2009 Caa1 Placed
     Under Review for Possible Downgrade;

  -- $10,000,000 Class D-3 Fixed Rate Notes, Downgraded to C;
     previously on March 4, 2009 Caa1 Placed Under Review for
     Possible Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds and second lien loans will be below
their historical averages, consistent with Moody's research.
Moody's has also applied resecuritization stress factors to
default probability assumptions for structured finance asset
collateral as described in the press release titled "Moody's
updates its key assumptions for rating structured finance CDOs,"
published on December 11, 2008.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, an increase in the proportion of securities
from issuers rated Caa1 and below, and failure of the Class D Par
Value Test and the Class B, Class C, and Class D Interest Coverage
Tests.  The weighted average rating factor has steadily increased
over the last year and is currently 4041 versus a test level of
2228 as of the last trustee report, dated June 15, 2009.  Based on
the same report, defaulted securities total about $71.9 million,
accounting for roughly 42% of the collateral balance, and
securities rated Caa1 or lower make up approximately 42.4% of the
underlying portfolio.  Additionally, interest payments on the
Class C, Class D-1, Class D-2 and Class D-3 Notes are presently
being deferred as a result of the failure of the Class B Interest
Coverage Test.

Moody's also observes that the transaction is exposed to a
significant concentration of mezzanine and junior CLO tranches in
the underlying portfolio.  These CLO tranches are currently
assigned speculative-grade ratings after adjustment for on review
for possible downgrade status, and carry depressed market
valuations that may herald poor recovery prospects in the event of
default.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

First Dominion Funding III, issued in December 1999, is a
collateralized debt obligation backed primarily by a portfolio of
senior secured loans and senior unsecured bonds.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


FIRST NATIONAL: S&P Assigns Initial Ratings on $690.79 Mil. Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to First National Master Note Trust's $690.79 million
asset-backed notes series 2009-3.

The preliminary ratings are based on information as of August 6,
2009.  Subsequent information may result in the assignment of
final ratings that differ from the preliminary ratings.
The preliminary ratings are based on:

* S&P's view that the credit support for each class of notes is
  sufficient to withstand the simultaneous stresses S&P apply, for
  each rating category, to S&P's 8.5%-10.5% base case loss rate
  assumption, 12.0%-14.0% base case payment rate assumption, and
  14.0%-16.0% base case yield assumption.  In addition, S&P uses
  stressed purchase rate, excess spread, and note interest rate
  assumptions to determine if sufficient credit support is
  available for each rating category.  All of the stress
  assumptions outlined above are based on S&P's current criteria
  and assumptions;

* S&P's view of the credit risk inherent in the collateral loan
  pool, based on S&P's economic forecast, the trust portfolio's
  historical performance, the collateral characteristics, and
  vintage performance data;

* S&P's credit rating on First National Bank of Omaha (BBB-
  /Negative/--); its servicing experience; and S&P's opinion of
  the quality and consistency of its account origination,
  underwriting, account management, collections, and general
  operational practices;

* S&P's expectation of the timely payment of interest and ultimate
  payment of principal by July 15, 2015, the legal final maturity
  date, based on stressed cash flow modeling scenarios using
  assumptions commensurate with the respective preliminary rating
  categories; and

* The series 2009-3 notes' underlying payment structure and cash
  flow mechanics, and legal structure.

                   Preliminary Ratings Assigned

         First National Master Note Trust - Series 2009-3

       Class               Rating                Amount ($)
       -----               ------                ----------
       A                   AAA                  525,000,000
       B                   A                     98,438,000
       C                   BBB                   43,174,000
       D                   BB                    24,178,000


FRANKLIN AUTO: S&P Downgrades Ratings on Two Classes of Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class C notes issued by Franklin Auto Trust's series 2007-1 and
the class D notes issued by series 2008-A.  Concurrently, S&P
removed these ratings from CreditWatch, where they were placed
with negative implications on April 8, 2009.  At the same time,
S&P affirmed its ratings on the remaining nine classes from these
two series.

The rating actions reflect weaker-than-expected collateral
performance, as evidenced by high cumulative net losses and lower
recovery rates.  As a result, Standard & Poor's revised its loss
expectations in April 2009 for series 2007-1 to 7.50%-8.00%, up
from 7.0%-7.5%, and to 10.0%-10.5% for series 2008-A, up from
9.75%-10.25%.  At issuance, S&P's loss expectations for series
2007-1 and 2008-A were 3.65%-3.85% and 6.0%-6.2%, respectively.

As of the June 2009 performance month, series 2007-1 was 27 months
seasoned and had experienced cumulative net losses totaling 5.52%
of the original pool balance with a pool factor of 41.07%.  Series
2008-A was 14 months seasoned, had experienced cumulative net
losses totaling 3.92% of the original pool balance, and had a pool
factor of 65.99%.  In addition, loans that are 60-plus-days
delinquent equaled 1.82% for series 2007-1 and 1.87% for series
2008-A, each measured as a percent of the current pool balance.

                             Table 1

                     Collateral Performance (%)

                                              Former       Revised
                Pool    Current  60-plus day  lifetime     lifetime
  Series   Mo.  factor  CNL      delinq.      CNL(i) exp.  CNL exp.(ii)
  ------   ---  ------  -------  -----------  -----------  ------------
  2007-1   27   41.07   5.52     1.82         7.00-7.50    7.50-8.00
  2008-A   14   65.99   3.92     1.87         9.75-10.25   10.00-10.50

    (i) CNL-cumulative net loss.

    (ii) Revised CNL expectations based on current performance
         data.

The issuer initially structured each transaction with credit
enhancement consisting of subordination for the higher-rated
tranches, a letter of credit commitment, and a spread account.  As
provided by the transaction documents, the spread account can
build by trapping monthly excess spread, and, combined with the
LOC commitment, reach a specified combined credit enhancement
target as shown in table 2.  The spread account is subject to a
0.50% floor and the LOC is subject to a 1.00% floor for a combined
floor of 1.50% of the initial collateral balance.  Also, as
provided by the transaction documents, the structure can benefit
from a cumulative net loss trigger that prevents any step-down of
the spread account and LOC in the event that losses exceed
prescribed levels in any given month.  If cumulative net losses
fall below the trigger for one month, the transaction documents
allow the spread account and LOC to step down to their respective
targets or floors.  As of the June 2009 performance month, the
issuer had replaced the series 2008-A LOC with a cash funded
account, as permitted by the transaction documents, due to the
lowering of the short term ratings of the LOC provider.  Series
2007-1 and 2008-A have also triggered their cumulative net loss
provisions, preventing any step-down of their spread accounts and
LOC or cash funded accounts unless cured.  Series 2007-1 has
depleted its spread account and has been drawing on its LOC.  For
series 2008-A, the triggering of its net loss provision has
prevented it from stepping down its enhancement despite the
enhancement being higher than its target enhancement level,
although it has been drawing on its spread account.

                             Table 2

                   Spread Account And LOC Levels

                              Combined     Current    Current LOC/
         Initial              enhancement  spread     cash funded
         spread   Initial     target       account(i) account(ii)
         account  LOC         (% of        (% of      (% of
  Series deposit  commitment  current)     current)   current)
  ------ -------  ----------  -----------  ---------- ------------
2007-1   0.00     3.25         5.00        0.00       3.99
2008-A   2.25     5.75        10.25        3.06       8.71

     (i) Spread account (% of current) is subject to a floor
         of 0.50% of initial collateral balance.

     (ii) LOC/cash funded account (% of current) is subject
          to a floor of 1.00% of initial collateral balance.

S&P's analysis of these Franklin Auto Trust series incorporated
cash flow analysis, which took into account current and historical
transaction performance.  Consequently, S&P used voluntary
prepayments and losses reported by the trusts.  S&P's various cash
flow scenarios and sensitivity analysis included assumptions on
recoveries of 45% and monthly prepayment speeds ranging between
1.2 and 1.3 ABS (absolute prepayment speed).  Additionally, in
applying the losses, S&P used various loss timing curves,
including Franklin Auto Trust's historical gross and net loss
curves, to simulate the timing of future losses.  The results
demonstrated that there remained adequate coverage of remaining
losses at their respective rating levels for all classes of the
two transactions except for the class C tranche in 2007-1 and
class D tranche in 2008-A.

Sensitivity analysis run at the base-case level of losses also
showed that for the most subordinate tranches, total available
credit enhancement relative to remaining expected losses does not
grow as quickly, over time, as the higher rated tranches.  As a
result, credit support available for class C from series 2007-1
and class D from series 2008-A were not commensurate with their
initial ratings.

The affirmed ratings reflect S&P's view of the benefits of a
sequential principal payment structure and the growth in credit
support as a percent of the amortizing pool balance (see table 3).
The classes with affirmed ratings were able to withstand cash flow
stress scenarios at their respective rating levels despite S&P's
higher revised lifetime loss expectations.

                             Table 3

                        Hard Credit Support

                                                Current
                              Total hard        total hard
                   Pool       credit support    credit support(i)
   Series   Class  factor(%)  at issuance(i)    (% of current)
   ------   -----  ---------  ---------------   -----------------
   2007-1   A      41.07      14.25             30.77
   2007-1   B      41.07       7.75             14.95
   2007-1   C      41.07       3.25              3.99
   2008-A   A      65.99      26.77             40.22
   2008-A   B      65.99      24.01             36.03
   2008-A   C      65.99      16.68             24.30
   2008-A   D      65.99       8.00             11.77

     (i) Consists of spread account and LOC/cash funded account,
         as well as subordination for the higher rated tranches,
         and excludes excess spread that can also provide
         additional enhancement(as of the June 2009 performance
         period).

Standard & Poor's will continue to monitor the performance of each
transaction to ensure that the credit enhancement remains
sufficient, in S&P's view, to cover its revised cumulative net
loss expectations under S&P's stress scenarios for each of the
rated classes.

       Ratings Lowered And Removed From Creditwatch Negative

                       Franklin Auto Trust

                                  Rating
                                  ------
          Series   Class    To             From
          -----    -----    --             ----
          2007-1   C        BB+            BBB/Watch Neg
          2008-A   D        BBB-           BBB/Watch Neg

                         Ratings Affirmed

                       Franklin Auto Trust

                     Series   Class    Rating
                     ------   -----    ------
                     2007-1   A-3      AAA
                     2007-1   A-4      AAA
                     2007-1   B        A
                     2008-A   A-2      AAA
                     2008-A   A-3      AAA
                     2008-A   A-4a     AAA
                     2008-A   A-4b     AAA
                     2008-A   B        AA
                     2008-A   C        A


GE COMMERCIAL MORTGAGE: DBRS Downgrades Two Classes to C-
---------------------------------------------------------
DBRS has downgraded the ratings of two classes of GE Commercial
Mortgage Corporation Commercial Mortgage Pass-Through
Certificates, Series 2005-C1 as follows:

  -- Class N to C - Interest in Arrears from CCC
  -- Class O to C - Interest in Arrears from CCC

Both classes will continue to carry Negative trends.

The changes primarily reflect the $10.7 million appraisal
reduction taken on the eighth largest loan, Washington Mutual
Buildings (2.7% of the pool) along with the $3.5 million appraisal
reduction applied to Heritage on the River (0.9% of the pool).
This is resulting in interest shortfalls for the two-rated classes
being downgraded.  To the extent that the resolution of this loan
results in losses less than those anticipated by the appraisal
reduction, the interest shortfalls may be recoverable.

                           *     *     *

As reported in the Troubled Company Reporter on November 26, 2008,
Standard & Poor's Ratings Services raised its ratings on eight
classes of commercial mortgage pass-through certificates from GE
Commercial Mortgage Corp. Series 2003-C1.  Concurrently, S&P
affirmed its ratings on the remaining 11 classes.


GE COMMERCIAL: S&P Downgrades Ratings on 14 2005-C1 Securities
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 14
classes of commercial mortgage-backed securities from GE
Commercial Mortgage Corp.'s series 2005-C1 and removed them from
CreditWatch with negative implications.  In addition, S&P affirmed
its ratings on eight classes from the same transaction and removed
two of them from CreditWatch negative.

The downgrades follow S&P's analysis of the transaction using
S&P's recently released U.S. conduit and fusion CMBS criteria,
which was the primary driver of the rating actions.  S&P's
analysis included a review of the credit characteristics of all of
the loans in the pool.  Using servicer-provided financial
information, S&P calculated an adjusted debt service coverage of
1.58x and a loan-to-value ratio of 94.5%.  S&P further stressed
the loans' cash flows under S&P's 'AAA' scenario to yield a
weighted average DSC of 1.06x and an LTV of 120.7%.  The implied
defaults and loss severity under the 'AAA' scenario were 52.1% and
29.5%, respectively.  The DSC and LTV calculations exclude two
credit-impaired loans (3.6%).  S&P estimated losses for these
loans, which are included in the 'AAA' scenario implied default
and loss
figures.

S&P affirmed the ratings on the interest-only (IO) certificates
based on S&P's current criteria.  S&P published a request for
comment proposing changes to the IO criteria on June 1, 2009.
After S&P finalizes its criteria review, S&P may revise its
current criteria.  Any change in S&P's criteria may affect
outstanding ratings, including the ratings on the IO certificates
S&P affirmed.

                          Credit Concerns

Six assets ($237.5 million, 14.9%) in the pool, including three of
the top 10 loans, are with the special servicer, LNR Partners Inc.
The payment statuses of the loans are: two are more than 90 days
delinquent ($56.6 million, 3.6%), one is 30 days delinquent
($16.0 million, 1.0%), and three are current ($164.9 million,
10.4%).  Two of the specially serviced loans have appraisal
reduction amounts (ARAs) in effect totalling $14.2 million.  Three
of the specially serviced assets have balances that are greater
than 2.5% of the total pool balance, while the remaining specially
serviced loan has a balance that is less than 1.1% of the total
pool balance.  The top 10 loans with the special servicer are
discussed below.

                       Transaction Summary

As of the July 2009 remittance report, the collateral pool
consisted of 126 loans with an aggregate trust balance of
$1.59 billion, which represents approximately 95% of the trust
balance at issuance.  The master servicer for the transaction is
GEMSA Loan Services L.P.  Financial information was provided for
97.6% of the pool, and 88.9% of the financial information was
full-year 2008 data.  Eleven loans (11.0% of the pool) have been
defeased.  S&P calculated a weighted average DSC of 1.64x for the
pool based on the reported figures.  S&P's adjusted DSC and LTV
were 1.58x and 94.5%, respectively.  The transaction has not
experienced any principal losses to date.  Twenty loans (13.4%)
are on the master servicer's watchlist, including one of the top
10 loans.  Thirteen loans ($126.8 million, 8.0%) have a reported
DSC below 1.10x, and 10 of these loans ($99.7 million, 6.3%) have
a reported DSC of less than 1.0x.

                     Summary Of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$584.2 million (36.8%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC for the top 10 loans of 1.89x,
compared with 1.65x at issuance, excluding one credit-impaired
loan, the Washington Mutual Buildings loan, which is discussed
below.  The fourth-largest loan in the pool ($60.0 million, 3.8%)
appears on the master servicer's watchlist.  S&P's adjusted DSC
and LTV for the top 10 loans, excluding the credit-impaired loan,
were 1.74x and 88.4%, respectively.

The Lakeside Mall loan, the second-largest loan in pool, is the
largest loan with the special servicer.  This loan has a total
exposure of $90.2 million and is secured by 643,375 sq. ft. of a
1.5 million-sq.-ft. regional mall in Sterling Heights, Mich.  The
reported DSC for the property in 2008 was 1.62x, and the occupancy
was 92.5%.  The loan is current and was transferred to the special
servicer on April 29, 2009, due to General Growth Properties'
bankruptcy filing.  S&P continues to monitor the developments
relating to the GGP bankruptcy and will take rating actions as
necessary.

The Ward Centers loan is the fifth-largest loan in pool and is the
second-largest loan with the special servicer.  This loan has a
total exposure of $58.3 million and is secured by two neighboring
retail properties totalling 270,961 sq. ft. in Honolulu, Hawaii.
The reported DSC for the properties for the nine months ended
September 30, 2008, was 2.34x and the occupancy was 91.0%.  The
loan is current and was transferred to the special servicer on
April 24, 2009, due to GGP's bankruptcy filing.

The Washington Mutual Buildings loan is the eighth-largest loan in
pool and is the third-largest loan with the special servicer.
This loan has a total exposure of $44.6 million and is secured by
three office properties in Los Angeles, Calif., totalling 257,336
sq. ft.  The loan is over 90 days delinquent and was transferred
to the special servicer on March 19, 2009, due to monetary
default.  The reported DSC for the properties in 2008 was 2.09x
and the occupancy was 100%.  The properties were 100% leased to
Washington Mutual, but the borrower received formal notice of the
lease rejection by the FDIC after the bank's closure.  There is a
$10.7 million ARA in effect for this asset.  Standard & Poor's
expects a moderate loss upon the resolution of this asset.

Standard & Poor's stressed the loans in the pool according to
S&P's updated conduit/fusion criteria.  The resultant credit
enhancement levels support the lowered and affirmed ratings.

      Ratings Lowered And Removed From Creditwatch Negative

                   GE Commercial Mortgage Corp.
   Commercial mortgage pass-through certificates series 2005-C1

                 Rating
                 ------
      Class     To    From            Credit enhancement (%)
      -----     --    ----            ----------------------
      A-J       AA-   AAA/Watch Neg                   14.09
      B         A-    AA/Watch Neg                    11.46
      C         BBB+  AA-/Watch Neg                   10.40
      D         BBB-  A/Watch Neg                      8.69
      E         BB+   A-/Watch Neg                     7.77
      F         BB    BBB+/Watch Neg                   6.32
      G         BB-   BBB/Watch Neg                    5.40
      H         B+    BBB-/Watch Neg                   3.82
      J         B     BB+/Watch Neg                    3.56
      K         B-    BB/Watch Neg                     3.03
      L         B-    B+/Watch Neg                     2.37
      M         CCC+  B/Watch Neg                      2.24
      N         CCC   B-/Watch Neg                     1.84
      O         CCC-  CCC+/Watch Neg                   1.58

      Ratings Affirmed And Removed From Creditwatch Negative

                    GE Commercial Mortgage Corp.
   Commercial mortgage pass-through certificates series 2005-C1

                 Rating
                 ------
      Class     To    From            Credit enhancement (%)
      -----     --    ----            ----------------------
      A-5       AAA   AAA/Watch Neg                    21.07
      A-1A      AAA   AAA/Watch Neg                    21.07

                         Ratings Affirmed

                   GE Commercial Mortgage Corp.
   Commercial mortgage pass-through certificates series 2005-C1

            Class     Rating    Credit enhancement (%)
            -----     ------    ----------------------
            A-2       AAA                        21.07
            A-3       AAA                        21.07
            A-4       AAA                        21.07
            A-AB      AAA                        21.07
            X-C       AAA                          N/A
            X-P       AAA                          N/A

                       N/A - Not applicable.


GMAC COMMERCIAL: Fitch Takes Rating Actions on 14 2006-C1 Certs.
----------------------------------------------------------------
Fitch Ratings has downgraded, removed from Rating Watch Negative,
and assigned Rating Outlooks to 14 classes of commercial mortgage
pass-through certificates from GMAC Commercial Mortgage
Securities, Inc. series 2006-C1.  A detailed list of rating
actions follows at the end of this release.

The downgrades are the result of loss expectations and reflect
Fitch's prospective views regarding commercial real estate market
value and cash flow declines.  Fitch forecasts potential losses of
10.3% for this transaction, should market conditions not recover.
The rating actions are based on losses of 8.2%, including 100% of
the losses associated with term defaults and any losses associated
with maturities within the next five years.  Given the significant
term to maturity, Fitch's actions only account for 25% of the
losses associated with maturities beyond five years.  The bonds
with Negative Outlooks indicate classes that may be downgraded in
the future should full potential losses be realized.

Fitch analyzed the transaction and calculated expected losses by
assuming cash flows on each of the properties decline 15% from
year-end (YE) 2007 and property values decline 35% from issuance.
These loss estimates were reviewed in more detail for certain
loans representing 56.1% of the pool and, in some cases, revised
based on additional information and/or property characteristics.

Approximately 16.5% of the mortgages mature within the next five
years: 15.6% in 2010, 0.9% in 2012.  In 2015, 69.4% of the pool is
scheduled to mature.

Fitch identified 20 Loans of Concern (21.3%) within the pool,
seven of which (9.9%) are specially serviced.  Of the specially
serviced loans, four (7.2%) are current.  Two of the specially
serviced loans are within the transaction's top 15 loans (54.0%)
by unpaid principal balance.

Four of the Loans of Concern (16.6%) within the top 15 loans are
expected to default during the term, with loss severities ranging
from 3% to 53%.  The largest contributors to loss are:
DDR/Macquarie Mervyn's Portfolio (6.3%), Main Street Village
Apartments (1.57%), and Highline Club Apartments (0.9%).

The DDR/Macquarie Mervyn's Portfolio loan was originally
collateralized by 35 retail stores located in California, Nevada,
Arizona, and Texas of which 32 remain.  The collateral was
previously 100% leased by Mervyn's under 20-year leases; however,
the tenant subsequently filed for Chapter 11 bankruptcy relief,
rejected the leases and vacated each of the stores.  Two of the
stores have been leased, and three stores were sold to Kohl's in
February 2009.  The sale generated approximately $20 million pay
down to the floating-rate A3 note.  One store sale and two 50%
leases are pending.  Modification terms were negotiated by the
special servicer to provide for pending and future collateral
sales and reserves for future partial debt service.  Fitch losses
are based on recent appraised values.

The Main Street Village Apartments loan is collateralized by a 148
unit apartment complex located in Novi, MI.  The loan transferred
to the special servicer in March 2009 due to imminent default.
The economic downturn has put pressure on collections and
concessions at the property.  The sponsor has indicated that they
can no longer afford to advance funds to make the full debt
service payments, but continues to remit cash flow after operating
expenses.  The special servicer is in continuing negotiations with
the sponsor.  The servicer reported YE 2008 debt service coverage
ratio and occupancy were 0.93x and 86.5%, respectively.

The Highline Club Apartments loan is collateralized by a 160 unit
apartment complex located in Novi, MI.  The loan transferred to
the special servicer in December 2008 for imminent default.  The
initial three year interest-only period ended in November 2008.
Due to the deteriorating economic conditions in eastern Michigan,
the property has had to lower rents substantially in order to
maintain occupancy.  Currently, the special servicer is pursuing
foreclosure.  The servicer reported YE 2008 occupancy was 95.6%.
Fitch losses are based on a recent appraised value.

Classes FNB-1 through FNB-6 are secured by a $33 million non-
pooled B-note on the First National Bank Center.  The $65 million
A-note is a pooled component of the trust.  The property is a
547,785 square foot (sf) office property located in San Diego, CA.
Year-end 2006 occupancy was reported at 37.4% due to non-lease
renewals of several tenants, one of which was the largest tenant.
In early 2007, sponsorship changed and as of June 2009, occupancy
had increased to approximately 70%; however, the property's
occupancy has not managed to improve to the occupancy at issuance
of 86%.  6.8% of the net rentable area (NRA) expires throughout
the rest of 2009, 5.2% in 2010, 17% in 2011 and 2.2% in 2012.  The
YE 2008 servicer-reported DSCR was 1.11x.

Fitch has downgraded, removed from Rating Watch Negative and
assigned Rating Outlooks to these classes:

  -- $114.6 million class A-J to 'BBB' from 'AAA'; Outlook
     Negative;

  -- $36.1 million class B to 'BB' from 'AA'; Outlook Negative;

  -- $19.1 million class C to 'BB' from 'AA-'; Outlook Negative;

  -- $12.7 million class D to 'BB' from 'A+'; Outlook Negative;

  -- $21.2 million class E to 'B-' from 'A'; Outlook Negative;

  -- $17 million class F to 'B-' from 'A-'; Outlook Negative;

  -- $19.1 million class G to 'B-' from 'BBB+'; Outlook Negative;

  -- $19.1 million class H to 'CCC/RR6' from 'BBB';

  -- $23.3 million class J to 'CC/RR6' from 'BBB-';

  -- $6.4 million class K to 'CC/RR6' from 'BB+';

  -- $6.4 million class L to 'CC/RR6' from 'BB';

  -- $8.5 million class M to 'CC/RR6' from 'BB-';

  -- $2.1 million class N to 'CC/RR6' from 'B+'

  -- $4.2 million class O to 'CC/RR6' from 'B';

  -- $6.4 million class P to 'CC/RR6' from 'B-';

  -- $5,100,000 class FNB-1 from 'BBB-' to 'B'; Outlook Negative;

  -- $5,600,000 class FNB-2 from 'BB' to 'B'; Outlook Negative;

  -- $2,100,000 class FNB-3 from 'BB-' to 'CCC/RR1';

Fitch has also downgraded these classes:

  -- $4,500,000 class FNB-4 from 'B' to 'CCC/RR1';
  -- $2,400,000 class FNB-5 from 'B-' to 'CCC/RR1';
  -- $13,300,000 class FNB-6 from 'CCC' to 'CCC/RR1'.

Fitch has affirmed these classes and revised the Rating Outlooks
as indicated:

  -- $15.9 million class A-1 at 'AAA'; Outlook Stable;

  -- $6.5 million class A-1D at 'AAA'; Outlook Stable;

  -- $293.1 million class A-1A at 'AAA'; Outlook Stable;

  -- $166 million class A-2 at 'AAA'; Outlook Stable;

  -- $98 million class A-3 at 'AAA'; Outlook Stable;

  -- $576.1 million class A-4 at 'AAA'; Outlook Stable;

  -- Interest-only class XP at 'AAA'; Outlook Stable;

  -- $169.7 million class A-M at 'AAA'; Outlook to Negative from
     Stable;

  -- Interest-only class XC at 'AAA'; Outlook Stable;

Fitch does not rate the $23.3 million class Q.


GREENWICH CAPITAL: S&P Downgrades Ratings on Three 2005-FL3 Certs.
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on three
classes of commercial mortgage pass-through certificates from
Greenwich Capital Commercial Funding Corp.'s series 2005-FL3.
Concurrently, S&P affirmed its 'AAA' ratings on two other classes
from this series.  At the same time, S&P removed all five ratings
from CreditWatch with negative implications, where they were
placed April 7, 2009.

The lowered ratings follow S&P's analysis of the remaining loan in
the pool, the Lowell Hotel loan, which is secured by a 17-story,
70-room luxury hotel on the upper east side of Manhattan.  The
reduction in business and leisure travel has significantly
affected the lodging collateral performance.  S&P based its
analysis on a review of the borrower's operating statements for
the first five months of 2009, the 12 months ended December 31,
2008, and the borrower's 2009 budget.  S&P's adjusted valuation
has fallen 24% since S&P's last review, dated March 11, 2008.
S&P's analysis factored in its expectation that overall average
2009 revenue per available room in the lodging industry would
decline between 14% and 16%, as S&P noted in a recent article and
also considered conditions in the New York City lodging market.

According to Smith Travel, the New York City lodging market posted
a significant 33% decline in RevPAR in the first six months of
2009 compared with 2008, whereas the general U.S. hotel industry
reported a 19% decline in RevPAR.

As of the July 7, 2009, trustee remittance report, the Lowell
Hotel loan has a $60.0 million whole-loan balance that is split
into a $45.0 million in-trust senior participation interest and a
$15.0 million nontrust junior subordinate participation interest.
The senior participation interest is further divided into a
$30.0 million senior pooled component and a $15.0 million
subordinate nonpooled component that is raked to the 'LH'
certificates (not rated by Standard & Poor's).  The master
servicer, Wachovia Bank N.A., reported debt service coverage of
2.74x for the 12 months ended December 31, 2008, and 73% occupancy
as of May 2009.  The loan matures on September 1, 2009.  According
to Wachovia, the borrower plans to exercise its remaining one-year
extension option.  Wachovia indicated that if there are any
special servicing fees and/or workout fees, they will be absorbed
by the nontrust junior subordinate participation interest first.

      Ratings Lowered And Removed From Creditwatch Negative

             Greenwich Capital Commercial Funding Corp.
   Commercial mortgage pass-through certificates series 2005-FL3

                  Rating
                  ------
    Class       To       From            Credit enhancement (%)
    -----       --       ----            ----------------------
    K           AA+      AAA/Watch Neg                    57.78
    L           A        A+/Watch Neg                     40.72
    M           B+       BBB-/Watch Neg                     N/A

      Ratings Affirmed And Removed From Creditwatch Negative

             Greenwich Capital Commercial Funding Corp.
  Commercial mortgage pass-through certificates series 2005-FL3

                  Rating
                  ------
    Class       To       From            Credit enhancement (%)
    -----       --       ----            ----------------------
    H           AAA      AAA/Watch Neg                    93.20
    J           AAA      AAA/Watch Neg                    72.31

                       N/A - Not applicable.


HALCYON STRUCTURED: Moody's Downgrades Ratings on 2007-2 Notes
--------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Halcyon Structured Asset
Management Long Secured/Short Unsecured 2007-2 Ltd.:

  -- US$350,000,000 Class A-1a Senior Secured Floating Rate Notes
     Due 2021, Downgraded to Aa1; previously on September 27, 2007
     Assigned Aaa;

  -- US$22,750,000 Class A-1b Senior Secured Floating Rate Notes
     Due 2021, Downgraded to A1; previously on March 4, 2009 Aa1
     Placed Under Review for Possible Downgrade;

  -- US$30,000,000 Class A-2 Senior Secured Floating Rate Notes
     Due 2021, Downgraded to A3; previously on March 4, 2009 Aa2
     Placed Under Review for Possible Downgrade;

  -- US$24,000,000 Class C Secured Deferrable Floating Rate Notes
     Due 2021, Downgraded to B2; previously on March 17, 2009
     Downgraded to B1 and Placed Under Review for Possible
     Downgrade.

In addition, Moody's has confirmed the rating of these notes:

  -- US$28,250,000 Class B Senior Secured Deferrable Floating Rate
     Notes Due 2021, Confirmed at Ba1; previously on March 17,
     2009 Downgraded to Ba1 and Placed Under Review for Possible
     Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," the application
of certain stresses with respect to the default probabilities
associated with certain Moody's credit estimates, and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds and second lien loans will be below
their historical averages, consistent with Moody's research.

Credit deterioration of the collateral pool is observed through an
increase in the dollar amount of defaulted securities, an increase
in the proportion of securities from issuers rated Caa1 and below,
and failure of certain overcollateralization tests.  The amount of
defaulted securities has steadily increased over the last year and
is currently about $28 million, accounting for roughly 5.8% of the
collateral balance as of the last trustee report, dated June 15,
2009.  Based on the same report, securities rated Caa1/CCC+ or
lower make up approximately 15% of the underlying portfolio.
Additionally, interest payments on the Class B and C Notes are
presently being deferred as a result of a previous failure of the
Class A overcollateralization test and the current failure of the
Class B overcollateralization test.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Halcyon Structured Asset Management Long Secured/Short Unsecured
2007-2 Ltd., issued in August 2007, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


HALCYON STRUCTURED: Moody's Downgrades Ratings on Two Classes
-------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Halcyon Structured Asset
Management Long Secured/Short Unsecured 2007-1 Ltd.:

  -- US$35,000,000 Class A-2 Senior Secured Floating Rate Notes,
     Due 2021, Downgraded to Aa3; previously on March 4, 2009 Aa1
     Placed Under Review for Possible Downgrade;

  -- US$32,000,000 Class B Senior Secured Floating Rate Notes, Due
     2021, Downgraded to A3; previously on March 4, 2009 Aa2
     Placed Under Review for Possible Downgrade.

In addition, Moody's has confirmed the ratings of these notes:

  -- US$28,000,000 Class C Senior Secured Deferrable Floating Rate
     Notes, Due 2021, Confirmed at Baa3; previously on March 17,
     2009 Downgraded to Baa3 and Placed Under Review for Possible
     Downgrade;

  -- US$27,500,000 Class D Secured Deferrable Floating Rate Notes,
     Due 2021, Confirmed at Ba3; previously on March 17, 2009
     Downgraded to Ba3 and Placed Under Review for Possible
     Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," the application
of certain stresses with respect to the default probabilities
associated with certain Moody's credit estimates, and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds and second lien loans will be below
their historical averages, consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities and an increase in the proportion of
securities from issuers rated Caa1 and below.  The weighted
average rating factor has steadily increased over the last year
and is currently 2866 versus a test level of 2675 as of the last
trustee report, dated July 1, 2009.  Based on the same report,
defaulted securities total about $20.8 million, accounting for
roughly 4.6% of the collateral balance, and securities rated Caa1
or lower make up approximately 12% of the underlying portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Halcyon Structured Asset Management Long Secured/Short Unsecured
2007-1 Ltd., issued in July 2007, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


HOSPITAL AUTHORITY: Fitch Cuts Rating on $12.7 Mil. Bonds to 'BB-'
------------------------------------------------------------------
Fitch Ratings has downgraded the rating on approximately
$12.7 million outstanding Hospital Authority of the City of
Royston, GA's revenue anticipation certificates (Ty Cobb
Healthcare System, Inc. Project) series 1999 to 'BB-' from 'BB'.
The Rating Outlook is Stable.

The rating downgrade is based on Ty Cobb Healthcare System's (Ty
Cobb) worsened operating performance, weak debt service coverage,
and flat utilization trends.  Since Fitch's last review, Ty Cobb
recorded a $5 million loss in fiscal 2008 (negative 8.7% margin)
and has lost approximately $777,000 (negative 5% margin) through
three months ending March 31, 2009.  Fiscal 2008's operating
performance deteriorated significantly from the prior three fiscal
years, which is demonstrated by Ty Cobb's negative 0.9% operating
EBITDA margin in 2008 - the lowest since fiscal 2004.  Management
states that the operating losses observed in fiscal 2008 and 2009
are directly related to the poor performing economy in Hart and
Franklin counties.  Consequently, in fiscal 2008 Ty Cobb violated
its debt service coverage covenant as the system had 0.4 times (x)
coverage.  As a result from the coverage violation, Ty Cobb was
required to engage a management consultant, which has focused on
revenue-cycle enhancement.  Through the three-month interim
period, Ty Cobb had improved coverage of 2.2x.  Since fiscal 2007,
Ty Cobb has experienced flat inpatient utilization statistics,
while outpatient procedures have slightly declined.  For example,
inpatient admissions fell to 3,019 in 2008 from 3,120 in 2007,
while outpatient surgeries dropped to 1,328 in 2008 from 1,534 in
2007.

An ongoing credit concern is Ty Cobb's weak payor mix.  Located in
northeast Georgia and operating in Hart and Franklin counties, Ty
Cobb's two acute care facilities had a high percentage of gross
revenues coming from Medicaid in fiscal 2008, 14.6%.  Ty Cobb's
high Medicaid load exposes the organization to further revenue
pressure if reimbursement cuts are made at the state level.

Ty Cobb's primary credit strengths are the organization's
favorable liquidity position and strong market share.  In fiscal
2008, Ty Cobb had 152.8 days cash on hand ($22.7 million in
unrestricted cash), a cushion ratio of 12.0x, and cash to debt of
106.6%, which compare favorably for the rating category.  As of
March 31, 2009, Ty Cobb had approximately $24.5 million in
unrestricted cash and investments.  The organization maintains a
dominant inpatient market position of approximately 65%-68% in its
primary service area.  Additionally, management is beginning the
process of consolidating both hospital operations into one new
hospital.  On July 10, 2009, Ty Cobb's management team announced
plans to partner with physicians to build and operate a new 56-bed
hospital located in Lavonia, GA, which is approximately 15 miles
away from both of Ty Cobb's current locations.  The new hospital
will replace Ty Cobb's two current facilities, Cobb Memorial
Hospital and Hart County Hospital.  Management estimates that
there will be an approximate $5-$6 million positive impact to Ty
Cobb's operating income after the consolidation occurs.  Fitch
will continue to monitor Ty Cobb's consolidation plan as the
process moves forward.

The Stable Rating Outlook is based on the strength of Ty Cobb's
balance sheet metrics.  Additionally, over the medium term,
management expects hospital consolidation to occur, which will
ultimately improve bottom-line performance.  Negative rating
pressure may be warranted if the organization's balance sheet
declines, operational performance falls below management's
expectations of an approximate $1 million loss from operations,
and/or the organization fails to consolidate into one single
facility.

Ty Cobb Healthcare System consists of two hospitals (153 operated
beds) and three long-term care facilities (350 operated beds).
The two hospitals capture approximately 65%-68% of admissions in
the service area.  The system had $57.4 million in total operating
revenue in fiscal 2008.  While there is no covenant to do so in
their bond documents, management discloses to the Nationally
Recognized Municipal Securities Information Repositories quarterly
and annual audited financial information.


ING INVESTMENT: Moody's Downgrades Ratings on Two Classes of Notes
------------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by ING Investment Management CLO II,
Ltd.:

  -- US$76,250,000 Class A-2 Floating Rate Notes Due 2020,
     Downgraded to Aa2; previously on March 4, 2009 Aaa Placed
     Under Review for Possible Downgrade;

  -- US$25,000,000 Class B Floating Rate Notes Due 2020,
     Downgraded to A2; previously on March 4, 2009 Aa2 Placed
     Under Review for Possible Downgrade.

In addition, Moody's has confirmed the ratings of these notes:

  -- US$27,500,000 Class C Floating Rate Deferrable Notes Due
     2020, Confirmed at Ba1; previously on March 17, 2009
     Downgraded to Ba1 and Placed Under Review for Possible
     Downgrade;

  -- US$32,500,000 Class D Floating Rate Deferrable Notes Due
     2020, Confirmed at B1; previously on March 17, 2009
     Downgraded to B1 and Placed Under Review for Possible
     Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
second lien loans will be below their historical average,
consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, and an increase in the proportion of
securities from issuers rated Caa1 and below.  The weighted
average rating factor has increased over the last year and is
currently 2492 versus a test level of 2430 as of the last trustee
report, dated June 3, 2009.  Based on the same report, defaulted
securities total about $24.7 million, accounting for roughly 5% of
the collateral balance, and securities rated Caa1 or lower make up
approximately 13.6% of the underlying portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

ING Investment Management CLO II, Ltd., issued in August of 2006,
is a collateralized loan obligation backed primarily by a
portfolio of senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


JEFFERSON COUNTY: S&P Corrects Ratings on Revenue Bonds to 'C'
--------------------------------------------------------------
Standard & Poor's Ratings Services corrected its long-term ratings
on Jefferson County, Alabama's series 1997A, 2001A, 2003 B-1-A
through series 2003 B-1-E, and series 2003 C-1 through 2003 C-8
sewer system revenue bonds to 'C' from 'CCC/Negative' and placed
them on CreditWatch with negative implications to reflect the
sewer system revenue bonds' underlying rating.  While the bonds
are insured by Financial Guaranty Insurance Co. (not rated), on
April 22, 2009, S&P lowered and then withdrew S&P's rating on FGIC
and inadvertently did not change the long-term rating on the bonds
to reflect their SPUR.  According to S&P's criteria, the long-term
rating is based on the higher of the rating of the bond insurance
policy provider and the underlying rating of the issuer.

At the same time, Standard & Poor's also corrected its long-term
ratings on series 2003 B-2 through 2003 B-7 sewer revenue
refunding warrants to 'D' from 'CC/Negative' to reflect the sewer
revenue refunding warrants' SPUR.  The prior 'CC/Negative' long-
term rating reflected that of Syncora Guarantee Inc. (D/--/--),
which insures the bonds.  On April 27, 2009, Standard &
Poor's changed Syncora's issuer credit rating to 'D' from
'CC'/Negative and Syncora's financial strength rating to 'R' from
'CC'/Negative, but S&P inadvertently did not change the long-term
rating on the warrants.

The SPUR on series 2003B-2 through 2003B-7 remains at 'D', which
reflects the sewer system's failure to make a principal payment on
the bank warrants when due on April 1, 2008, in accordance with
the terms of the standby warrant purchase agreement.


JEFFERSON COUNTY: S&P Keeps 'C' Underlying Rating on Various Bonds
------------------------------------------------------------------
Standard & Poor's Ratings Services has kept its 'C' underlying
rating on Jefferson County, Alabama's series 1997A, 2001A, 2003-B-
8, 2003 B-1-A through series 2003 B-1-E, and series 2003 C-1
through 2003 C-10 sewer system revenue bonds on CreditWatch with
negative implications, where they were placed September 16, 2008.

"We are keeping the bonds on CreditWatch due to previous draws
against the system's cash and surety reserves beginning in
September 2008 and S&P's uncertainty of the system's continued
timely payment on the obligations," said credit analyst Sussan
Corson.

Although the system depleted its cash reserves and a portion of
its surety reserves in late 2008, according to the trustee, as of
July 29, 2009, there have been no additional draws against its
surety reserves since last year.  The trustee estimates the system
currently has $176 million remaining in total combined surety
reserves with Financial Guaranty Insurance Co. (FGIC; not rated),
Syncora Guarantee Inc. (Syncora; D/--/--), and Financial Security
Assurance Inc. (AAA/Negative/--), which can be applied on a pro
rata basis to any parity debt.  Syncora's surety reserve totals
$137.4 million, or 77% of the total surety reserves.

In September 2008, the trustee, FGIC, and Syncora filed a motion
against the county in the United States District Court for the
Northern District of Alabama, Southern Division seeking
appointment of a receiver over the system.  The judge appointed
two special masters to review the matter and provide
recommendations to the court; the special masters provided a final
report to the court on July 17, 2009.  In June 2OO9, the judge
ruled that the court lacked jurisdiction to appoint a receiver
with ratemaking authority.  The judge stayed all proceedings of
the case as of July 20, 2009.  The plaintiffs could still pursue
the case with a state court.

Standard & Poor's believes that increased interest rates in
conjunction with accelerated principal repayments under the
standby warrant purchase agreements, termination events of the
swap agreements, and the system's very high debt burden have
placed significant financial pressure on the county's sewer
system.  The system has not raised sewer rates to offset increased
costs.  Interest payments on the auction-rate sewer revenue
obligations are due on a near-daily basis throughout the month
while interest on the variable-rate demand warrants are due at the
first of each month.  Regularly scheduled principal payments are
due February 1 of each year.  In the event the system fails to
make a principal or interest payment on the auction-rate bonds
when due, S&P expects to lower the SPUR on the bonds to 'D'.

On April 1, 2008, Standard & Poor's lowered its SPUR on Jefferson
County's variable-rate demand series 2003 B-2 through 2003 B-7
sewer revenue refunding warrants to 'D' from 'CCC' due to the
sewer system's failure to make a principal payment on the bank
warrants when due on April 1, 2008, in accordance with the terms
of the standby warrant purchase agreement.  Due to Syncora's
suspension of payments on its insurance policies, Syncora also
failed to pay a principal payment on a portion of the bank
warrants when due on July 1, 2009.


JP MORGAN: Fitch Takes Rating Actions on 25 2007-LDP10 Certs.
-------------------------------------------------------------
Fitch Ratings downgrades, removes from Rating Watch Negative, and
revises Rating Outlooks on 25 classes of commercial mortgage pass-
through certificates from J.P. Morgan Chase Commercial Mortgage
Securities Corp., series 2007-LDP10, commercial mortgage pass-
through certificates.  A detailed list of rating actions follows
at the end of this press release.

The downgrades are the result of loss expectations and reflect
Fitch's prospective views regarding commercial real estate market
value and cash flow declines.  Fitch foresees potential losses
could reach as high as 14.8% for this transaction, should market
conditions not recover.  The rating actions are based on losses of
8.4%, including 100% of the term losses and 25% of the losses
anticipated to occur at maturity; the 8.4% recognizes all of the
losses anticipated in the next five years.  Given the uncertainty
surrounding macroeconomic conditions, commercial real estate
fundamentals, interest rates, liquidity and property performance,
Fitch's actions do not account for the full magnitude of possible
maturity losses.  The bonds with Negative Outlooks indicate
classes that may be downgraded in the future should full potential
losses be realized.

Fitch analyzed the transaction and calculated expected losses by
assuming cash flows on each of the properties decline 15% from
year-end 2007 and property values decline 35% from issuance.
These loss estimates were reviewed in more detail for 48.8% of the
pool and, in certain cases, revised based on additional
information and/or property characteristics.

The deal consists of two loan groups, Group R and Group S.  Loans
are grouped according to whether they have a five to seven year
maturities, or 10 year and greater maturities.  Principal
proceeds, including unscheduled proceeds from liquidations, are
distributed according to their respective loan group: Group S pays
down the class S certificates and Group R pays down the
certificates not noted with an 'S.' Losses are allocated reverse
sequentially, then pro rata to each loan group's corresponding
class.  Fitch incorporated an analysis of the structural features
of this transaction, including the expected paydown of each loan
group with unscheduled principal proceeds based on projected
losses, into this review.

Approximately 32.7% of the mortgages mature within the next five
years: 5.8% in 2011, 15.8% in 2012, 7.2% in 2013, and 3.9% in
2014.  All losses associated with these loans are recognized in
the rating actions.

Fitch identified 67 Loans of Concern (35.9%) within the pool, 17
of which (13.5%) are specially serviced (including one loan which
will potentially be transferred and is expected to become
delinquent).  Of the specially serviced loans, six (7.7%) are
current.  Seven of the Fitch Loans of Concern (18.2%) are within
the transaction's top 15 loans (41.8%) by unpaid principal
balance.

Three of the Loans of Concern (6.5%) within the top 15 loans are
expected to default during the term, with loss severities ranging
from 9% to 49%.  The largest contributors to loss are: Solana
(2.6% of the pool), Outrigger Guam (1.9%), and the Orchard at
Saddleback (1.9%).  Solana consists of 1,793,290 square feet (sf)
of office space, 43,685 sf of retail, a 38,000 sf health club, and
a full-service Marriott hotel.  The property, located in Westlake,
TX, was built in 1988 and most recently renovated in 2006.  The
most recent servicer reported debt service coverage ratio is 1.15
times (x) as of June 2008.  The loan, sponsored by Maguire
Partners, transferred to the special servicer in March 2009 for
imminent default after a large tenant vacated a portion of their
space.  The tenant continues to occupy 375,000 sq with their lease
expiration in 2011.  Additionally, the borrower reported the
Marriott hotel within the complex is underperforming expectations.
The special servicer is discussing workout options with the
borrower.  Limited details are presently available on the workout
and current valuation of the asset due to the loan's recent
transfer to special servicing.

The Outrigger Guam loan is secured by a full-service hotel
consisting of 600-rooms and 37,215 sf of retail space in Tumon,
Guam.  The servicer reported year-end debt service coverage ratio
(DSCR) was 1.07x, as compared to the issuer DSCR of 1.39x at
origination.  Occupancy was not reported.  Based on current
performance and anticipated declines, losses are expected prior to
the loan's maturity.

The Orchard at Saddleback is a two-phase community center located
in Lake Forest, Orange County, California.  The property's third
largest tenant, Shoe Pavilion (23,000 sf, 8.3% NRA), filed for
bankruptcy and liquidated in October 2008.  One additional tenant
filed for bankruptcy and two tenants have defaulted on their
leases.  Additionally, nine tenants requested rent reduction
ranges of up to 50%.  The loan will potentially be transferred to
the special servicer and is expected to become delinquent.  Per
the July remittance report, the servicer advanced the loan's July
debt service payment.

Fitch downgrades and removes from Rating Watch Negative these
classes:

  -- $200.7 million class A-J to 'BB' from 'AAA'; Outlook
     Negative;

  -- $145.8 million class A-JS to 'BB' from 'AAA'; Outlook
     Negative;

  -- $100.0 million class A-JFL to 'BB' from 'AAA'; Outlook
     Negative;

  -- $71.8 million class B to 'BB' from 'AA'; Outlook Negative;

  -- $34.8 million class B-S to 'BB' from 'AA'; Outlook Negative;

  -- $26.9 million class C to 'B' from 'AA-'; Outlook Negative;

  -- $13.1 million class C-S to 'B' from 'AA-'; Outlook Negative;

  -- $49.4 million class D to 'B-' from 'A'; Outlook Negative;

  -- $23.9 million class D-S to 'B-' from 'A'; Outlook Negative;

  -- $40.4 million class E to 'B-' from 'A-'; Outlook Negative;

  -- $19.6 million class E-S to 'B-' from 'A-'; Outlook Negative;

  -- $44.9 million class F to 'B-' from 'BBB+'; Outlook Negative;

  -- $21.8 million class F-S to 'B-' from 'BBB+'; Outlook
     Negative;

  -- $44.9 million class G to 'B-' from 'BBB-'; Outlook Negative;

  -- $21.8 million class G-S to 'B-' from 'BBB-'; Outlook
     Negative;

  -- $40.4 million class H to 'B-' from 'BB'; Outlook Negative;

  -- $19.6 million class H-S to 'B-' from 'BB'; Outlook Negative;

  -- $20.0 million class J to 'CCC/RR6' from 'BB-';

  -- $20.0 million class K to 'CCC/RR6' from 'B';

  -- $13.3 million class L to 'CCC/RR6' from 'B-';

  -- $6.7 million class M to 'CCC/RR6' from 'B-';

  -- $6.7 million class N to 'CCC/RR6' from 'CCC';

  -- $13.3 million class P to 'CCC/RR6' from 'CCC'.

Additionally, Fitch affirms these classes:

  -- $25.8 million class A-1 at 'AAA'; Outlook Stable;

  -- $197.9 million class A-1S at 'AAA'; Outlook Stable;

  -- $250.0 million class A-2 at 'AAA'; Outlook Stable;

  -- $688.9 million class A-2S at 'AAA'; Outlook Stable;

  -- $150.0 million class A-2SFL at 'AAA'; Outlook Stable;

  -- $1,714.1 million class A-3 at 'AAA'; Outlook Stable;

  -- $179.9 million class A-3S at 'AAA'; Outlook Stable;

  -- $505.9 million class A-1A at 'AAA'; Outlook Stable;

  -- Interest-only class X at 'AAA'; Outlook Stable;

  -- $359.0 million class A-M at 'AAA'; Outlook revised to
     Negative from Stable;

  -- $174.1 million class A-MS at 'AAA'; Outlook revised to
     Negative from Stable.

Fitch does not rate the $66.6 million class NR.


JP MORGAN: Moody's Affirms Ratings on Eight 2008-C2 Certs.
----------------------------------------------------------
Moody's Investors Service affirmed the ratings of eight classes
and downgraded 17 classes of J.P. Morgan Chase Commercial Mortgage
Securities Corp., Commercial Mortgage Pass-Through Certificates,
Series 2008-C2.  The downgrades are due to interest shortfalls and
significantly higher expected losses for the pool resulting from
anticipated losses from loans in special servicing.  Moody's
placed 17 classes on review for possible downgrade on April 14,
2009.  This action concludes Moody's review.

As of the July 13, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$1.16 billion from $1.17 billion at securitization.  The
Certificates are collateralized by 79 mortgage loans ranging in
size from less than 1% to 11% of the pool, with the top 10 loans
representing 52% of the pool.  Two loans, representing 3% of the
pool, have investment grade underlying ratings.

Eighteen loans, representing 17% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.

The pool has not experienced any realized losses since
securitization.  There are currently four loans, representing 22%
of the pool, in special servicing.  The largest specially serviced
loan is the Promenade Shops at Dos Lagos Loan ($125.2 million --
10.8%), which is secured by a 350,000 square foot entertainment
lifestyle center located in Corona, California.  The center was
95% leased at securitization, but has experienced significant
tenant issues due to the downturn in the economy.  The loan was
transferred to special servicing in November 2008 due to imminent
default and is in the process of foreclosure.  The property was
appraised at $169.7 million at securitization.  A December 2008
appraisal valued the property at $69.6 million, leading the
special servicer to recognize a $63.9 million appraisal reduction
in April 2009.

The second largest specially serviced loan is the Westin Portfolio
Loan ($104.0 million -- 8.9%), which represents a pari passu
interest in a $209.0 million first mortgage loan.  The loan is
secured by a 487-unit full service hotel located in Tucson,
Arizona and a 412-unit full service hotel located in Hilton Head,
South Carolina.  The loan was transferred to special servicing in
October 2008 due to imminent default and is now 90+ days
delinquent.  The properties were appraised at $303.8 million at
securitization.  A March 2009 appraisal valued the properties at
$142.0 million.  The special servicer recognized a $26.0 million
appraisal reduction in July 2009 based on 25% of the outstanding
loan balance.  Moody's expects that the appraisal reduction will
be increased based on based on the recent appraisal.

Moody's estimates an aggregate loss for the specially serviced
loans of $143.2 million (55% loss severity on average).  The
losses for the two largest loans in special servicing are based on
a discount to the recently received appraisals.

As of the most recent remittance date, the transaction has
experienced unpaid accumulated interest shortfalls totaling
$3.4 million affecting Classes F through NR.  It is expected that
the interest shortfalls will increase and continue as long as the
two largest specially serviced loans remain in special servicing.

Moody's was provided with full-year 2008 operating results for 92%
of the pool.  Moody's weighted average loan to value ("LTV") ratio
for the conduit component is 139% compared to 148% at Moody's last
review in February 2009.  Moody's stressed debt service coverage
ratio for the conduit component is 0.86X compared to 0.75X at last
review.  Moody's stressed DSCR is based on Moody's net cash flow
and a 9.25% stressed rate applied to the loan balance.

Moody's uses a variation of the Herfindahl index to measure
diversity of loan size, where a higher number represents greater
diversity.  Loan concentration has an important bearing on
potential rating volatility, including the risk of multiple-notch
downgrades under adverse circumstances.  The credit neutral Herf
score is 40 and the pool, excluding loans with underlying ratings,
has a Herf score of 23.

The two loans with underlying ratings comprise 3% of the pool. The
largest loan with an underlying rating is the Two Democracy Plaza
Loan ($31.0 million -- 2.7%), which is secured by a 273,000 square
foot office building located in Bethesda, Maryland.  The largest
tenant is the National Institute of Health (a U.S. government-
related tenant; Moody's senior unsecured rating Aaa -- stable
outlook), which leases 82% of the net rentable area through
October 2010 and September 2012.  The property was 98% occupied as
of June 2009, the same level as at last review. Moody's current
underlying rating and stressed DSCR are A2 and 1.79X,
respectively, compared to A2 and 1.59X at last review.

The second largest loan with an underlying rating is the Lofts at
New Roc Loan ($4.9 million -- 0.4%), which is secured by a 98-unit
cooperative multifamily property located in New Rochelle, New
York.  Moody's current underlying rating and stressed DSCR are Aaa
and 2.53X, respectively, compared to Aaa and 2.26X at last review.

The top three performing conduit loans represent 16.9% of the
pool. The largest loan is the Block at Orange Loan ($110.0 million
-- 9.5%), which represents a pari passu interest in a
$220.0 million first mortgage loan.  The loan is secured by
700,000 square foot retail entertainment center located in Orange,
California.  The property is anchored by an AMC Entertainment
movie theater, Dave & Buster's, and Vans Skate Park.  The property
was 83% occupied as of March 2009 compared to 96% at
securitization.  The decline in occupancy is due to three tenants,
each of which occupied more than 20,000 square feet at
securitization, vacating the center.  Moody's LTV and stressed
DSCR are 135% and 0.68X, respectively, compared to 130% and 0.73X
at last review.

The second largest performing conduit loan is the Tupper Building
Loan ($43.9 million -- 3.8%), which is secured by a 97,000 square
foot medical office property located in Boston, Massachusetts.
The property is 100% occupied by New England Medical Center
Hospitals through September 2017.  The loan is interest-only for
its entire five year term.  Moody's LTV and stressed DSCR are 122%
and 0.88X, respectively, compared to 167% and 0.61X at last
review.

The third largest conduit loan is the Station Casinos Headquarters
Loan ($42.3 million -- 3.6%), which is secured by 138,000 square
foot office building located in Las Vegas, Nevada.  The building
is 100% occupied by Station Casinos under a 20-year lease and
serves at their corporate headquarters.  The property is located
adjacent to the Red Rocks Casino, which is owned and operated by
Stations Casinos.  Station Casinos Inc. filed for Chapter 11
bankruptcy protection on July 28, 2009.  Due to the bankruptcy
filing, Moody's expect that this loan will be transferred to
special servicing.  Moody's LTV and stressed DSCR are 146% and
0.85X, respectively, compared to 162% and 0.68X at last review.

Moody's rating action is:

  -- Class A-1, $19,929,927, affirmed at Aaa; previously affirmed
     at Aaa on 2/6/2009

  -- Class A-1A, $64,723,480, affirmed at Aaa; previously affirmed
     at Aaa on 2/6/2009

  -- Class A-2, $68,126,000, affirmed at Aaa; previously affirmed
     at Aaa on 2/6/2009

  -- Class A-3, $105,514,000, affirmed at Aaa; previously affirmed
     at Aaa on 2/6/2009

  -- Class A-SB, $54,460,000, affirmed at Aaa; previously affirmed
     at Aaa on 2/6/2009

  -- Class A-4, $354,554,000, affirmed at Aaa; previously affirmed
     at Aaa on 2/6/2009

  -- Class A-4FL, $145,000,000, affirmed at Aaa; previously
     affirmed at Aaa on 2/6/2009

  -- Class X, Notional, affirmed at Aaa; previously affirmed at
     Aaa on 2/6/2009

  -- Class A-M, $116,589,000, downgraded to Aa3 from Aaa;
     previously placed on review for possible downgrade on
     04/16/2009

  -- Class A-J, $61,209,000, downgraded to Ba1 from A2; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class B, $14,574,000, downgraded to B1 from A3; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class C, $14,574,000, downgraded to B3 from Baa1; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class D, $10,201,000, downgraded to Ca from Baa2; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class E, $10,202,000, downgraded to Ca from Baa3; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class F, $13,116,000, downgraded to Ca from Ba1; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class G, $11,659,000, downgraded to Ca from Ba3; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class H, $16,031,000, downgraded to C from B2; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class J, $14,574,000, downgraded to C from B3; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class K, $14,573,000, downgraded to C from Caa1; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class L, $8,745,000, downgraded to C from Caa3; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class M, $4,372,000, downgraded to C from Caa3; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class N, $5,829,000, downgraded to C from Ca; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class P, $4,372,000, downgraded to C from Ca; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class Q, $2,915,000, downgraded to C from Ca; previously
     placed on review for possible downgrade on 04/16/2009

  -- Class T, $4,372,000, downgraded to C from Ca; previously
     placed on review for possible downgrade on 04/16/2009


LB-UBS COMMERCIAL: Fitch Takes Rating Actions on 2007-C1 Certs.
---------------------------------------------------------------
Fitch Ratings downgrades 14 classes, removes 13 classes from
Rating Watch Negative and revises Rating Outlooks on six classes
of commercial mortgage pass-through certificates from LB-UBS
Commercial Mortgage Trust 2007-C1.  A detailed list of rating
actions follows at the end of this press release.

The downgrades are the result of loss expectations and reflect
Fitch's prospective views regarding commercial real estate market
value and cash flow declines.  Fitch forecasts potential losses of
12.2% for this transaction, should market conditions not recover.
The rating actions are based on losses of 9.4%, including 100% of
the losses associated with term defaults and any losses associated
with maturities within the next five years.  Given the significant
term to maturity, Fitch's actions only account for 25% of the
losses associated with maturities beyond five years.  The bonds
with Negative Outlooks indicate classes that may be downgraded in
the future should full potential losses be realized.  Fitch
considers the Outlooks on the super-senior classes to be Stable
due to projected losses having limited impact on credit
enhancement when associated paydown is factored into the analysis.

Fitch analyzed the transaction and calculated expected losses by
assuming cash flows on each of the properties decline 15% from
year-end 2007 and property values decline 35% from issuance. These
loss estimates were reviewed in more detail for loans representing
67.6% of the pool and, in certain cases, revised based on
additional information and/or property characteristics.

Approximately 24.3% of the mortgages mature within the next five
years: 14% in 2011, 4.3% in 2012, 0.1% in 2013, and 5.9% in 2014.
In 2017, 57.3% of the pool is scheduled to mature.

Fitch identified 25 Loans of Concern (17.2%) within the pool, 18
of which (16.3%) are specially serviced.  Of the specially
serviced loans, six (8.7% of the pool) are current.  Three of the
Fitch Loans of Concern (8.1%) are within the transaction's top 15
loans (62.2%) by unpaid principal balance, one of which is 90 days
delinquent.

Seven of the loans within the top 15 (24%) are expected to
default, with losses expected during the term for two (6.8%)
loans, and maturity losses expected for the remaining five (17.2%)
loans.  Loss severities associated with these defaults range from
12% to 47%.  The largest contributors to loss on a pool level
basis are: Bethany Maryland Portfolio (4%), Bethany Houston
Portfolio (2.7%), and Sevilla Apartments (1.3%).

The largest (4%) and second largest (2.7%) Loans of Concern are
two components of a four loan (8.3%) borrower concentration that
transferred to the special servicer in March 2009 for imminent
default.  Bethany Maryland Portfolio (4%), Bethany Houston
Portfolio (2.7%), Bethany Austin Portfolio (1.2%), and Bethany
Blanding Place (0.4%) are comprised of class B/C multifamily units
generally built in the 1960s, 1970s, and 1980s.  The loans
transferred after it was reported to the special servicer that the
former management company, which was related to the borrower,
apparently terminated all employees and abandoned the properties
in late February 2009.  In addition, with respect to the Houston
and Austin Portfolios, it was also reported that numerous mechanic
liens had been recorded against the properties securing the loans.
Since the transfer, new management companies have been appointed
to focus on maintenance of the grounds.  The management companies
are also conducting aggressive leasing campaigns.  The borrower,
Bethany Holdings Group LLC, is seeking a loan modification in
order to stabilize performance of the property.  Occupancy at each
property on a portfolio level ranges from 72% to 89% as of year-
end 2008.  Losses are expected prior to the loan maturities.

The next Loan of Concern (1.3%) is secured by a 249-unit
multifamily portfolio located in San Francisco.  The loan, which
is specially serviced, is cross-collateralized and cross-defaulted
with four other specially serviced loans (0.96%) in the pool that
have a related borrower, Frank Lembi.  In total, the five loans
(2.3%) are secured by 19 multi-family buildings located in San
Francisco, CA, encompassing a total of 509-units.  The loans
transferred in April 2009 as a result of cash flow being
insufficient to cover the debt service.  Occupancy at each
property on a portfolio level ranges from 60% to 100% as of year-
end 2008.  Limited details are presently available on the workout
due to the loan's recent transfer to special servicing.  The
special servicer is discussing workout options with the borrower.

The next Loan of Concern (1.3%) is secured by Sevilla Apartments,
a 512-unit class B garden apartment complex located in Palm
Desert, CA.  The loan, which is specially serviced, transferred in
May 2009 for imminent default.  Due to increased tenant
delinquency, job losses, and softening market conditions,
occupancy during 2008 declined to a low of 45%.  Occupancy has
improved to 65% as of June 2009; however, cash flow continues to
be insufficient to cover debt service.  As of year-end 2008, the
servicer-reported debt service coverage ratio (DSCR) was 0.14
times (x), as compared to an issuer underwritten DSCR of 1.23
times (x) at origination.  The borrower has asked for a loan
modification and is discussing workout options with the special
servicer.  Based on current performance, losses are expected prior
to the loan's maturity.

Fitch downgrades and assigns Rating Outlooks where indicated to
these classes:

  -- $315.6 million class A-J to 'BB' from 'AAA'; Outlook
     Negative;

  -- $27.8 million class B to 'BB' from 'AA+'; Outlook Negative;

  -- $55.7 million class C to 'B' from 'AA'; Outlook Negative;

  -- $37.1 million class D to 'B-' from 'AA-'; Outlook Negative;

  -- $18.6 million class E to 'B-' from 'A+'; Outlook Negative;

  -- $32.5 million class F to 'B-' from 'A'; Outlook Negative;

  -- $32.5 million class G to 'B-' from 'A-'; Outlook Negative;

  -- $41.8 million class H to 'CCC/RR6' from 'BBB+';

  -- $41.8 million class J to 'CC/RR6' from 'BBB';

  -- $51.1 million class K to 'CC/RR6' from 'BBB-';

  -- $9.3 million class L to 'CC/RR6' from 'BB-';

  -- $9.3 million class M to 'CC/RR6' from 'B+';

  -- $9.3 million class N to 'CC/RR6' from 'B'.

Fitch also removes all of the above classes from Rating Watch
Negative.

In addition, Fitch affirms these classes and Outlooks as
indicated:

  -- $37.4 million class A-1 at 'AAA'; Outlook Stable;
  -- $211 million class A-2 at 'AAA'; Outlook Stable;
  -- $225 million class A-3 at 'AAA'; Outlook Stable;
  -- $95 million class A-AB at 'AAA'; Outlook Stable;
  -- $1.2 billion class A-4 at 'AAA'; Outlook Stable;
  -- $849.3 million class A-1A at 'AAA'; Outlook Stable;
  -- Interest-only class X-CP at 'AAA'; Outlook Stable;
  -- Interest-only class X-W at 'AAA'; Outlook Stable;
  -- Interest-only class X-CL at 'AAA'; Outlook Stable.

Fitch also affirms this class and revises the Outlook as
indicated:

  -- $371.3 million class A-M at 'AAA'; Outlook to Negative from
     Stable;

Fitch does not rate classes P, Q, S, T, or BMP.


LEHMAN BROS: S&P Downgrades Ratings on Five 2004-LLF C5 Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
classes of multiclass pass-through certificates from Lehman Bros.
Floating Rate Commercial Mortgage Trust's series 2004-LLF C5.
Concurrently, S&P affirmed its 'AAA' ratings on seven other
classes from this series.  At the same time, S&P removed all 12
ratings from CreditWatch with negative implications, where they
were placed April 7, 2009.

The downgrades follow S&P's analysis of the Sheraton Chicago Hotel
& Towers loan and the Hilton in the Walt Disney World Resort loan.
Both loans are secured by hotel properties, which have been
affected by the reduction in business and leisure travel.  S&P's
analysis factored in S&P's expectation that overall average 2009
revenue per available room in the lodging industry would decline
between 14% and 16%, as S&P noted in a recent article and also
considered conditions in the local lodging markets.

According to Smith Travel, the Chicago and Orlando lodging markets
posted significant declines in RevPAR of 27% and 21%,
respectively, in the first six months of 2009 compared with 2008,
whereas the general U.S. hotel industry reported a 19% decline in
RevPAR.

S&P affirmed its ratings on the interest-only certificates based
on S&P's current criteria.  S&P published a request for comment
proposing changes to the IO criteria on June 1, 2009.  After S&P
finalize its criteria review, S&P may revise its current criteria.
Any change in S&P's criteria may affect outstanding ratings,
including the ratings on the IO certificates S&P affirmed.

The largest loan remaining in the pool, the Sheraton Chicago Hotel
& Towers loan, has a $157.0 million whole-loan balance that
consists of a $141.7 million senior note that makes up 49% of the
pooled trust balance (as of the July 15, 2009, trustee remittance
report) and a $15.3 million nontrust subordinate B note.  This
loan is secured by a 34-story, 1,209-room, full-service
convention-oriented hotel in Chicago.  The master servicer,
Wachovia Bank N.A., reported a debt service coverage of 4.79x for
the 12 months ended December 31, 2008, and 78% occupancy for the
period ended March 31, 2009.  S&P based its analysis on the
borrower's operating statements for the first three months of
2009, the 12 months ended December 31, 2008, and the borrower's
2009 budget.  S&P's adjusted valuation has fallen 20% since S&P's
last review, dated January 29, 2008.  The loan's final maturity
date is January 13, 2010.  The borrower is currently seeking to
refinance the loan.  According to Wachovia, any special servicing
and workout fees incurred on this loan will be absorbed by the
nontrust subordinate B note first.

The second-largest loan in the pool, the Hilton in the Walt Disney
World Resort loan, has a trust and whole-loan balance of
$100.0 million (35% of the pooled trust balance).  In addition,
the borrower's equity interests in the property secure a
$30.0 million mezzanine loan.  This loan is secured by an 814-
room, full-service upscale resort hotel located within the Walt
Disney World resort in Lake Buena Vista, Fla.  Wachovia reported a
5.85x DSC for the 12 months ended March 31, 2009, and 85%
occupancy as of May 2009.  Standard & Poor's used the borrower's
operating statements for the first five months of 2009, the 12
months ended December 31, 2008, and the borrower's 2009 budget to
derive an adjusted valuation that has declined 32% from S&P's last
review.  The loan matures on October 13, 2009.  The borrower has
indicated that it plans to exercise its remaining one-year
extension option.

The smallest loan in the pool, the specially serviced Westin Oaks
& Westin Galleria loan, has a whole-loan balance of $52.0 million
that is split into a $47.1 million senior pooled component (16% of
the pooled trust balance) and a $4.9 million subordinate nonpooled
component that is raked to the class 'WO' certificates (not rated
by Standard & Poor's).  This loan is secured by two adjacent full-
service hotels in Houston totaling 893 rooms.

According to the special servicer, TriMont Real Estate Advisors
Inc., this loan was paid in full on July 23, 2009.  As part of the
loan payoff, the borrower also paid the special servicing and
liquidation fees.  Wachovia indicated that the payoff of this loan
may be reflected as early as the August 17, 2009, trustee
remittance report.

      Ratings Lowered And Removed From Creditwatch Negative

       Lehman Bros. Floating Rate Commercial Mortgage Trust
     Multiclass pass-through certificates series 2004-LLF C5

                  Rating
                  ------
    Class       To       From            Credit enhancement (%)
    -----       --       ----            ----------------------
    F           AA-      AA+/Watch Neg                    37.13
    G           BBB+     AA/Watch Neg                     27.50
    H           BBB-     A/Watch Neg                      19.61
    J           BB       BBB+/Watch Neg                   10.92
    K           B        BBB-/Watch Neg                     N/A

      Ratings Affirmed And Removed From Creditwatch Negative

       Lehman Bros. Floating Rate Commercial Mortgage Trust
     Multiclass pass-through certificates series 2004-LLF C5

                  Rating
                  ------
    Class       To       From            Credit enhancement (%)
    -----       --       ----            ----------------------
    A-2         AAA      AAA/Watch Neg                    98.00
    B           AAA      AAA/Watch Neg                    83.25
    C           AAA      AAA/Watch Neg                    67.81
    D           AAA      AAA/Watch Neg                    56.90
    E           AAA      AAA/Watch Neg                    47.14
    X-2         AAA      AAA/Watch Neg                      N/A
    X1-WO       AAA      AAA/Watch Neg                      N/A

                       N/A - Not applicable.


LIGHTPOINT CLO: Moody's Downgrades Ratings on Two Classes of Notes
------------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Lightpoint CLO III, Ltd.:

  -- US$351,700,000 Class A-1A Senior Secured Floating Rate Notes
     due 2017, Downgraded to Aa2; previously on July 20, 2005
     Assigned Aaa;

  -- US$60,000,000 Class A-1B Delay Settle Senior Secured Floating
     Rate Notes due 2017, Downgraded to Aa2; previously on
     July 20, 2005 Assigned Aaa.

In addition, Moody's has confirmed the ratings of these notes:

  -- US$16,200,000 Class B Secured Deferrable Floating Rate Notes
     due 2017, Confirmed at Baa2; previously on March 18, 2009
     Downgraded to Baa2 and Placed Under Review for Possible
     Downgrade;

  -- US$35,750,000 Class C Secured Floating Rate Notes due 2017,
     Confirmed at Ba3; previously on March 18, 2009 Downgraded to
     Ba3 and Placed Under Review for Possible Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," the application
of certain stresses with respect to the default probabilities
associated with certain Moody's credit estimates, and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
second lien loans will be below their historical averages,
consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, and an increase in the proportion of
securities from issuers rated Caa1 and below.  The weighted
average rating factor has steadily increased over the last year
and is currently 2764 versus a test level of 2600 as of the last
trustee report, dated June 30, 2009.  Based on the same report,
defaulted securities total about $27.3 million, accounting for
roughly 5.9% of the collateral balance, and securities rated Caa1
or lower make up approximately 13.6% of the underlying portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Lightpoint CLO III, Ltd., issued on July 20, 2005, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


MADISON AVENUE: Moody's Cuts Ratings on Class A Notes to 'Ba2'
--------------------------------------------------------------
Moody's Investors Service announced that it has downgraded ratings
of one class of notes issued by Madison Avenue Structured Finance
CDO I, Limited.  The note affected by the rating action is:

* The US$250,000,000 Class A Floating Rate Notes due 2036,
  Downgraded to Ba2; previously on Mar 20, 2009 Downgraded to Baa1
  and Placed Under Review for Possible Downgrade;

Madison Avenue Structured Finance CDO I, Limited is a
collateralized debt obligation backed primarily by a portfolio of
residential mortgage backed securities and other types of assets
backed securities.

The rating downgrade actions reflect deterioration in the credit
quality of the underlying portfolio.  Credit deterioration of the
collateral pool is observed through a decline in the average
credit rating (as measured by the weighted average rating factor,
an increase in the proportion of securities rated Caa1 and below
and failure of the coverage tests.  More than 36% of its assets
have been downgraded since Moody's last review of the transaction
in March 2009.  Securities rated Caa1 or lower make up
approximately 28% of the underlying portfolio.  In addition, the
Trustee reports that the transaction is currently failing one or
more coverage tests, including the Class A/B Overcollateralization
Test.

The actions also take into consideration the occurrence on
December 11, 2008, as reported by the Trustee, of an Event of
Default described in Sections 5.1(a) and 5.1(c) of the Indenture
dated December 5, 2001.  As provided in Article V of the Indenture
during the occurrence and continuance of an Event of Default,
certain holders of Notes may be entitled to direct the Trustee to
take particular actions with respect to the Collateral and the
Notes, including the sale and liquidation of the assets. The
severity of losses of certain tranches may be different, however,
depending on the timing and outcome of liquidation.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision


MAGNOLIA FINANCE: Moody's Downgrades Ratings on 2006-7 Notes
------------------------------------------------------------
Moody's Investors Service announced that it has downgraded its
ratings of certain series of notes issued by Magnolia Finance II
plc under Series 2006-7 in the context of collateralized debt
obligation transactions as "Corporate Synthetic CDOs" referencing
a portfolio of corporate loan obligations.

Moody's explained that the rating action taken is primarily due to
the credit rating migration of CIT Group Inc. to Ca, greater than
had been anticipated by its forward looking measures in the
previous rating action on April 1, 2009.  CIT Group Inc.
represents approximately 4% of the notional of the portfolio.

Moody's initially analyzed and continues to monitor this
transaction using primarily the methodology for Corporate
Synthetic CDOs and for collateralized loan obligations as
described in Moody's Special Reports below:

  -- Moody's Approach to Rating Corporate Collateralized Synthetic
     Obligations (March 2009)

  -- Moody's Approach to Rating Collateralized Loan Obligations
      (December 2008)

The rating action is:

Transaction: Magnolia Finance II Series 2006-7A2

Class Description: Class A2

  -- Current Rating: Aa2
  -- Prior Rating Action: Downgrade to Aa1 from Aaa
  -- Prior Rating Action Date: April 1, 2009

Transaction: Magnolia Finance II Series 2006-7B

Class Description: Class B

  -- Current Rating: A2
  -- Prior Rating Action: Downgrade to Aa3 from Aa2
  -- Prior Rating Date: April 1, 2009

Transaction: Magnolia Finance II Series 2006-7C

Class Description: Class C

  -- Current Rating: Baa2
  -- Prior Rating Action: Downgrade to A3 from A2
  -- Prior Rating Date: April 1, 2009

Transaction: Magnolia Finance II Series 2006-7D

Class Description: Class D

  -- Current Rating: Ba1
  -- Prior Rating Action: assignment of Baa2
  -- Prior Rating Date: September 28, 2006


MASTR ASSET: Moody's Downgrades Ratings on 2-A-2 Tranche
--------------------------------------------------------
Moody's Investors Service has downgraded the 2-A-2 tranche from
MASTR Asset Securitization Trust 2005-2.

The collateral backing this transaction consists primarily of
first-lien, fixed rate, Jumbo mortgage loans.  The action is
triggered by the quickly deteriorating performance -- marked by
rising delinquencies and loss severities, along with concerns
about the continuing drop in housing prices nationwide and the
rising unemployment levels.  The actions listed below reflect
Moody's updated expected losses on the jumbo sector announced in a
press release on March 19, 2009, and are part of Moody's on-going
review process.

Moody's final rating actions are based on current ratings, level
of credit enhancement, collateral performance and updated pool-
level loss expectations relative to current level of credit
enhancement.  Moody's took into account credit enhancement
provided by seniority, cross-collateralization, time tranching,
and other structural features within the senior note waterfalls.

Loss estimates are subject to variability and are sensitive to
assumptions used; as a result, realized losses could ultimately
turn out higher or lower than Moody's current expectations.
Moody's will continue to evaluate performance data as it becomes
available and will assess the pattern of potential future defaults
and adjust loss expectations accordingly as necessary.

Complete rating actions are:

Issuer: MASTR Asset Securitization Trust 2005-2

  -- Cl. 2-A-2, Downgraded to Ba3; previously on 3/19/2009 Aaa
     Placed Under Review for Possible Downgrade

The ratings on the notes were assigned after evaluating factors
determined applicable to the credit profile of the notes, such as:

  i) the nature, sufficiency, and quality of historical
     performance information available for the asset class as well
     as for the transaction sponsor,

ii) collateral analysis,

iii) an analysis of the policies, procedures and alignment of
     interests of the key parties to the transaction, most notably
     the originator and the servicer,

iv) an analysis of the transaction's allocation of collateral
     cashflow and capital structure,

  v) an analysis of the transaction's governance and legal
     structure, and

vi) a comparison of these attributes against those of other
     similar transactions.


MAX CMBS: S&P Downgrades Ratings on 22 Classes of Notes
-------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 22
classes from MAX CMBS I Ltd.'s series 2008-1 and COMM 2008-RS3.
The lowered ratings, as well as the rating on class A-1 from MAX
2008-1 (which was not lowered), remain on CreditWatch with
negative implications.  In addition, S&P's 'AAA' rating on class
A-1 from MAX CMBS I Ltd.'s series 2007-1 remains on CreditWatch
negative.

MAX CMBS I Ltd., the issuer, has the ability to issue one or more
series of notes.  MAX 2008-1 is the second series of notes.  The
first series, MAX 2007-1, is cross-collateralized with MAX 2008-1.
The COMM 2008-RS3 transaction is primarily backed by certain
securities from MAX 2008-1 and has a similar priority of
distribution.

The downgrades reflect S&P's analysis of the transactions
following S&P's rating actions on seven commercial mortgage-backed
securities certificates that serve as underlying collateral for
MAX 2008-1 and MAX 2007-1.  The certificates are from four
transactions totaling $459.6 million (5.8% of the pool balance for
these transactions).  The ratings on MAX 2008-1, MAX 2007-1, and
COMM 2008-RS3 remain on CreditWatch negative due to each
transaction's exposure to CMBS collateral that is on CreditWatch
negative.

According to the trustee report dated July 17, 2009, MAX 2008-1
and MAX 2007-1 are collateralized by 156 CMBS certificates
($7.114 billion, 90% of the combined transaction balances) from 99
distinct transactions issued between 2005 and 2007.  The
collateral also includes 12 collateralized debt obligation (CDO)
securities ($776.6 million, 10%) from 12 distinct transactions.
The MAX 2008-1 and MAX 2007-1 transactions' exposure to downgraded
CMBS includes:

* GS Mortgage Securities Trust 2007-GG10 (classes A-M and A-J;
  $210.8 million, 2.7%);

* CD 2007-CD5 Mortgage Trust series 2007-CD5 (classes A-M and A-J;
  $100 million, 1.3%); and

* Morgan Stanley Capital I Trust series 2007-IQ16 (class A-M;
  $50 million, 0.6%).

The collateral for COMM 2008-RS3 consists of classes A-2A, A-2B,
X-B, X-W, C, E, F, G, H, J, and K from MAX 2008-1.  S&P lowered
the ratings on the COMM 2008-RS3 classes concurrently with the
downgrades of the respective MAX 2008-1 classes.

The distribution of interest proceeds to the interest-only classes
X-B and X-W from MAX 2008-1 are made pro rata to classes A-2A and
A-2B.  Classes X-B and X-W were downgraded accordingly.  S&P
published a request for comment proposing changes to S&P's
interest-only criteria on June 1, 2009.  After finalizing S&P's
criteria review, S&P may revise its current criteria.  Any change
in S&P's criteria may affect outstanding ratings, including the
ratings on the X-B and X-W certificates S&P lowered.

S&P will update or resolve the CreditWatch negative placements on
MAX 2008-1, MAX 2007-1, and COMM 2008-RS3 in conjunction with
S&P's CreditWatch resolutions of the underlying CMBS assets.

      Ratings Lowered And Remaining On Creditwatch Negative

                      MAX CMBS I 2008-1 Ltd.

                                 Rating
                                 ------
          Class            To               From
          -----            --               ----
          A-2A             AA+/Watch Neg    AAA/Watch Neg
          A-2B             AA+/Watch Neg    AAA/Watch Neg
          C                A+/Watch Neg     AA/Watch Neg
          E                A/Watch Neg      A+/Watch Neg
          F                BBB+/Watch Neg   A/Watch Neg
          G                BBB/Watch Neg    A-/Watch Neg
          H                BB+/Watch Neg    BBB+/Watch Neg
          J                BB/Watch Neg     BBB/Watch Neg
          K                B-/Watch Neg     BB+/Watch Neg
          X-B              AA+/Watch Neg    AAA/Watch Neg
          X-W              AA+/Watch Neg    AAA/Watch Neg

                           COMM 2008-RS3

                                 Rating
                                 ------
          Class            To               From
          -----            --               ----
          A-2A             AA+/Watch Neg    AAA/Watch Neg
          A-2B             AA+/Watch Neg    AAA/Watch Neg
          B                A+/Watch Neg     AA/Watch Neg
          C                A/Watch Neg      A+/Watch Neg
          D                BBB+/Watch Neg   A/Watch Neg
          E                BBB/Watch Neg    A-/Watch Neg
          F                BB+/Watch Neg    BBB+/Watch Neg
          G                BB/Watch Neg     BBB/Watch Neg
          H                B-/Watch Neg     BB+/Watch Neg
          X-B              AA+/Watch Neg    AAA/Watch Neg
          X-W              AA+/Watch Neg    AAA/Watch Neg

            Ratings Remaining On Creditwatch Negative

                      MAX CMBS I 2008-1 Ltd.

                  Class           Rating
                  -----           ------
                  A-1             AAA/Watch Neg

                      MAX CMBS I 2007-1 Ltd.

                  Class           Rating
                  -----           ------
                  A-1             AAA/Watch Neg


MERRILL LYNCH: Moody's Reviews Ratings on Series 2005-MCP1 Certs.
-----------------------------------------------------------------
Moody's Investors Service placed 14 classes of Merrill Lynch
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
Series 2005-MCP1 on review for possible downgrade due to higher
expected losses for the pool resulting from anticipated losses
from loans in special servicing, increased loan concentration and
a decline in the pool's overall credit quality.  Since Moody's
prior review in July 2008, the pool's exposure to specially
serviced loans has increased from 6% to 9%.  The rating action is
the result of Moody's on-going surveillance of commercial mortgage
backed securities transactions.

As of the July 13, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 5% to
$1.66 billion from $1.74 billion at securitization.  The
Certificates are collateralized by 109 mortgage loans ranging in
size from less than 1% to 12% of the pool, with the top 10 loans
representing 47% of the pool.  The pool includes three loans with
underlying ratings, representing 15% of the pool.  Four loans,
representing 4% of the pool, have defeased and are collateralized
by U.S. Government securities.

Twenty four loans, representing 11% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.

The pool has not experienced any losses to date.  Eight loans,
representing 9% of the pool, are currently in special servicing.
The largest specially serviced loan is the HSA Industrial
Portfolio ($61.3 million -- 3.7%), which is secured by nine
industrial properties totaling 2.3 million square feet which are
located in Ohio and Kentucky.  The loan has been in special
servicing since June 2008 due payment default.  In July 2009 the
special servicer recognized an appraisal reduction of
$17.0 million for this loan.  The special servicer has also
recognized an aggregate appraisal reduction of $17.6 million for
four other specially serviced loans.

Moody's review will focus on the performance of the overall pool
and potential losses from specially serviced loans.

Moody's rating action is:

  -- Class A-J, $115,142,000, currently rated Aaa, on review for
     possible downgrade; previously affirmed at Aaa on 7/24/2008

  -- Class B, $36,932,000, currently rated Aa2, on review for
     possible downgrade; previously affirmed at Aa2 on 7/24/2008

  -- Class C, $15,208,000, currently rated Aa3, on review for
     possible downgrade; previously affirmed at Aa3 on 7/24/2008

  -- Class D, $32,587,000, currently rated A2, on review for
     possible downgrade; previously affirmed at A2 on 7/24/2008

  -- Class E, $19,553,000, currently rated A3, on review for
     possible downgrade; previously affirmed at A3 on 7/24/2008

  -- Class F, $28,242,000, currently rated Baa1, on review for
     possible downgrade; previously affirmed at Baa1 on 7/24/2008

  -- Class G, $17,380,000, currently rated Baa2, on review for
     possible downgrade; previously affirmed at Baa2 on 7/24/2008

  -- Class H, $21,725,000, currently rated Baa3, on review for
     possible downgrade; previously affirmed at Baa3 on 7/24/2008

  -- Class J, $6,518,000, currently rated Ba1, on review for
     possible downgrade; previously affirmed at Ba1 on 7/24/2008

  -- Class K, $8,690,000, currently rated Ba2, on review for
     possible downgrade; previously affirmed at Ba2 on 7/24/2008

  -- Class L, $6,517,000, currently rated Ba3, on review for
     possible downgrade; previously affirmed at Ba3 on 7/24/2008

  -- Class M, $4,345,000, currently rated B1, on review for
     possible downgrade; previously affirmed at B1 on 7/24/2008

  -- Class N, $4,345,000, currently rated B2, on review for
     possible downgraded; previously affirmed at B2 on 7/24/2008

  -- Class P, $8,690,000, currently rated B3, on review for
     possible downgrade; previously affirmed at B3 on 7/24/2008


MISSISSIPPI HIGHER: Fitch Retains Ratings on Various Student Loans
------------------------------------------------------------------
Fitch Ratings currently maintains ratings on student loan asset-
backed securities issued by the Mississippi Higher Education
Assistance Corporation under the indenture, dated June 1, 2004.

MHEAC has requested that Fitch confirm its existing ratings upon
the adoption and effectiveness of the supplemental indenture,
dated as of July 1, 2009 (the Supplement).  Consistent with its
statements on policies regarding rating confirmations in
structured finance transactions (January 13, 2009) and student
loan confirms (May 8, 2009), Fitch is treating this request as a
notification.

Based on the information provided, Fitch has determined that this
transaction will not have an impact on the existing ratings at
this time.  This determination only addresses the effect of the
transaction on the current ratings assigned by Fitch to the
securities.  It does not address whether the transaction is
permitted by the terms of the documents nor does it address
whether it is in the best interests of, or prejudicial to, some or
all of the holders of the securities listed.

The Supplement allows for the use of approximately $11.6 million
held in the revolving subaccount of the acquisition account to
purchase select outstanding auction rate bonds at a price not
exceeding 95% of remaining principal balance plus 100% of the
accrued and unpaid interest (collectively, the transaction).  The
funds, which are currently held in the revolving subaccount of the
acquisition account and utilized to recycle into student loans
until June 1, 2010, would now be available to purchase bonds from
investors, who may voluntarily elect to sell their bonds at a
discount.

Based on trust balance sheet as of June 30, 2009, the transaction,
when completed, may increase the senior and total parity ratios
for the trust up to approximately 108.52% and 96.88% from 107.54%
and 96.77%, respectively.  The subordination level for the senior
bonds would increase slightly from 10% to 10.78%.  In addition,
the composition of the trust loan pool and the weighted average
coupon rate of the bonds are not expected to change materially.

The ratings assigned by Fitch are based on the documents and
information provided to Fitch by the issuer and other parties and
the receipt of final closing documents.  Fitch relies on all these
parties for the accuracy of such information and documents.  Fitch
did not audit or verify the truth or accuracy of such information.

The student loan revenue bonds, auction-rate securities, issued
under the indenture by the Mississippi Higher Education Assistance
Corporation are currently rated by Fitch:

  -- $45,000,000 senior series 2004 A-1 'AAA';
  -- $73,800,000 senior series 2007 A-1 'AAA';
  -- $36,900,000 senior series 2007 A-2 'AAA';
  -- $5,000,000 subordinate series 2004 B-1 'BB';
  -- $12,300,000 subordinate series 2007 B-1 'BB'.


MKP CBO: Moody's Downgrades Ratings on Class A-1 Notes to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of one class of notes issued by MKP CBO II, Ltd.  The notes
affected by the rating action are:

* $183,750,000 Class A-1 Senior Secured Floating Rate Term Notes,
  Due 2036, Downgraded to Ba1; previously on 2/24/2009 Downgraded
  to Aa3

MKP CBO II, Ltd., is a collateralized debt obligation backed
primarily by a portfolio of residential mortgage backed securities
and other types of assets backed securities.

The rating downgrade actions reflect deterioration in the credit
quality of the underlying portfolio.  Credit deterioration of the
collateral pool is observed through a decline in the average
credit rating (as measured by an increase in the weighted average
rating factor), an increase in the dollar amount of defaulted/PIK
assets and failure of one or more coverage tests.  Moody's notes
that in the case of MKP CBO II more than 26% of its assets have
been the subject of ratings downgrade since Moody's last review of
the transaction in February 2009.  The trustee reports
defaulted/PIK assets in the portfolio have increased to
$27.0 million from $22.9 million since February 2009.  In
addition, the Trustee reports that the transaction is currently
failing one or more coverage tests, including the Class A
Overcollateralization Percentage Test.

The actions also take into consideration the occurrence on
February 28, 2005, as reported by the Trustee, of an Event of
Default described in Section 5.1(i) of the Indenture dated
December 20, 2001.  As provided in Article V of the Indenture
during the occurrence and continuance of an Event of Default,
certain parties to the transaction may be entitled to direct the
Trustee to take particular actions with respect to the Collateral
and the Notes, including the sale and liquidation of the assets.
The severity of losses of certain tranches may be different
depending on the timing and outcome of a liquidation.

Moody's explained that in addition to the quantitative factors
that are explicitly modeled, qualitative factors are part of the
Moody's rating committee considerations.  These qualitative
factors include but are not limited to the structural protections
in the transaction, the recent performance of the transaction in
the current market environment, how legal risks and issues are
addressed in transaction documentation, the collateral manager's
track record, and the potential for selection bias in the
portfolio.  All information available to rating committees,
including macroeconomic forecasts, input from other Moody's
analytical groups, market factors, and judgments regarding the
nature and severity of credit stress on the transactions, may
influence the final rating decision


MKP CBO: Moody's Downgrades Ratings on Two Classes of Notes
-----------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of two classes of notes issued by MKP CBO III Ltd.  The
notes affected by the rating action are:

* US$50,000,000 Class A-2 Second Priority Senior Secured Floating
  Rate Notes Due 2039, Downgraded to Ba1; previously on 3/18/2009
  Downgraded to Baa1.

* US$45,000,000 Class B Third Priority Senior Secured Floating
  Rate Notes due 2039 Downgraded to B1; previously on 3/18/2009
  Downgraded to Ba2.

MKP CBO III, Ltd., is a collateralized debt obligation backed
primarily by a portfolio of residential mortgage backed securities
and other types of assets backed securities.

The actions take into consideration the occurrence on July 24,
2009, as reported by the Trustee, of an Event of Default described
in Section 5.1(i) of the Indenture dated April 7, 2004.  The Event
of Default was declared because of the failure, on the most recent
Measurement Date, of the Class A/B Overcollateralization Ratio to
equal to or be greater than 100%.  As provided in Article V of the
Indenture during the occurrence and continuance of an Event of
Default, certain parties to the transaction may be entitled to
direct the Trustee to take particular actions with respect to the
Collateral and the Notes, including the sale and liquidation of
the assets.  The severity of losses of certain tranches may be
different depending on the timing and outcome of a liquidation.

The rating downgrade actions also reflect the continuous
deterioration in the credit quality of the underlying portfolio.
Since Moody's last review in March the trustee reported that the
Class A/B OC ratio has fallen from 108.23% to below 100% and the
WARF has increased from 770 to 949.

Moody's explained that in addition to the quantitative factors
that are explicitly modeled, qualitative factors are part of the
Moody's rating committee considerations.  These qualitative
factors include but are not limited to the structural protections
in the transaction, the recent performance of the transaction in
the current market environment, how legal risks and issues are
addressed in transaction documentation, the collateral manager's
track record, and the potential for selection bias in the
portfolio.  All information available to rating committees,
including macroeconomic forecasts, input from other Moody's
analytical groups, market factors, and judgments regarding the
nature and severity of credit stress on the transactions, may
influence the final rating decision


MLMT COMMERCIAL: Fitch Downgrades Ratings on 15 2007-C1 Certs.
--------------------------------------------------------------
Fitch Ratings has downgraded and removed from Rating Watch
Negative 15 classes of commercial mortgage pass-through
certificates from MLMT Commercial Mortgage Trust series 2007-C1.
In addition, Fitch has assigned Rating Outlooks and Recovery
Ratings, as applicable.  A detailed list of rating actions follows
at the end of this release.

The downgrades are the result of loss expectations and reflect
Fitch's prospective views regarding commercial real estate market
value and cash flow declines.  Fitch forecasts potential losses of
11.4% for this transaction should market conditions not recover.
The rating actions are based on losses of 8.3%, including 100% of
the losses associated with term defaults and any losses associated
with maturities within the next five years.  Given the significant
term to maturity, Fitch's actions only account for 25% of the
losses associated with maturities beyond five years.  The bonds
with Negative Outlooks indicate classes that may be downgraded in
the future should full potential losses be realized.

Fitch analyzed the transaction and calculated expected losses by
assuming cash flows on each of the properties decline 15% from
year-end (YE) 2007 and property values decline 35% from issuance.
These loss estimates were reviewed in more detail for certain
loans representing 62.7% of the pool and, in some cases, revised
based on additional information and/or property characteristics.

Approximately 29% of the mortgages mature within the next five
years: 0.0% in 2010, 0.0% in 2011, 17.6% in 2012, 0.0% in 2013,
and 11.2% in 2014.  In 2016 and 2017, 67.1% of the pool is
scheduled to mature.

Fitch identified 45 Loans of Concern (16.7%) within the pool, five
of which (3.7%) are specially serviced.  Of the specially serviced
loans, one (0.1%) is current.  One of the specially serviced loans
(3.2%) is within the transaction's top 15 loans (54.3%) by unpaid
principal balance.  (Note: Fitch considers the transaction's top
15 loan concentration to include the U-Haul SAC 14, 15, 16, 17
loan grouping, a portfolio of four cross-collateralized and cross
defaulted loans (3.3%), in addition to 14 other individual loans,
as ranked by unpaid principal balance.)

Four of the top 15 loans (6.6%) are expected to default or have
already defaulted during the term, with loss severities ranging
from 19.0% to 47.2%.  The largest contributors to loss are: B2
Portfolio (3.2%), Town Center at Cobb (6.9%), and DRA/Colonial
Portfolio (6.1%).

The B2 Portfolio loan (3.2%) is secured by a portfolio of 11 class
B multifamily properties comprising a total of 2,904 units.  The
properties are located across three states, including Georgia (5),
North Carolina (4), and Virginia (2).  The loan transferred to
special servicing on February 11, 2009, due to payment default.
The borrower abandoned the properties in early March 2009.  Fitch
had previously reported that many of the tenants were experiencing
difficulty in making rental payments due to high unemployment and
current economic conditions.  As of June 2009, occupancy declined
to 62%, net of evictions, compared to 86% at issuance.  To date,
the mezzanine lender has failed to exercise its cure rights under
the intercreditor agreement.  In addition to the subject loan, the
tenants-in-common obtained $26.0 million in mezzanine financing.
The loan sponsor is The Bethany Group.  The appointed receivers
and the special servicer are working to stabilize the assets.

The Town Center at Cobb loan (6.9%) is collateralized by 558,869
square feet (sf) of a 1,257,271 sf regional mall, located in
Kennesaw, GA.  Anchors include Macy's, Macy's Furniture, Sears,
Belk, and JCPenney, with only Belk included in the collateral.  As
of the March 31, 2009 rent roll, eight tenants (6.1%) were
operating on a month-to-month basis, with leases for an additional
eight tenants (2.7%) expiring in 2009.  The heaviest rollover
comes the final year of the loan term, when leases corresponding
to 32.2% of the net rentable area (including those of anchor
tenant Belk, which comprises 28.8% of the net rentable area,)
expire.  Comparable in-line sales declined approximately 12% year-
over-year as of June 30, 2009, but remained above the national
average.  The loan sponsor is Simon Property Group, Inc.  The loan
matures June 8, 2012.

The DRA/Colonial Portfolio loan is collateralized by 19 office and
retail properties (with 43 buildings) which comprise approximately
5.2 million sf and are located across six metropolitan statistical
areas: Atlanta, GA (1); Austin, TX (1); Birmingham, AL (7);
Charlotte, NC (1); Orlando, FL (6); and Tampa, FL (3).  Most of
the properties are located in tertiary markets, but are generally
in very good condition.  Occupancies at individual properties
ranged between 72.0% and 100% as of March 31, 2009.  The
portfolio-wide occupancy was 91.6% as of the same date, compared
to 93.9% at issuance.  At issuance, the loan sponsors, DRA G&I
Fund VI and Colonial Properties Trust, had approximately
$207.3 million of cash equity (28%) in the properties.  The loan
matures August 6, 2014.

Fitch has downgraded, removed from Rating Watch Negative, and
assigned Rating Outlooks or Recovery Ratings to these classes:

  -- $134.1 million class AJ to 'BB' from 'AAA'; Outlook Negative;

  -- $200 million class AJ-FL to 'BB' from 'AAA'; Outlook
     Negative;

  -- $86.1 million class B to 'BB' from 'AA'; Outlook Negative;

  -- $40.5 million class C to 'B' from 'AA-'; Outlook Negative;

  -- $45.6 million class D to 'B-' from 'A'; Outlook Negative;

  -- $45.6 million class E to 'B-' from 'A-'; Outlook Negative;

  -- $50.6 million class F to 'B-' from 'BBB+'; Outlook Negative;

  -- $40.5 million class G to 'B-' from 'BBB'; Outlook Negative;

  -- $40.5 million class H to 'B-' from 'BBB-'; Outlook Negative;

  -- $15.2 million class J to 'B-' from 'B+; Outlook Negative;

  -- $15.2 million class K to 'B-' from 'BB'; Outlook Negative;

  -- $10.1 million class L to 'B-' from 'BB-; Outlook Negative;

  -- $10.1 million class M to 'B-' from 'B+'; Outlook Negative;

  -- $10.1 million class N to 'CCC/RR6' from 'B';

  -- $5.1 million class P to 'CCC/RR6' from 'B-'.

In addition, Fitch has affirmed these classes, with a Stable
Outlook:

  -- $41.3 million class A-1 at 'AAA';
  -- $298.9 million class A-2 at 'AAA';
  -- $200 million class A-2FL at 'AAA';
  -- $322.2 million class A-3 at 'AAA';
  -- $130 million class A-3FL at 'AAA';
  -- $90.3 million class A-SB at 'AAA';
  -- $442.2 million class A-4 at 'AAA';
  -- $1.29 billion class A-1A at 'AAA';
  -- $405 million class AM at 'AAA';
  -- Interest-only class X at 'AAA'.

Fitch does not rate the $60.8 million class Q certificates.


MORGAN STANLEY: S&P Downgrades Ratings on Class M 2005-XLF Certs.
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
M commercial mortgage pass-through certificates from Morgan
Stanley Capital I Inc.'s series 2005-XLF.  Concurrently, S&P
affirmed its ratings on five other classes from this series.  In
addition, S&P removed all six ratings from CreditWatch with
negative implications, where they were placed April 7, 2009.

The lowered rating follows S&P's revaluation of the largest loan
in the pool, the Metrocenter Mall loan.  A 534,900-sq.-ft. area of
a 1.37 million-sq.-ft. super-regional mall in Phoenix secures this
loan.  The property's operating performance has weakened in the
past year.  Based on S&P's review of the borrower's operating
statements for the first three months of 2009 and for the 12
months ended December 31, 2008, its 2009 budget, and its June 30,
2009, rent roll, S&P's adjusted valuation has declined 44% since
S&P's last review dated October 11, 2007.  Occupancy has fallen to
68% from 90% since S&P's last review.

The Metrocenter Mall loan was transferred to the special servicer,
Midland Loan Services Inc. (Midland), on June 26, 2009, due to an
imminent default determination by the master servicer, also
Midland.  According to Midland, the borrower expressed difficulty
securing refinancing and is unlikely to be able to pay off the
loan by its February 9, 2010, final maturity date.  This loan has
a trust and whole-loan balance of $112.0 million (52% of the
pooled trust balance as of the July 15, 2009, trustee remittance
report).  In addition, the borrower's equity interests in the
property secure a mezzanine loan totaling $37.8 million,
$22.0 million of which has been funded to date.  The master
servicer reported a debt service coverage of 2.24x for the 12
months ended December 31, 2008.

The Waterfront Corporate Center II loan is the second-largest loan
in the pool and has a trust and whole-loan balance of
$75.0 million (34% of the pooled trust balance).  A 531,200-sq.-
ft. class A suburban office building in Hoboken, N.J., secures
this loan.  Midland reported a DSC of 3.48x for the 12 months
ended December 31, 2008, and 92% occupancy as of March 2009.
Based on S&P's review of the borrower's operating statements for
the first three months of 2009, the 12 months ended December 31,
2008, and its 2009 budget, S&P's adjusted valuation is comparable
to its last review.  The loan has a Feb. 9, 2010, final maturity
date.  According to Midland, the borrower is seeking to refinance
this loan.

The Dominion Tower loan is the remaining loan in the pool and has
a trust and whole-loan balance of $30.0 million (14% of the pooled
trust balance).  In addition, the borrower's equity interests in
the property secure a mezzanine loan totaling $19.0 million,
$12.1 million of which has been funded to date.  A 615,900-sq.-ft.
class A office building in Pittsburgh secures this loan.  Although
Midland reported a DSC of 0.0x for the 12 months ended
December  31, 2008, S&P expects the operating performance at the
property to improve.  The borrower signed new leases in mid-to-
late 2008, bringing occupancy up to 96%, as of April 2009, from
36% in S&P's last review.  The full impact of the new leases was
not reflected in the December 2008 DSC.  Based on S&P's review of
the borrower's operating statements for the first six months of
2009, the 12 months ended December 31, 2008, and its 2009 budget,
S&P's adjusted valuation is comparable to S&P's last review.  This
loan has a May 9, 2010, final maturity.  According to Midland, the
borrower has not specified its plans for paying off this loan yet.

      Rating Lowered And Removed From Creditwatch Negative

                   Morgan Stanley Capital I Inc.
   Commercial mortgage pass-through certificates series 2005-XLF

                  Rating
                  ------
    Class       To       From            Credit enhancement (%)
    -----       --       ----            ----------------------
    M           CCC-     BB/Watch Neg                      N/A

      Ratings Affirmed And Removed From Creditwatch Negative

                   Morgan Stanley Capital I Inc.
   Commercial mortgage pass-through certificates series 2005-XLF

                  Rating
                  ------
    Class       To       From            Credit enhancement (%)
    -----       --       ----            ----------------------
    G           AAA      AAA/Watch Neg                    96.53
    H           AA+      AA+/Watch Neg                    76.70
    J           A+       A+/Watch Neg                     59.68
    K           BBB+     BBB+/Watch Neg                   46.85
    L           BBB-     BBB-/Watch Neg                   29.91

                       N/A - Not applicable.


MORGAN STANLEY: S&P Withdraws 'CC+' Rating on Class IIIB Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its 'CCC+' rating on
the class IIIB notes issued by Morgan Stanley Managed ACES SPC's
Peninsula Funding series 2007-17, a synthetic collateralized debt
obligation of investment-grade corporate bonds transaction.

The rating withdrawal follows the complete redemption of the
notes, which occurred on July 31, 2009, after the noteholders
elected to redeem the notes prior to their stated maturity.

                         Rating Withdrawn

                  Morgan Stanley Managed ACES SPC
                  Peninsula Funding series 2007-17

                           Rating             Balance (mil. JPY)
                           ------             ------------------
  Class               To          From       Current      Previous
  -----               --          ----       -------      --------
IIIB                  NR          CCC+          0.00      1,000.00

                          NR - Not rated.


MOUNTAIN CAPITAL: Moody's Downgrades Ratings on Various Classes
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Mountain Capital CLO III Ltd.:

  -- US$51,000,000 Class A-1LB Notes due 2016, Downgraded A2;
     previously on March 4, 2009 Aaa Placed Under Review for
     Possible Downgrade;

  -- US$18,500,000 Class A-2L Notes due 2016, Downgraded Ba1;
     previously on March 4, 2009 Aa2 Placed Under Review for
     Possible Downgrade;

  -- US$13,500,000 Class A-3L Notes due 2016, Downgraded B2;
     previously on March 18, 2009 Downgraded to Baa3 and Placed
     Under Review for Possible Downgrade;

  -- US$6,000,000 Class A-3F Notes due 2016, Downgraded B2;
     previously on March 18, 2009 Downgraded to Baa3 and Placed
     Under Review for Possible Downgrade;

  -- US$15,000,000 Class B-1L Notes due 2016, Downgraded Ca;
     previously on March 18, 2009 Downgraded to Ba3 and Placed
     Under Review for Possible Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," the application
of certain stresses with respect to the default probabilities
associated with certain Moody's credit estimates, and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds and second lien loans will be below
their historical averages, consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, an increase in the proportion of securities
from issuers rated Caa1 and below, and failure of the Class B-1L
Overcollateralization Test.  The weighted average rating factor
has increased over the last year and is currently 2688 versus a
test level of 2400 as of the last trustee report, dated July 2,
2009.  Based on the same report, defaulted securities total about
$25 million, accounting for roughly 8% of the collateral balance,
and securities rated Caa1 or lower make up approximately 10% of
the underlying portfolio.  Moody's also assessed the collateral
pool's elevated concentration risk in debt obligations of
companies in the banking, finance, real estate, and insurance
industries, which Moody's views to be more strongly correlated in
the current market environment.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Mountain Capital CLO III Ltd., issued on May 26, 2004, is a
collateralized loan obligation, backed primarily by a portfolio of
senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


MOUNTAIN CAPITAL: Moody's Downgrades Ratings on Various Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Mountain Capital CLO IV Ltd.:

  -- US$134,000,000 Class A-1L Floating Rate Notes due 2018,
     Downgraded to Aa2; previously on December 20, 2005 Assigned
     Aaa;

  -- US$9,000,000 Class A-1LB Floating Rate Notes due 2018,
     Downgraded to Aa3; previously on March 4, 2009 Aa1 Placed
     Under Review for Possible Downgrade;

  -- US$21,000,000 Class A-2L Floating Rate Notes due 2018,
     Downgraded to A3; previously on March 4, 2009 Aa2 Placed
     Under Review for Possible Downgrade;

  -- US$12,000,000 Class B-2L Floating Rate Notes due 2018,
     Downgraded to Caa3; previously on March 18, 2009 Downgraded
     to Caa2 and Placed Under Review for Possible Downgrade.

In addition, Moody's has confirmed the ratings of these notes:

  -- US$15,000,000 Class A-3L Floating Rate Notes due 2018,
     Confirmed at Ba1; previously on March 18, 2009 Downgraded to
     Ba1 and Placed Under Review for Possible Downgrade;

  -- US$13,500,000 Class B-1L Floating Rate Notes due 2018,
     Confirmed at B1; previously on March 18, 2009 Downgraded to
     B1 and Placed Under Review for Possible Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," the application
of certain stresses with respect to the default probabilities
associated with certain Moody's credit estimates, and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
second lien loans will be below their historical averages,
consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, an increase in the proportion of securities
from issuers rated Caa1 and below, and failure of the Class B-2L
Overcollateralization Test.  The weighted average rating factor
has steadily increased over the last year and is currently 2881
versus a test level of 2600 as of the last trustee report, dated
July 2, 2009.  Based on the same report, defaulted securities
total about $21 million, accounting for roughly 7% of the
collateral balance, and securities rated Caa1 or lower make up
approximately 11% of the underlying portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Mountain Capital CLO IV Ltd., issued on December 20, 2005, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


MRU STUDENT: S&P Downgrades Ratings on Two Classes of Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class A and B notes from MRU Student Loan Trust 2007-A and removed
them from CreditWatch, where they were placed with negative
implications on February 18, 2009.

The lowered ratings reflect S&P's revised net loss expectation for
this series and the transaction's remaining credit enhancement.
Additionally, S&P believes the potential for the transaction to
generate future excess spread is remote due to failed auctions and
the elevated cost of funds of the auction rate notes.

Based on 21 months of performance since closing, the transaction's
default performance is deteriorating rapidly, and S&P projects
that overall defaults will be substantially worse than S&P
originally anticipated.  Consequently, S&P has increased its
cumulative default expectations, and now believe the trust will
likely incur at least 11% in remaining cumulative defaults, or 9%
in remaining cumulative losses (as a percentage of the current
pool balance).  In addition, defaults, delinquencies,
forbearances, and deferments are at elevated levels.  Credit
enhancement currently consists of subordination and funds in a
reserve account, as excess spread is non-existent for the reasons
described below.

Like many student loan transactions, a large percentage of the
borrowers are still in school and not making any interest or
principal payments at the outset.  During this time, loans accrue
and capitalize unpaid interest.  The structure provides for what
S&P consider a large reserve fund (a capitalized interest account)
and the use of principal collections in order to pay timely
interest on the notes during this period when the transaction is
generating little cash.  At closing, the liabilities were more
than the assets, creating undercollateralization, or parity equal
to less than 100%.  Defaults and negative excess spread have kept
parity from growing.  When S&P first rated the notes, S&P expected
the capitalizing of interest while students are in school to help
build overcollateralization.  However, S&P currently believes that
any future interest capitalization on loans not in repayment
status will likely not compensate for the amount of principal
collections reallocated to cover current interest on the notes.
Accordingly, S&P believes the degree of undercollateralization for
this trust will continue to grow.

At the time of issuance, S&P expected the weighted average coupon
on the assets, net of expenses (the net WAC), would be above the
cost of funds on the notes and would thus produce substantial
excess spread over the term of the loans (15-20 year original
repayment terms).  However, given the continued auction failures
for the auction rate notes, the transaction's maximum rate
definition during a failed auction has stepped up to the lower of
the net WAC, LIBOR plus 3.50% and 16%.  Accordingly, S&P currently
believe this maximum rate definition will cause the trust to
realize negative excess spread for the remainder of its life.
Therefore, the trust will only be able to rely on subordination
and the reserve account to cover remaining net losses, yielding
multiples of coverage that S&P deems sufficient only at the
lowered rating levels.

The transaction's payment structure includes interest
reprioritization triggers that, when breached, allow subordinate
note interest to be used to pay principal on higher classes.  S&P
believes this will benefit the class A notes.

The sponsor and administrator, MRU Holdings Inc., filed for
Chapter 7 bankruptcy on February 6, 2009.  S&P believes this adds
additional uncertainly about the transaction's future performance,
since MRU had historically taken an active role in managing late-
stage delinquencies for the trust.  S&P also believes the
borrowers and co-borrowers backing the pool of student loans will
face challenging economic conditions in the current recession that
could affect their ability to make timely payments on the loans.

           Ratings Lowered And Off Creditwatch Negative

                  MRU Student Loan Trust 2007-A

                             Rating
                             ------
                Class    To         From
                -----    --         ----
                A-1      BB-        AAA/Watch Neg
                A-2      BB-        AAA/Watch Neg
                B        CCC-       A/Watch Neg


NEW YORK STATE DORMITORY: S&P Junks Ratings on Bonds
----------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on New York
State Dormitory Authority's mortgage hospital revenue bonds series
2000 A to 'CC' from 'BBB' and removed the rating from CreditWatch
with negative implications where it was placed July 1, 2009.  The
outlook is developing.   This action follows Standard & Poor's
July 28, 2009, downgrade of Ambac Assurance Corp. to CC/Developing
from BBB/Watch Neg.

The affected issue receives partial support in the form of
guaranteed investment contracts or investment agreements from
Ambac Assurance Corp. for the debt service reserve fund.
According to current criteria, Standard & Poor's considers whether
monies deposited in the DSRF, which is generally sized in the
amount of at least six to 12 months' debt service, are invested
in investment grade securities rated 'BBB-' or higher, and will be
available to pay debt service in the event of a shortfall.
Because AMBAC is currently rated below investment grade, its
rating is no longer consistent with S&P's minimum rating level for
DSRF investments.


RACERS SERIES: Moody's Junks Ratings on 2001-12-E Trust From 'B2'
-----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded its
rating of these notes issued by RACERS Series 2001-12-E Trust:

* RACERS Series 2001-12-E Trust US$5,070,000 Notes, Downgraded to
  Ca; previously on April 8, 2009 Downgraded to B2.

The transaction is a repackaged security whose rating is based
primarily upon the transaction's structure and the credit quality
of the Deposited Asset, which consists of $6,500,000 of the PAMCO
CLO Series 1997-1 Class B Second Senior Secured Notes Due 2009.
The rating of the Deposited Asset was downgraded from Caa2 to Ca
on July 30, 2009.


RESIDENTIAL REINSURANCE: S&P Cuts Ratings on Catastrophe Bonds
--------------------------------------------------------------
Standard & Poor's Ratings Services said that it lowered its
ratings on four natural peril catastrophe bonds issued by
Residential Reinsurance 2007 Ltd.:

  -- Class 2 to 'B' from 'B+'.
  -- Class 3 to 'B-' from 'B'.
  -- Class 4 to 'BB' from 'BB+'.
  -- Class 5 to 'BB-' from 'BB+'.

Standard & Poor's also said that it removed these ratings from
CreditWatch, where they had been placed on July 20, 2009, with
negative implications.  The rating actions are consistent with
what S&P had indicated in its July 20, 2009, release.

"These downgrades reflect the adjusted probability of attachment
for each note that resulted from applying S&P's criteria to the
information S&P recently received in the annual reset reports,"
explained Standard & Poor's credit analyst Gary Martucci.  "To be
clear, the ratings actions are because of criteria and not changes
in the fundamentals of the transactions."


RYLAND MORTGAGE: Moody's Downgrades Ratings on 11 Certificates
--------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 11
certificates from eight transactions issued by Ryland Mortgage
Securities.  Six of the transactions are supported by pool
insurance policies provided by Genworth Mortgage Insurance
Corporation.

The transactions are backed by small number of loans.  Should a
default occur on any of those loans, protection from loss to the
subordinate bond is completely dependant on payments made from the
pool policy provided by Genworth Mortgage Insurance Corporation
(Baa2).  Due to the low likelihood of default given the long pay
history of the remaining borrowers, Moody's concludes that the
joint probability of default and loss given default for those
deals is consistent with a Baa1 rating.

The rating is based on the methodology applied to all transactions
with small pool factors.  Moody's defines low pool factor deals as
those that meet one of these two criteria: (1) the outstanding
collateral balance is less than $1 million, and the pool factor is
less than 5% or (2) the pool has fewer than 50 loans remaining

Moody's uses These methodology to estimate losses on low pool
factor deals

First, gross defaults are determined by applying assumed lifetime
roll-rates (probabilities of transition to default) to the
transactions' current delinquency buckets and a pipeline
multiplier.  The pipeline multiplier accounts for further possible
defaults that might arise from borrowers that are current.  The
pipeline multiplier differs for each deal based on the number of
loans remaining in the pool -- greater the number of loans
remaining the higher the multiplier.  The estimated defaults are
subject to a floor -- a minimum default.  The minimum default also
differs based on the number loans remaining in the pool.  The
fewer the number of loans remaining in the pool the higher the
minimum default since each loan represents a higher percentage of
the pool.

The final default number is then multiplied by expected loss
severity to arrive at Moody's expected loss estimate.  Loss
severity also differs by transaction and is higher for more recent
vintages.

Complete rating action:

Ryland-American Home Funding Trust 1988-1 (Loans Remaining: 13)

  -- Cl. A, Current Balance: $676,132, Downgraded to Baa1;
     previously on 8/30/1995 Upgraded to Aaa

Ryland Mortgage Securities 1990-05 (Loans Remaining: 1)

  -- Cl. B-1, Current Balance: $63,523, Downgraded to Baa1;
     previously on 12/20/1990 Assigned Aaa

  -- Cl. B-2, Current Balance: $10, Downgraded to Baa1; previously
     on 12/20/1990 Assigned Aaa

Ryland Mortgage Securities 1991-14 (Loans Remaining: 1)

  -- Cl. 14-B-1, Current Balance: $46,439, Downgraded to Baa1;
     previously on 8/29/1991 Assigned Aaa

Ryland Mortgage Securities 1991-15 (Loans Remaining: 8)

  -- Cl. B, Current Balance: $789,463, Downgraded to Baa1;
     previously on 9/29/1995 Downgraded to A3

Ryland Mortgage Securities 1991-16 (Loans Remaining: 12)

  -- Cl. B, Current Balance: $1,055,824, Downgraded to Baa1;
     previously on 9/29/1995 Downgraded to A3

  -- Cl. I, Current Balance: $184, Downgraded to Baa1; previously
     on 9/29/1995 Downgraded to A3

Ryland Mortgage Securities 1991-19 (Loans Remaining: 12)

  -- Cl. B, Current Balance: $985,015, Downgraded to Baa1;
     previously on 9/29/1995 Downgraded to A3

Ryland Mortgage Securities 1992-04 (Loans Remaining: 16)

  -- Cl. B, Current Balance: $1,592,530, Downgraded to Baa1;
     previously on 9/29/1995 Downgraded to A3

Ryland-FBS 1992-1 (Loans Remaining: 1)

  -- Cl. F, Current Balance: $215,930, Downgraded to Aa3;
     previously on 3/25/1992 Assigned Aaa

  -- Cl. M, Current Balance: $23,951, Downgraded to Ba2;
     previously on 3/25/1992 Assigned Aa1


SATURN VENTURES: Moody's Downgrades Ratings on Three Classes
------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of three classes of notes issued by Saturn Ventures I, Ltd.
The notes affected by the rating action are:

  -- Class A-1 Floating Rate Senior Notes, Downgraded at A1;
     previously on 3/6/2009 Confirmed to Aa2

  -- Class A-2 Floating Rate Senior Notes, Downgraded to B2;
     previously on 3/6/2009 Downgraded to Baa1

  -- Class A-3 Floating Rate Senior Notes, Downgraded to Ca;
     previously on 3/6/2009 Downgraded to Caa1

Saturn Ventures I, Ltd., is a collateralized debt obligation
backed primarily by a portfolio of commercial mortgage backed
securities, residential mortgage backed securities and other types
of assets backed securities.

The rating downgrade actions reflect deterioration in the credit
quality of the underlying portfolio.  Credit deterioration of the
collateral pool is observed through a decline in the average
credit rating (as measured by an increase in the weighted average
rating factor) and a failure of one or more coverage tests, among
other measures.  Moody's notes that in the case of Saturn Ventures
I more than 18% of its assets have been the subject of ratings
downgrade since Moody's last review of the transaction in March
2009.  The trustee reports the WARF of the portfolio has increased
to 981 from 391 since March 2009.  In addition, the Trustee
reports that the transaction is currently failing all of its
coverage tests.

Moody's explained that in addition to the quantitative factors
that are explicitly modeled, qualitative factors are part of the
Moody's rating committee considerations.  These qualitative
factors include but are not limited to the structural protections
in the transaction, the recent performance of the transaction in
the current market environment, how legal risks and issues are
addressed in transaction documentation, the collateral manager's
track record, and the potential for selection bias in the
portfolio.  All information available to rating committees,
including macroeconomic forecasts, input from other Moody's
analytical groups, market factors, and judgments regarding the
nature and severity of credit stress on the transactions, may
influence the final rating decision


SIGNATURE 6: Moody's Downgrades Ratings on Two Classes of Notes
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Signature 6 Limited:

  -- US$245,000,000 Class A Floating Rate Notes, Due 2016,
     Downgraded to Aa1; previously on December 18, 2001 Assigned
     Aaa;

  -- US$52,000,000 Class B Fixed Rate Notes, Due 2016, Downgraded
     to Ba3; previously on December 18, 2001 Assigned A3.

Moody's has also upgraded the ratings of these notes:

  -- US$13,000,000 Combination 2 Notes, Due 2016, Upgraded to
     Baa2; previously on October 21, 2005 Downgraded to Ba2.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," the application
of certain stresses with respect to the default probabilities
associated with certain Moody's credit estimates, and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds will be below their historical
averages, consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor calculated by Moody's), an increase in the
dollar amount of defaulted securities, and an increase in the
proportion of securities from issuers rated Caa1 and below.  The
weighted average rating factor has steadily increased over the
last year and is currently 1,163 versus a test level of 1,000 as
of the last trustee report, dated July 17,2009.  Based on the same
report, defaulted securities total about $12.4 million, accounting
for roughly 7.8% of the collateral balance.  Moody's also assessed
the collateral pool's elevated concentration risk in a small
number of obligors and industries.  This includes a significant
concentration in debt obligations of companies in the banking,
finance, real estate, and insurance industries, which Moody's
views to be more strongly correlated in the current market
environment.  Moody's also noted that the transaction is
negatively impacted by a large pay-fixed, receive-floating
interest rate swap where payments to the hedge counterparty absorb
a large portion of the excess spread in the deal.  Finally,
Moody's noted that the portfolio includes a number of investments
in securities that mature after the maturity date of the notes.
These investments potentially expose the notes to market risk in
the event of liquidation at the time of the notes' maturity.

Moody's also notes that a material proportion of the collateral
pool includes debt obligations whose credit quality has been
assessed through Moody's Credit Estimates.  Moody's analysis
reflects the application of certain stresses with respect to the
default probabilities associated with CEs.  These additional
stresses reflect the rapid pace of recent changes in credit market
conditions and the default rate expectations in the current
economic cycle that are higher than the historical averages.
Specifically, the default probability stresses include (1) a 1.5
notch-equivalent assumed downgrade for CEs updated between 12-15
months ago; and (2) assuming an equivalent of Caa3 for CEs that
were not updated within the last 15 months. Additionally, as CEs
do not carry credit indicators such as ratings reviews and
outlooks, a stress of a 0.5 notch-equivalent assumed downgrade for
CEs is also applied to CEs provided between 6-12 months ago.

In addition, Moody's notes that the rating action on the
Combination 2 Notes is the result of a paydown of the rated
balance of the notes.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Signature 6 Limited, issued in December 2001, is a collateralized
bond obligation backed primarily by a portfolio of senior secured
bonds and senior unsecured bonds.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


SIGNATURE 7: Moody's Downgrades Ratings on Three Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Signature 7 L.P.

  -- US$168,090,000 Class A Floating Rate Notes Due 2019,
     Downgraded to A3; previously on July 29, 2004 Assigned Aaa;

  -- US$15,085,000 Class B Deferrable Floating Rate Notes Due
     2019, Downgraded to B2; previously on July 29, 2004 Assigned
     A2;

  -- US$12,930,000 Class C Deferrable Floating Rate Notes Due
     2019, Downgraded to Caa3; previously on July 29, 2004
     Assigned Baa2.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook", the application
of certain stresses with respect to the default probabilities
associated with certain Moody's credit estimates, and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds will be below their historical
averages, consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor calculated by Moody's), an increase in the
dollar amount of defaulted securities, and an increase in the
proportion of securities from issuers rated Caa1 and below.  Based
on the latest trustee report dated July 17, 2009, defaulted
securities total about $13.9 million, accounting for roughly 11.5%
of the collateral balance.  Moody's also assessed the collateral
pool's elevated concentration risk in a small number of obligors
and industries.  This includes a significant concentration in debt
obligations of companies in the banking, finance, real estate, and
insurance industries, which Moody's views to be more strongly
correlated in the current market environment.  Moody's also noted
that the transaction is negatively impacted by a large pay-fixed,
receive-floating interest rate swap where payments to the hedge
counterparty absorb a large portion of the excess spread in the
deal.  Finally, Moody's noted that the portfolio includes a number
of investments in securities that mature after the maturity date
of the notes.  These investments potentially expose the notes to
market risk in the event of liquidation at the time of the notes'
maturity.

Moody's also notes that a material proportion of the collateral
pool includes debt obligations whose credit quality has been
assessed through Moody's Credit Estimates.  Moody's analysis
reflects the application of certain stresses with respect to the
default probabilities associated with CEs.  These additional
stresses reflect the rapid pace of recent changes in credit market
conditions and the default rate expectations in the current
economic cycle that are higher than the historical averages.
Specifically, the default probability stresses include (1) a 1.5
notch-equivalent assumed downgrade for CEs updated between 12-15
months ago; and (2) assuming an equivalent of Caa3 for CEs that
were not updated within the last 15 months. Additionally, as CEs
do not carry credit indicators such as ratings reviews and
outlooks, a stress of a 0.5 notch-equivalent assumed downgrade for
CEs is also applied to CEs provided between 6-12 months ago.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

Signature 7 L.P., issued in July of 2004, is a collateralized debt
obligation backed primarily by a portfolio of senior unsecured
bonds, senior secured bonds, and senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


SIGNUM VERMILION: Moody's Downgrades Ratings on 2007-1 Notes
------------------------------------------------------------
Moody's Investors Service announced that it has downgraded these
notes issued by Signum Vermilion Ltd. Series 2007-1, a synthetic
collateralized debt obligation transaction referencing a portfolio
of corporate entities.

Moody's explained that the rating action taken is the result of
the deterioration in the credit quality of the reference
portfolio.  According to Moody's, the reference pool has suffered
a downward credit rating migration greater than what had been
anticipated by its forward looking measures in its February rating
action.  The reference portfolio includes but is not limited to
exposures to Ambac Financial Group, Inc. and CIT Group Inc. which
have experienced substantial credit migration in the past few
months.  Both are rated Ca as of the date of this rating action.

Moody's continues to monitor this transaction using primarily the
methodology and its supplements for Corporate Synthetic CDOs as
described in Moody's Special Reports below:

-- Moody's Approach to Rating Corporate Collateralized Synthetic
    Obligations (April 2009)

The rating action is:

  -- Current Rating: B2
  -- Prior Rating Action: downgrade to Baa3 from Aa1
  -- Prior Rating Action Date: February 5, 2009


ST JAMES: Moody's Downgrades Ratings on Various Classes of Notes
----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by St. James River CLO, Ltd:

  -- US$50,000,000 Class A-R First Priority Senior Secured
     Floating Rate Revolving Notes Due 2021, Downgraded to Aa2;
     previously on July 12, 2007 Assigned Aaa;

  -- US$255,500,000 Class A-T First Priority Senior Secured
     Floating Rate Term Notes Due 2021, Downgraded to Aa2;
     previously on July 12, 2007 Assigned Aaa;

  -- US$27,500,000 Class B Second Priority Senior Secured Floating
     Rate Notes Due 2021, Downgraded to A3; previously on March 4,
     2009 Aa2 Placed Under Review for Possible Downgrade.

Moody's has also confirmed the ratings of these notes:

  -- US$15,500,000 Class C Third Priority Senior Secured
     Deferrable Floating Rate Notes Due 2021, Confirmed at Ba1;
     previously on March 13, 2009 Downgraded to Ba1 and Placed
     Under Review for Possible Downgrade;

  -- US$15,500,000 Class D Fourth Priority Mezzanine Secured
     Deferrable Floating Rate Notes Due 2021, Confirmed at B1;
     previously on March 13, 2009 Downgraded to B1 and Placed
     Under Review for Possible Downgrade;

  -- US$16,000,000 Class E Fifth Priority Mezzanine Secured
     Deferrable Floating Rate Notes Due 2021, Confirmed at Caa2;
     previously on March 13, 2009 Downgraded to Caa2 and Placed
     Under Review for Possible Downgrade.

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds and second lien loans will be below
their historical averages, consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured by the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, an increase in the proportion of securities
from issuers rated Caa1 and below, and failure of the Class E
overcollateralization test.  The weighted average rating factor
has increased over the last year and is currently 2685 versus a
test level of 2475 as of the last trustee report, dated July 2,
2009.  Based on the same report, defaulted securities total about
$4.3 million, accounting for roughly 1.1% of the collateral
balance, and securities rated Caa1 or lower by Moody's or CCC+ or
lower by S&P make up approximately 10.4% of the underlying
portfolio.

Due to the impact of all aforementioned stresses, key model inputs
used by Moody's in its analysis, such as par, weighted average
rating factor, and weighted average recovery rate, may be
different from the trustee's reported numbers.

St.  James River CLO, Ltd., issued in July 2007, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


STARTS LTD: S&P Withdraws 'B+' Rating on Series 2007-30 Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its rating on the
notes issued by STARTS (Cayman) Ltd.'s series 2007-30, a synthetic
corporate investment-grade collateralized debt obligation
transaction.

The rating withdrawal follows the repurchase of the notes
according to the repurchase notice dated August 3, 2009.

                         Rating Withdrawn

                        STARTS (Cayman) Ltd.
                Maple Hill II managed synthetic CDO

                                         Rating
                                         ------
              Series          Class    To      From
              ------          -----    --      ----
              2007-30         B3-J3    NR      B+

                         NR - Not rated.


STRAITS GLOBAL: Moody's Downgrades Ratings on Two Classes
---------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of two classes of notes issued by Straits Global ABS CDO
I, Limited.  The notes affected by the rating action are:

* US$248,000,000 Class A-1 First Priority Senior Secured Floating
  Rate Notes Due 2040, Downgraded to Caa3; previously on 2/4/2009
  Baa3

* US$72,000,000 Class A-2 Second Priority Senior Secured Floating
  Rate Notes Due 2040, Downgraded to Ca; previously on 2/4/2009
  Caa2

Straits Global ABS CDO I, Limited is a collateralized debt
obligation backed primarily by a portfolio of of residential
mortgage backed securities consisting of approximately 65% of the
outstanding portfolio, of which the majority are from 2004
vintage.

The rating downgrade actions reflect deterioration in the credit
quality of the underlying portfolio.  Credit deterioration of the
collateral pool is observed through a decline in the average
credit rating (as measured by the weighted average rating
factor(WARF), an increase in the dollar amount of defaulted
securities, and an increase in the proportion of securities rated
Caa1 and below, among other measures.  More than 50% of its assets
have been downgraded since Moody's last review of the transaction
in February 2009.  The trustee reported the WARF of the portfolio
is 1619 as of July 10, 2009.  The Trustee currently reports
defaulted assets in the amount of $66.9million. Securities rated
Caa1 or lower make up approximately 53% of the underlying
portfolio.  The deal is currently failing a variety of coverage
tests including the Class A/B Overcollateralization Test.

The actions also take into consideration the occurrence on May 7,
2008, as reported by the Trustee, of an Event of Default described
in Section 5.1 (i) of the Indenture dated October 28, 2004.  As
provided in Article V of the Indenture during the occurrence and
continuance of an Event of Default, certain parties to the
transaction may be entitled to direct the Trustee to take
particular actions with respect to the Collateral and the Notes,
including the sale and liquidation of the assets.  The severity of
losses of certain tranches may be different depending on the
timing and outcome of a liquidation.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


TBW ALT-A: Moody's Corrects Ratings on Seven Tranches
-----------------------------------------------------
Moody's Investors Service has corrected the ratings of 7 tranches
from 2 TBW Alt-A transactions.  Previously, certain loss and
principal allocation features of the transactions were not
accurately accounted for.  Ratings have been adjusted to reflect
that, for both transactions, losses will not be allocated to
certain senior certificates, and distribution of principal to
those tranches will continue sequentially even after depletion of
subordinate certificates.  The actions listed below reflect
Moody's updated expected losses on the transaction.

The rating actions for the securities are:

Issuer: TBW Mortgage-Backed Trust Series 2006-4

Current pool expected loss: 21% of original balance

  -- Cl. A-2, Upgraded to Aaa; previously on 2/20/2009 Downgraded
     to B3

  -- Cl. A-3, Upgraded to A3; previously on 2/20/2009 Downgraded
     to Caa2

  -- Cl. A-4, Upgraded to Ba3; previously on 2/20/2009 Downgraded
     to Caa2

  -- Cl. A-6, Downgraded to Ca; previously on 2/20/2009 Downgraded
     to Caa2

Issuer: TBW Mortgage-Backed Trust Series 2006-5

Current pool expected loss: 19% of original balance

  -- Cl. A-2-A, Upgraded to Aaa; previously on 2/20/2009
     Downgraded to A1

  -- Cl. A-2-B, Upgraded to Aaa; previously on 2/20/2009
     Downgraded to A1

  -- Cl. A-3, Upgraded to Baa3; previously on 2/20/2009 Downgraded
     to Ba3

The collateral backing these transactions consists primarily of
first-lien, fixed-rate, Alt-A mortgage loans.  Moody's final
rating actions are based on current ratings, level of credit
enhancement, collateral performance and updated pool-level loss
expectations relative to current level of credit enhancement.
Moody's took into account credit enhancement provided by
seniority, cross-collateralization, excess spread, time tranching,
and other structural features within the senior note waterfalls.

Loss estimates are subject to variability and are sensitive to
assumptions used; as a result, realized losses could ultimately
turn out higher or lower than Moody's current expectations.
Moody's will continue to evaluate performance data as it becomes
available and will assess the pattern of potential future defaults
and adjust loss expectations accordingly as necessary.

The ratings on the notes were assigned by evaluating factors
determined to be applicable to the credit profile of the notes,
such as i) the nature, sufficiency, and quality of historical
performance information regarding the asset class as well as for
the transaction sponsor, ii) an analysis of the collateral, iii)
an analysis of the policies, procedures and alignment of interests
of the key parties to the transaction, most notably the originator
and the servicer, iv) an analysis of the transaction's allocation
of collateral cashflow and capital structure, v) an analysis of
the transaction's governance and legal structure, and (vi) a
comparison of these attributes against those of other similar
transactions.


TIERS BRISBANE: Moody's Downgrades Ratings on 2007-34 Notes
-----------------------------------------------------------
Moody's Investors Service announced that it has downgraded these
notes issued by TIERS Brisbane Floating Rate Credit Linked Trust,
Series 2007-34, a synthetic collateralized debt obligation
transaction referencing a portfolio of corporate loans (a
"Corporate Synthetic CDO").

Moody's explained that the rating action taken is the result of
the downgrade of the insurance financial strength rating of Ambac
Assurance Corporation, which acts as Guarantor under the
Investment Agreement in the transaction.  On July 29, 2009, the
insurance financial strength rating of Ambac Assurance Corporation
was downgraded to Caa2 from Ba3.  A default of Ambac Assurance
Corporation under the swap is an additional termination event.
Under an additional termination event, a swap termination payment
potentially due to Citibank acting as buyer under the credit
default swap would be paid senior to the noteholders claim.

Moody's initially analyzed and continues to monitor this
transaction using primarily the methodology for Corporate
Synthetic CDOs and for collateralized loan obligations as
described in Moody's Special Report below:

  -- Moody's Approach to Rating Corporate Collateralized Synthetic
     Obligations (April 2009)

  -- Moody's Approach to Rating Collateralized Loan Obligations
     (December 2008)

The rating action is:

Class Description: US$75,000,000 Floating Rate Credit Linked Trust

  -- Current Rating: Caa3

  -- Prior Rating Action Date: 05/05/2009

  -- Prior Rating Action: Downgrade to B2 from Baa2 on watch for
     possible downgrade


VERMEER FUNDING: Moody's Downgrades Ratings on Two Classes
----------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of two classes issued by Vermeer Funding, Limited.  The
notes affected by the rating action are:

  -- Class A-1 Senior Secured Floating Rate Notes, Due 2039,
     Downgraded to A3; previously on 12/22/2008 Downgraded to Aa2
     Placed Under Review for Possible Downgrade

  -- Class A-2 Senior Secured Floating Rate Notes, Due 2039,
     Downgraded to Ba1; previously on 3/20/2009 Downgraded to Baa2

Vermeer Funding, Limited is a collateralized debt obligation
backed primarily by a portfolio of Residential ABS Securities.
RMBS are approximately 53% of the underlying portfolio, of which
the majority are from 2004 vintage.

The rating downgrade actions reflect deterioration in the credit
quality of the underlying portfolio due to the recent actions
taken upon seasoned (pre-2005) RMBS.  Credit deterioration of the
collateral pool is observed through a decline in the average
credit rating (as measured by an increase in the weighted average
rating factor), an increase in the dollar amount of defaulted
securities, and an increase in the proportion of securities from
issuers rated Caa1 and below.  More than 30% of the underlying
assets have been downgraded since Moody's last review of the
transaction in March 2009.  The trustee reports that the WARF of
the portfolio is 1,377 as of June 30, 2009, and also reports
defaulted assets in the amount of $25.6 million.  Securities rated
Caa1 or lower make up approximately 23.4% of the underlying
portfolio.  The Class A/B and Class C Overcollateralization Tests
are currently failing.

The actions also take into consideration the risk of the
transaction experiencing an Event of Default.  As provided in
Article V of the Indenture during the occurrence and continuance
of an Event of Default, certain parties to the transaction may be
entitled to direct the Trustee to take particular actions with
respect to the Collateral and the Notes, including the sale and
liquidation of the assets.  The severity of losses of certain
tranches may be different depending on the timing and outcome of a
liquidation.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


WACHOVIA BANK: S&P Affirms Ratings on Six 2005-WHALE5 Certs.
------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on six
classes of commercial mortgage pass-through certificates from
Wachovia Bank Commercial Mortgage Trust's series 2005-WHALE5 and
removed them from CreditWatch with negative implications, where
they were placed on April 7, 2009.

The rating actions reflect S&P's revaluation of the remaining loan
in the pool.  S&P does, however, have concerns regarding the
borrower's ability to refinance before the upcoming January 2010
final maturity.

The remaining loan in the pool, the Lightstone Pool 2 loan, is
secured by a 580,300-sq.-ft. regional mall in Lake Jackson, Texas,
and a 322,200-sq.-ft. regional mall in Shawnee, Oklahoma.  This
loan has a whole-loan balance of $39.1 million that consists of an
intrust senior participation interest of $29.7 million (as of the
July 15, 2009, trustee remittance report) and a nontrust
subordinate junior participation interest of $9.4 million.  The
borrower's equity interests in the properties secure a
$7.5 million mezzanine loan.

Standard & Poor's used the borrower's operating statements for the
trailing 12-months ended June 30, 2009, and its 2009 budgets to
derive an adjusted valuation that is comparable to S&P's last
review dated December 3, 2008.  The master servicer, Wachovia Bank
N.A. (Wachovia), reported a combined debt service coverage of
2.43x for the 12 months ended December 31, 2008, and a combined
occupancy of 80% as of April 2009.  According to Wachovia, the
borrower stated that it intends to refinance or sell the
properties before the loan's January 9, 2010, final maturity date.
If the borrower is unable to pay off the loan, the loan would be
transferred to the special servicer, also Wachovia.  Wachovia
indicated that any special servicing and/or workout fees related
to this loan will be absorbed by the subordinate junior
participation interest before affecting the rated certificates.

      Ratings Affirmed And Removed From Creditwatch Negative

              Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2005-WHALE5

                  Rating
                  ------
    Class       To       From            Credit enhancement (%)
    -----       --       ----            ----------------------
    J           AAA      AAA/Watch Neg                    74.54
    K           A        A/Watch Neg                      36.29
    L           BB       BB/Watch Neg                       N/A
    X-1B        AAA      AAA/Watch Neg                      N/A
    X-1C        AAA      AAA/Watch Neg                      N/A
    X-2         AAA      AAA/Watch Neg                      N/A

                       N/A - Not applicable.


WESTWOOD CDO: Moody's Downgrades Ratings on Various Classes
-----------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Westwood CDO I, Ltd.:

  -- US$342,000,000 Class A-1 Senior Secured Floating Rate Notes
     due 2021, Downgraded to A1; previously on January 16, 2007
     Assigned Aaa;

  -- US$22,500,000 Class A-2 Senior Secured Floating Rate Notes
     due 2021, Downgraded to Baa2; previously on March 4, 2009 Aa2
     Placed Under Review for Possible Downgrade;

  -- US$30,000,000 Class B Senior Secured Deferrable Floating Rate
     Notes due 2021, Downgraded to Ba3; previously on March 13,
     2009, Downgraded to Ba1 and Placed Under Review for Possible
     Downgrade;

  -- US$16,600,000 Class C-1 Senior Secured Deferrable Floating
     Rate Notes due 2021, Downgraded to Caa3; previously on March
     13, 2009, Downgraded to B1 and Placed Under Review for
     Possible Downgrade;

  -- US$4,400,000 Class C-2 Senior Secured Deferrable Fixed Rate
     Notes due 2021, Downgraded to Caa3; previously on March 13,
     2009, Downgraded to B1 and Placed Under Review for Possible
     Downgrade;

  -- US$13,500,000 Class D Secured Deferrable Floating Rate Notes
     due 2021, Downgraded to C; previously on March 13, 2009,
     Downgraded to Caa2 and Placed Under Review for Possible
     Downgrade;

  -- US$14,700,000 Type I Composite Notes due 2021, Downgraded to
     Ca; previously on March 4, 2009 Baa2 Placed Under Review for
     Possible Downgrade;

  -- US$6,500,000 Type II Composite Notes due 2021, Downgraded to
     Ca; previously on March 4, 2009 Baa2 Placed Under Review for
     Possible Downgrade;

According to Moody's, the rating actions taken on the notes are a
result of credit deterioration of the underlying portfolio.  The
actions also reflect Moody's revised assumptions with respect to
default probability, the treatment of ratings on "Review for
Possible Downgrade" or with a "Negative Outlook," and the
calculation of the Diversity Score.  The revised assumptions that
have been applied to all corporate credits in the underlying
portfolio are described in the press release dated February 4,
2009, titled "Moody's updates key assumptions for rating CLOs."
Moody's analysis also reflects the expectation that recoveries for
high-yield corporate bonds and second lien loans will be below
their historical averages, consistent with Moody's research.

Credit deterioration of the collateral pool is observed through a
decline in the average credit rating (as measured through the
weighted average rating factor), an increase in the dollar amount
of defaulted securities, an increase in the proportion of
securities from issuers rated Caa1 and below, and failure of the
Over Collateralization Ratio Tests for the Class C Notes and the
Class D Notes.  The weighted average rating factor has steadily
increased over the last year and it is currently at 2871 as of the
last trustee report, dated July 27, 2009.  Based on the same
report, defaulted securities total about 32.7 million, accounting
for roughly 7.4% of the collateral balance, and securities rated
Caa1 or lower make up approximately 11% of the underlying
portfolio.  Additionally, interest payment on the Class D Notes is
presently being deferred as a result of the failure of the
Overcollateralization Ratio Test for the Class C Notes.

Westwood CDO I, Ltd., issued in January 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of the rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, specific
documentation features, the collateral manager's track record, and
the potential for selection bias in the portfolio.  All
information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.


* S&P Puts Ratings on 29 Tranches on CreditWatch Negative
---------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on 29
tranches from 20 U.S cash flow and hybrid collateralized debt
obligation transactions on CreditWatch with negative implications.
The CreditWatch placements follow S&P's monthly review of U.S.
cash flow and hybrid CDO transaction performance.

As in prior months, most of the transactions with ratings S&P
placed on CreditWatch negative are CDOs backed by corporate loans.
Of the affected transactions, 19 of the 20 (or 95%) are CDOs
backed by corporate loans.  The other transaction is a
collateralized bond obligation transaction.  The affected tranches
had a total issuance amount of $890.84 million.

The CreditWatch placements follow S&P's most recent monthly review
of U.S. cash flow and hybrid CDO performance.  The rationale for
the rating actions is based on both quantitative and qualitative
performance parameters, including transaction structural features,
manager purchase patterns, and a broad view of the underlying
collateral within each transaction, including these:

* A change in Standard & Poor's rated overcollateralization
  metric.  S&P reviews this ratio monthly based on current
  collateral ratings, and it provides an estimate of the stability
  of the current rating on a given cash flow CDO tranche;

* A decline in the credit quality of the performing assets within
  the collateral pools, including negative rating migration of the
  underlying securities to ratings in the 'CCC' range;

* A change in the proportion of securities in the collateral pool
  with ratings on CreditWatch negative, which serves as a forward-
  looking indicator of rating actions that will affect the assets
  in the pools;

* A decrease in the level of overcollateralization available to
  support each tranche since origination, or since S&P's last
  rating action.  Many of the affected CLO transactions have
  experienced declines in their O/C ratios as a result of defaults
  or rating-based "haircuts" for the calculation of par coverage
  tests.  This may cause some transactions to begin breaching
  mezzanine O/C ratio tests that would cut off subordinate classes
  from receiving current interest; and

* An increase in the level of defaulted assets held in the CDO
  transactions' portfolios.

S&P will resolve the CreditWatch placements after S&P complete a
comprehensive cash flow analysis for each of the affected
transactions, and after S&P evaluate additional information S&P
may receive during discussions with the relevant collateral
managers.  S&P expects to resolve these CreditWatch placements
within 90 days.  Standard & Poor's will continue to monitor the
CDO transactions it rates and take rating actions, including
CreditWatch placements, as S&P deems appropriate.

              Ratings Placed On Creditwatch Negative

                                                         Rating
                                                         ------
Transaction                                 Class To               From
-----------                                 ----- --               ----
Ares Enhanced Loan Investment Strategy II   B-1   A/Watch Neg      A
Ares Enhanced Loan Investment Strategy II   B-2   A/Watch Neg      A
Babson CLO Ltd 2003-I                       D     BBB-/Watch Neg   BBB-
Babson Mid-Market CLO Ltd 2007-II           C     A/Watch Neg      A
Callidus Debt Partners CDO Fund I           A-2   AAA/Watch Neg    AAA
Callidus Debt Partners CDO Fund I           A-3   AAA/Watch Neg    AAA
Callidus Debt Partners CLO Fund II          C-1   BBB/Watch Neg    BBB
Callidus Debt Partners CLO Fund II          C-2   BBB/Watch Neg    BBB
Callidus Debt Partners CLO Fund III         D     BBB/Watch Neg    BBB
Fairway Loan Funding Company                B-1L  BBB/Watch Neg    BBB
First Dominion Funding III                  B-1   AAA/Watch Neg    AAA
First Dominion Funding III                  B-2   AAA/Watch Neg    AAA
GSC Capital Corp Loan Funding 2005-1        C     AA/Watch Neg     AA
GSC Partners CDO Fund VII Ltd               B     AA/Watch Neg     AA
Gulf Stream-Compass CLO 2002-I, Ltd         C     A-/Watch Neg     A-
Gulf Stream-Compass CLO 2002-I, Ltd         D     BB+/Watch Neg    BB+
Gulf Stream-Compass CLO 2002-I, Ltd         E     B-/Watch Neg     B-
Katonah VIII CLO Limited                    C     A/Watch Neg      A
Katonah VIII CLO Limited                    D     BBB-/Watch Neg   BBB-
Latitude CLO III Ltd.                       D     A/Watch Neg      A
Limerock CLO I                              A-4   AA/Watch Neg     AA
Marquette US/European CLO, P.L.C.           D-1   BBB/Watch Neg    BBB
Marquette US/European CLO, P.L.C.           D-2   BBB/Watch Neg    BBB
Nantucket CLO I Ltd                         E     BB/Watch Neg     BB
Pacifica CDO II Ltd.                        B-1   A-/Watch Neg     A-
Pacifica CDO II Ltd.                        B-2   A-/Watch Neg     A-
Pro Rata Funding Ltd.                       B     A-/Watch Neg     A-
SPF CDO I, Ltd.                             B     AA/Watch Neg     AA
Stanfield Daytona CLO, Ltd.                 B-2L  BB/Watch Neg     BB


* S&P Rakes Rating Actions on 10 Emerging Market Transactions
-------------------------------------------------------------
Standard & Poor's Ratings Services took these rating actions on 10
emerging market transactions:

* S&P lowered its ratings on seven emerging market asset-backed
  future flow transactions and removed them from CreditWatch with
  negative implications, were they were placed June 25, 2009;

* S&P lowered its global scale and Mexican national scale ratings
  on two Mexican residential mortgage-backed securities
  transactions and removed them from CreditWatch negative, were
  they were placed June 25, 2009; and

* S&P made public its global scale issue rating and Standard &
  Poor's underlying rating on one Mexican ABS transaction, and the
  SPUR on one Mexican RMBS transaction, at the issuers' request.
  These transactions benefit from an insurance policy provided by
  Ambac Assurance Corp. ('CC' insurer financial enhancement
  rating).

At the same time, S&P's 'mxAA' Mexican national scale (CaVal)
rating on one Mexican ABS transaction remains on CreditWatch
negative, where it was placed June 25, 2009.

S&P's previous ratings on 10 of the affected securitizations were
based on the full financial guarantee insurance policy that Ambac
provides, which guarantees the timely payment of interest and
principal according to the respective transaction's terms.

Under S&P's criteria, the issue rating on an insured bond reflects
the higher of the rating on the bond insurer (monoline) or the
SPUR on the securities.  As a result, S&P lowered its ratings
on nine Ambac-insured transactions and kept S&P's rating on one
Ambac-insured transaction on CreditWatch negative to reflect the
corresponding SPUR on the transactions rather than S&P's 'CC'
insurer financial enhancement rating on Ambac.  The SPURs on the
affected series reflect the securitizations' performance and
credit quality.

These rating actions follow the July 28, 2009, lowering of S&P's
insurer financial enhancement rating on Ambac to 'CC' from 'BBB'
and S&P's assignment of a developing outlook on Ambac.

At the issuers' request, S&P has made public its global scale
issue rating and SPUR on Hipotecaria Su Casita - Bursatilizaciones
de Creditos Puente II's Mexican ABS series HSCCB 06 transaction,
and the SPUR on Patrimonio - Bursatilizaciones de Hipotecas
Residenciales' Mexican RMBS series PATRICB O7U transaction. The
ratings on these notes reflect the transactions' underlying credit
quality.

S&P will continue to surveil the ratings on these transactions and
revise them as necessary to reflect any changes in the
transactions' underlying credit quality.  S&P's analysis regarding
the effect of these rating actions is ongoing.

      Ratings Lowered And Removed From Creditwatch Negative

         Akbank Remittances Trust Securitization (Akbank)

                                     Rating
                                     ------
            Series/tranche    To                   From
            --------------    --                   ----
                    11        BBB-                 BBB/Watch Neg
                    13        BBB-                 BBB/Watch Neg
                    20        BBB-                 BBB/Watch Neg

     Patrimonio - Bursatilizaciones de Hipotecas Residenciales

                               Rating
                               ------
     Series/tranche     To                   From
     --------------     --                   ----
     PATRICB 06U        BBB-                 BBB/Watch Neg
     PATRICB 06U        mxAA-                mxAA/Watch Neg
     PATRICB 07U        BBB-                 BBB/Watch Neg
     PATRICB 07U        mxAA-                mxAA/Watch Neg

          Garanti Diversified Payment Rights Finance Co.
                    (Turkiye Garanti Bankasi)

                                Rating
                                ------
       Series/tranche    To                   From
       --------------    --                   ----
       2007-A            BBB-                 BBB/Watch Neg

       TIB Diversified Payment Rights Finance Co. (Isbank)

                                Rating
                                ------
       Series/tranche    To                   From
       --------------    --                   ----
       2004-B            BBB-                 BBB/Watch Neg

                  VB DPR Finance Co. (Vakifbank)

                                Rating
                                ------
       Series/tranche    To                   From
       --------------    --                   ----
       2006-D            BBB-                 BBB/Watch Neg

         Yapi Kredi Diversified Payment Rights Finance Co.

                                Rating
                                ------
       Series/tranche    To                   From
       --------------    --                   ----
       2006-D            BBB-                 BBB/Watch Neg

             Ratings Made Public At Issuer's Request

Hipotecaria Su Casita - Bursatilizaciones de Creditos Puente II

               Series/tranche  Rating
               --------------  ------
               HSCCB 06        BBB/Watch Neg
               HSCCB 06        BBB/Watch Neg (SPUR)

    Patrimonio - Bursatilizaciones de Hipotecas Residenciales

                 Series/tranche     Rating
                 --------------     ------
                 PATRICB 07U        BBB- (SPUR)

              Rating Remains On Creditwatch Negative

Hipotecaria Su Casita - Bursatilizaciones de Creditos Puente II

                Series/tranche      Rating
                --------------      ------
                HSCCB 06            mxAA/Watch Neg



                           *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers'
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Wednesday's edition of the TCR. Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com/

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

For copies of court documents filed in the District of Delaware,
please contact Vito at Parcels, Inc., at 302-658-9911.  For
bankruptcy documents filed in cases pending outside the District
of Delaware, contact Ken Troubh at Nationwide Research &
Consulting at 207/791-2852.

                           *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors' Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Frederick, Maryland,
USA.  Danilo Munnoz, Joseph Medel C. Martirez, Denise Marie
Varquez, Philline Reluya, Ronald C. Sy, Joel Anthony G. Lopez,
Cecil R. Villacampa, Sheryl Joy P. Olano, Carlo Fernandez,
Christopher G. Patalinghug, and Peter A. Chapman, Editors.

Copyright 2009.  All rights reserved.  ISSN: 1520-9474.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.  Information contained
herein is obtained from sources believed to be reliable, but is
not guaranteed.

The TCR subscription rate is $775 for 6 months delivered via e-
mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Christopher
Beard at 240/629-3300.

                  *** End of Transmission ***