TCR_Public/091108.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

            Sunday, November 8, 2009, Vol. 13, No. 309

                            Headlines



ABS CAPITAL: Moody's Downgrades Ratings on Two Classes of Notes
AIRCRAFT CERTIFICATE: Moody's Downgrades Ratings on 2003-A Certs.
ALTERNATIVE LOAN: S&P Downgrades Ratings on Two 2006-37R Certs.
ALTERNATIVE LOAN: S&P Downgrades Ratings on Four 2007-HY5R Certs.
ALTERNATIVE LOAN: S&P Downgrades Ratings on 14 2007-26R Certs.

BANC OF AMERICA: Moody's Reviews Ratings on 16 2007-3 Loans
BANC OF AMERICA: S&P Downgrades Ratings on 21 2008-LS1 Securities
BANC OF AMERICA: S&P Junks Ratings on 2007-R1 Class A-2 Certs.
BEAR STEARNS: S&P Downgrades Ratings on 17 2007-BBA8 Certificates
BEAR STEARNS: S&P Downgrades Ratings on Two 2007-R6 Certificates

BLACKROCK SENIOR: Moody's Downgrades Ratings on Various Classes
C-BASS CBO: Fitch Downgrades Ratings on Four Classes of Notes
CAF ABS: S&P Downgrades Ratings on Medium-term Notes to 'B'
CALIFORNIA COLLEGE: Moody's Affirms Rating on 2001 & 2005 Bonds
CMBSPOKE 2005-III: Moody's Assigns Provisional Ratings on Notes

CREDIT SUISSE: Moody's Reviews Ratings on 14 2005-C4 Certificates
CREDIT SUISSE: S&P Downgrades Ratings on Eight 2008-2R Certs.
DELPHINUS CDO: Macquarie Bank Deal Won't Affect Fitch's Ratings
FORD CREDIT: Moody's Downgrades Ratings on 2006-4 Floorplan Notes
GENWORTH FINANCIAL: Moody's Downgrades Ratings on $750 Mil. Notes

HASTINGS: S&P Gives Stable Outlook on Bonds; Keeps 'BB+' Rating
ILLINOIS STUDENT: Fitch Downgrades Ratings on Student Loans
MADISON AVENUE: Moody's Downgrades Ratings on Two Classes of Notes
MASTR ADJUSTABLE: S&P Junks Ratings on Two 2007-R5 Certificates
ML-CFC COMMERCIAL: S&P Downgrades Ratings on 2007-9 Securities

MORGAN STANLEY: Moody's Downgrades Rating on 2007-10 Notes to 'B2'
MORGAN STANLEY: Moody's Downgrades Rating on 2006-18 Notes
PEGASUS AVIATION: Moody's Reviews Ratings on Three Securitizations
PETER COOPER: Fitch Downgrades Ratings on 19 Classes
RBSSP RESECURITIZATION: Moody's Puts Ratings on 2009-11 Securities

RESTRUCTURED ASSET: Moody's Downgrades Ratings on 2006-14-E Certs.
RESIDENTIAL ASSET: S&P Downgrades Ratings on Three 2007-R1 Certs.
RESIDENTIAL ASSET: S&P Downgrades Ratings on Two 2006-R1 Certs.
RESIDENTIAL MORTGAGE: Moody's Downgrades Rating on 2008-2 Notes
RFC CDO: Fitch Downgrades Ratings on Eight Classes of Notes

SAN JOAQUIN HILLS: Moody's Affirms 'Ba2' Rating on Two Bonds
SOLOSO CDO: Moody's Downgrades Ratings on Five Classes of Notes
SOLOSO CDO: Moody's Downgrades Ratings on Various 2005-1 Notes
SOLSTICE ABS: Fitch Takes Rating Actions on Various Classes
STRIPS CDO: S&P Puts Note Ratings on CreditWatch Developing

SWIFT MASTER: Moody's Confirms Ratings on Various Floorplan Notes
TRAINER WORTHAM: Fitch Downgrades Ratings on Three Classes
TIERS FLOATING: Moody's Junks Ratings on 2006-12 Certs. From 'B2'
TOURO INFIRMARY: Moody's Reviews 'Ba1' Long-Term Bond Rating
TRICADIA CDO: S&P Downgrades Ratings on Three 2004-2 Notes

TROPIC CDO: Moody's Downgrades Ratings on Four Classes of Notes
TROPIC CDO: Moody's Downgrades Ratings on Various Classes of Notes
TROPIC CDO: Moody's Downgrades Ratings on Four Classes of Notes
TROPIC CDO: Moody's Downgrades Ratings on Five Classes of Notes
TROPIC CDO: Moody's Reviews Ratings on Three Classes of Notes

WACHOVIA BANK: Moody's Reviews Ratings on 10 2005-C21 Certs.
WACHOVIA BANK: S&P Downgrades Ratings on 19 2006-C28 Securitiess

* Fitch Puts Ratings on 58 Classes From 13 CRE CDOs on Neg. Watch
* S&P Downgrades Ratings on 26 Classes From Nine RMBS Transactions
* S&P Downgrades Ratings on 28 Classes From Three CDOs to 'D'
* S&P Downgrades Ratings on 42 Classes From 22 RMBS Transactions
* S&P Downgrades Ratings on 361 Tranches From 140 CDO Transactions



                            *********

ABS CAPITAL: Moody's Downgrades Ratings on Two Classes of Notes
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of two classes of Notes issued by ABS Capital Funding II,
Ltd.  The Notes affected by the rating action are:

  -- US$20,000,000 Class A-2 Floating Rate Term Notes, Due
     2037, Downgraded to Caa1; previously on February 4, 2009
     Downgraded to Ba2;

  -- US$10,000,000 Class 1 Combination Notes, Due 2037,
     Downgraded to Ba1; previously on February 4, 2009 Downgraded
     to Baa3.

ABS Capital Funding II, Ltd. is a collateralized debt obligation
backed primarily by a portfolio of residential mortgage backed
securities and other types of asset 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).  Moody's notes that in the case of ABS Capital
Funding II, more than 50% of its assets have been the subject of
ratings downgrade since Moody's last review of the transaction in
February 2009.  All the OC tests have been failing their trigger
levels and have been deteriorating.  In the latest trustee report
WARF was 1356 as compared to a WARF of 1119 as reported in the
January trustee report.  Defaults currently total $52,730,754,
which comprises about 1/3 of the current portfolio.

The action also takes into consideration the risk of the
transaction experiencing an Event of Default.  An Event of Default
may occur due to a Missed Interest payment on any Class A Note or
a failure to maintain the Aggregate Principal Balance of the
Collateral Debt Securities and Eligible Investments plus Principal
Proceeds and Uninvested Proceeds held as Cash and Eligible
Investments purchased wit Principal Proceeds or Uninvested
Proceeds at least equal to 100% of the Aggregate Outstanding
Amount of the Class A Notes.  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


AIRCRAFT CERTIFICATE: Moody's Downgrades Ratings on 2003-A Certs.
-----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded its
ratings on Notes and Certificates issued by Aircraft Certificate
Owner Trust 2003-A.

The complete rating action is:

Issuer: Aircraft Certificate Owner Trust 2003-A

  -- Class D, Downgraded to Ba3; previously on Mar 6, 2009 Baa1
     Placed Under Review for Possible Downgrade

  -- Class E, Downgraded to Ba3; previously on Mar 6, 2009 Baa1
     Placed Under Review for Possible Downgrade

  -- Certificates, Downgraded to Ba3; previously on Mar 6, 2009
     Baa1 Placed Under Review for Possible Downgrade

The Aircraft Certificate Owner Trust Notes and Certificates are
backed by debt issued under three Enhanced Equipment Trust
Certificate transactions.  The Underlying EETC Debt have been
issued by three separate pass through trusts, the obligations of
which are secured by leases and loans to US Airways on various
Airbus planes.  Each of the Underlying EETC Debt is also supported
by an insurance policy issued by MBIA (rated B3).  As the ratings
of the Underlying EETC Debt have been downgraded to Ba3, Moody's
has downgraded the Aircraft Certificate Owner Trust Notes and
Certificates accordingly.


ALTERNATIVE LOAN: S&P Downgrades Ratings on Two 2006-37R Certs.
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on two
classes of certificates from Alternative Loan Trust
Resecuritization 2006-37R, a U.S. residential mortgage-backed
securities re-securitized real estate mortgage investment conduit
transaction.  S&P lowered its ratings on classes A-1 and A-2 to
'CCC' from 'AAA'.

The downgrades reflect the significant deterioration in
performance of the loans backing the underlying certificates.
This performance deterioration is so severe that the credit
enhancement for CWALT 2006-37R is insufficient to maintain the
ratings on the re-REMIC classes.

CWALT 2006-37R, which closed in October 2006, is collateralized by
two underlying classes that support both classes within the re-
REMIC.  The loans securing the two underlying classes consist
predominately of fixed-rate Alternative-A mortgage loans.

The class A-1 and A-2 certificates from CWALT 2006-37R are
supported by classes 1-A-3 and 1-A-4 from Alternative Loan Trust
2006-4CB (both currently rated 'CCC').  The performance of the
loans securing this trust has declined precipitously in recent
months.  This pool had experienced losses of 1.09% as of the
October 2009 distribution, and currently has approximately 23.78%
in delinquent loans.  Based on the losses to date, the current
pool factor of 0.6262 (62.62%), which represents the outstanding
pool balance as a proportion of the original balance, and the
pipeline of delinquent loans, S&P's current projected loss for
this pool is 9.61%, which exceeds the level of credit enhancement
available to cover losses.

Over the past two years, S&P has revised its RMBS default and loss
assumptions, and consequently S&P's projected losses, to reflect
the continuing decline in mortgage loan performance and the
housing market.  The performance deterioration of most U.S. RMBS
has continued to outpace the market's expectation.

                          Ratings Lowered

         Alternative Loan Trust Resecuritization 2006-37R
                          Series 2006-37R

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-1        02147UAA1     CCC                  AAA
        A-2        02147UAB9     CCC                  AAA


ALTERNATIVE LOAN: S&P Downgrades Ratings on Four 2007-HY5R Certs.
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
classes of certificates from Alternative Loan Trust
Resecuritization 2007-HY5R, a U.S. residential mortgage backed
securities re-securitized real estate mortgage investment conduit
transaction.  S&P lowered its rating on class 2-A-1A to 'B' from
'AAA', and S&P lowered its ratings on classes 2-A-1B, 2-A-1C, and
2-A-1D to 'B-' from 'AAA'.

The downgrades reflect the significant deterioration in the
performance of the loans backing the underlying certificate.  This
performance deterioration is so severe that the credit enhancement
for CWALT 2007-HY5R is insufficient to maintain the ratings on the
re-REMIC classes.

CWALT 2007-HY5R, which closed in March 2007, is collateralized by
one underlying class that supports the four classes within the re-
REMIC.  The loans securing the underlying class, consist
predominately of long-reset adjustable-rate Alternative-A mortgage
loans.

The classes from CWALT 2007-HY5R are supported by class 2-A-1 from
Alternative Loan Trust 2007-HY3 (currently rated 'B-').  The
performance of the loans securing this trust has declined
precipitously in recent months.  This pool had experienced losses
of 2.47% as of the October 2009 distribution date, and it
currently has approximately 32.50% in delinquent loans.  Based on
the losses to date, the current pool factor of 0.7435 (74.35%),
which represents the outstanding pool balance as a proportion of
the original balance, and the pipeline of delinquent loans, S&P's
current projected loss for this pool is 13.41%, which exceeds the
level of credit enhancement available to cover losses.

Over the past two years S&P has revised its RMBS default and loss
assumptions, and consequently S&P's projected losses, to reflect
the continuing decline in mortgage loan performance and the
housing market.  The performance deterioration of most U.S. RMBS
has continued to outpace the market's expectation.

                          Ratings Lowered

         Alternative Loan Trust Resecuritization 2007-HY5R

                                         Rating
                                         ------
        Class       CUSIP         To                  From
        -----       -----         --                  ----
        2-A-1A      02150WAA1     B                   AAA
        2-A-1B      02150WAB9     B-                  AAA
        2-A-1C      02150WAC7     B-                  AAA
        2-A-1D      02150WAD5     B-                  AAA


ALTERNATIVE LOAN: S&P Downgrades Ratings on 14 2007-26R Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 14
classes of certificates from Alternative Loan Trust
Resecuritization 2007-26R, a U.S. residential mortgage-backed
securities re-securitized real estate mortgage investment conduit
transaction.

The downgrades reflect the significant deterioration in the
performance of the loans backing the underlying certificates.
This performance deterioration is so severe that the credit
enhancement for ALT 2007-26R is insufficient to maintain the
ratings on the re-REMIC classes.

ALT 2007-26R, which closed in December 2007, is collateralized by
two underlying classes that support all classes within the re-
REMIC.  The loans securing the two underlying classes consist
predominately of fixed-rate Alternative-A mortgage loans.

All of the classes from ALT 2007-26R are supported by the 2-A-1
and 2-A-2 classes from Alternative Loan Trust 2006-39CB (both
currently rated 'CCC').  The performance of the loans securing
this trust has declined precipitously in recent months.  This pool
had experienced losses of 2.38% as of the October 2009
distribution date, and it currently has approximately 33.25% in
delinquent loans.  Based on the losses to date, the current pool
factor of 0.6983 (69.83%), which represents the outstanding pool
balance as a proportion of the original balance, and the pipeline
of delinquent loans, S&P's current projected loss for this pool is
14.89%, which exceeds the level of credit enhancement available to
cover losses.

Over the past two years S&P has revised its RMBS default and loss
assumptions, and consequently its projected losses, to reflect the
continuing decline in mortgage loan performance and the housing
market.  The performance deterioration of most U.S. RMBS has
continued to outpace the market's expectations.

                          Ratings Lowered

         Alternative Loan Trust Resecuritization 2007-26R

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-1        02152JAA8     CCC                  AAA
        A-2        02152JAB6     CC                   AAA
        A-3        02152JAD2     CCC                  AAA
        A-4        02152JAE0     CCC                  AAA
        A-5        02152JAF7     CCC                  AAA
        A-6        02152JAG5     CCC                  AAA
        A-7        02152JAH3     CCC                  AAA
        A-8        02152JAJ9     CCC                  AAA
        A-9        02152JAK6     CC                   AAA
        A-10       02152JAL4     CC                   AAA
        A-11       02152JAM2     CC                   AAA
        A-12       02152JAN0     CC                   AAA
        A-13       02152JAP5     CC                   AAA
        A-14       02152JAQ3     CC                   AAA


BANC OF AMERICA: Moody's Reviews Ratings on 16 2007-3 Loans
-----------------------------------------------------------
Moody's Investors Service placed 16 classes of Banc of America
Commercial Mortgage Trust 2007-3 on review for possible downgrade,
including three super-senior Aaa-rated classes, due to higher
expected losses for the pool resulting from losses from loans in
special servicing and concerns about the decline in performance of
several loans on the master servicer's watchlist.

Moody's has included Classes A-4, A-5 and A-1A in the review
because these classes have the longest weighted average life among
the super senior Aaa classes with 30% initial credit support.
Depending on the magnitude, severity, and timing of losses from
specially serviced loans and the balance of the pool, along with
any loan payoffs, sequential paydowns may not reach these classes.
At the same time, losses are likely to erode the credit
enhancement cushion for the super senior classes creating a
potential differential in expected loss between those super senior
classes benefiting first from paydowns and those classes receiving
paydowns last.  Although Moody's believe that it is unlikely that
Classes A-4, A-5 and A-1A will actually experience losses, the
expected level of credit enhancement and their priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

The rating action is the result of Moody's on-going surveillance
of commercial mortgage backed securities transactions.

As of the October 13, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$3.51 billion from $3.52 billion at securitization.  The
Certificates are collateralized by 151 mortgage loans ranging in
size from less than 1% to 9% of the pool, with the top ten loans
representing 52% of the pool.

The pool has not realized any losses since securitization.
Currently 21 loans, representing 20% of the pool, are in special
servicing.  Three of the pool's top 10 loans are in special
servicing, including One Park Avenue ($187.5 million -- 5%),
Second & Seneca ($175.0 million -- 5%) and Rockwood Ross
Multifamily ($175.0 million -- 5%).  Each of these loans is
current or within its respective grace period, but property
performance has been below original projections.  The special
servicer has recognized a $68.3 million aggregate appraisal
reduction for four of the smaller specially serviced loans.

Twenty three loans, representing 22% 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.  Not all loans on the
watchlist are delinquent or have significant issues.

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

Moody's rating action is:

  -- Class A-4, $1,017,000,000, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 8/23/2007

  -- Class A-5, $50,000,000, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 8/23/2007

  -- Class A-1A, $646,979,662, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 8/23/2007

  -- Class A-M, $116,565,000, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 8/23/2007

  -- Class A-MF, $100,000,000, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 8/23/2007

  -- Class A-MFL, $135,000,000, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 8/23/2007

  -- Class A-J, $241,701,000, currently rated A2, on review for
     possible downgrade; previously assigned at A2 on 2/11/2009

  -- Class B, $35,157,000, currently rated A3, on review for
     possible downgrade; previously assigned at A3 on 2/11/2009

  -- Class C, $48,340,000, currently rated Baa1, on review for
     possible downgrade; previously assigned at Baa1 on 2/11/2009

  -- Class D, $26,368,000, currently rated Baa2, on review for
     possible downgrade; previously assigned at Baa2 on 2/11/2009

  -- Class E, $26,367,000, currently rated Baa3, on review for
     possible downgrade; previously assigned at Baa3 on 2/11/2009

  -- Class F, $35,157,000, currently rated Ba1, on review for
     possible downgrade; previously assigned at Ba1 on 2/11/2009

  -- Class G, $30,762,000, currently rated Ba2, on review for
     possible downgrade; previously assigned at Ba2 on 2/11/2009

  -- Class H, $48,340,000, currently rated B1, on review for
     possible downgrade; previously assigned at B1 on 2/11/2009

  -- Class J, $35,156,000, currently rated B2, on review for
     possible downgrade; previously assigned at B2 on 2/11/2009

  -- Class K, $43,946,000, currently rated B3, on review for
     possible downgrade; previously assigned at B3 on 2/11/2009


BANC OF AMERICA: S&P Downgrades Ratings on 21 2008-LS1 Securities
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 21
classes of commercial mortgage-backed securities from Banc of
America Commercial Mortgage Loan Trust 2008-LS1 and removed them
from CreditWatch with negative implications.  In addition, S&P
affirmed S&P's ratings on five classes from the same transaction.

The downgrades follow S&P's analysis of the transaction using
S&P's U.S. conduit and fusion CMBS criteria, which was the primary
driver of the rating actions.  The downgrades of the subordinate
and mezzanine classes also reflect credit support erosion S&P
anticipate will occur upon the eventual resolution of several
specially serviced loans.  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 1.25x and a loan-to-value ratio
of 123.9%.  S&P further stressed the loans' cash flows under S&P's
'AAA' scenario to yield a weighted average DSC of 0.76x and an LTV
of 179.6%.  The implied defaults and loss severity under the 'AAA'
scenario were 93.6% and 47.3%, respectively.  All of the DSC and
LTV calculations noted above exclude six ($37.5 million, 1.6%) of
the 12 specially serviced loans.  S&P separately estimated losses
for these loans, which are included in S&P's 'AAA' scenario
implied default and loss figures.

The affirmation of the ratings on the principal and interest
certificates reflects subordination levels that adequately support
the outstanding ratings.  S&P affirmed S&P's rating on the class
XW interest-only certificates based on S&P's current criteria.
S&P published a request for comment proposing changes to S&P's IO
criteria on June 1, 2009.  After S&P finalizes S&P's criteria
review, S&P may revise S&P's IO criteria, which may affect
outstanding ratings, including the rating on the IO certificates
that S&P affirmed.

                         Credit Concerns

As of the October 2009 remittance report, 12 loans ($98.6 million,
4.2%) in the pool are with the special servicer, LNR Partners Inc.
The specially serviced loans by payment status are: one is real
estate owned ($3.6 million, 0.2%); two are in foreclosure
($19.7 million, 0.8%); five are more than 90 days delinquent
($60.9 million, 2.6%); one is 30 days delinquent ($2.0 million,
0.1%); one is in its grace period ($4.5 million, 0.2%); and two
are current ($7.9 million, 0.3%).  Six of the specially serviced
loans have appraisal reduction amounts in effect totaling
$17.2 million.

The Hyatt on Capitol Hill loan, the largest loan with the special
servicer, is secured by a 400-room hotel in Columbus, Ohio, with a
total exposure of $32.8 million (1.4%).  The loan was transferred
to LNR on Aug. 4, 2009, for payment default.  The borrower also
failed to establish a clearing account and enter into a cash
management agreement as required under the loan documents.  The
loan is more than 90 days delinquent.  For the trailing 12 months
ended June 30, 2009, the reported DSC was 0.15x, down from 1.19x
at year-end 2008.  The special servicer is negotiating a
restructuring of the loan with the borrower.

The remaining specially serviced loans have balances that
individually represent less than 0.7% of the total pool balance.

                       Transaction Summary

As of the October 2009 remittance report, the collateral pool
consisted of 238 loans with an aggregate trust balance of
$2.34 billion, which represents approximately 99.6% of the trust
balance at issuance.  No loans have paid off or have been
liquidated since issuance.  The master servicer for the
transaction, Bank of America N.A., provided financial information
for 99.2% of the pool; 98.7% of the financial information was
full-year 2008 data or interim-2009 data.  S&P calculated a
weighted average DSC of 1.29x for the pool based on the reported
figures.  S&P's adjusted DSC and LTV were 1.25x and 123.9%,
respectively.  S&P's adjusted DSC and LTV figures exclude six
($37.5 million, 1.6%) of the 12 specially serviced loans for which
S&P separately estimated losses.  Bank of America provided DSC
figures for four of these six loans, and based on these figures,
S&P calculated a weighted average DSC of 1.01x.  Fifty-eight loans
(27.0%) are on Bank of America's watchlist, including six of the
top 10 loans.  Forty-three loans ($392.2 million, 16.8%) have a
reported DSC of less than 1.10x, and 35 of these loans
($324.4 million, 13.9%) have a reported DSC of less than 1.0x.

                     Summary of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$679.4 million (29.1%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.30x for the top 10 loans.
Six of the top 10 loans ($300.7 million, 12.9%) appear on Bank of
America's watchlist.  S&P's adjusted DSC and LTV for the top 10
loans are 1.17x and 137.9%, respectively.  The three largest loans
on Bank of America's watchlist are discussed below.

The Hallmark Building loan is the third-largest loan in the pool
and the largest loan on the master servicer's watchlist due to low
DSC.  The loan is current and has a trust balance of $64.0 million
(2.7%).  The loan is secured by a 305,347-sq.-ft. office building
in Dulles, Virginia.  The reported net cash flow DSC was 1.00x and
occupancy was 78.7% for the trailing six months ended June 30,
2009, down from 1.13x and 87.1%, respectively, at year-end 2008.
The reported net operating income DSC for the trailing six months
ended June 30, 2009, and year-end 2008 were 1.07x and 1.20x,
respectively.

The Boulder Green Office and Industrial Portfolio loan is the
fourth-largest loan in the pool and the second-largest loan on the
master servicer's watchlist.  The loan appears on the watchlist
due to the Nov. 30, 2009, lease expiration of Northrup Grumman,
which occupies 22% of net rentable area.  The loan is current and
has a trust balance of $62.0 million (2.6%).  The loan is secured
by a portfolio of six single-tenant properties comprising 666,797
sq. ft in five states (Utah, Indiana, Texas, Kansas, and New
Hampshire) that are cross-collateralized and cross-defaulted.  For
the trailing six months ended June 30, 2009, the reported DSC for
the portfolio was 1.38x and the occupancy was 100%.  The year-end
2008 DSC was 1.55x and the occupancy was 100%.  Per the master
servicer, Northrop Grumman has renewed its lease for an additional
three years.  The new lease expiration date is Sept. 30, 2012.

The Memphis and Orlando Industrial Portfolio loan is the fifth-
largest loan in the pool.  The loan is composed of two crossed
loans, the Memphis Industrial Portfolio loan (Memphis loan) and
the Orlando Industrial Portfolio loan (Orlando loan).  Only the
Orlando loan is on the master servicer's watchlist due to low DSC.
The Orlando loan consists of three industrial complexes totaling
307,927 sq. ft within two distinct submarkets in Orlando, Fla.
The Orlando loan is current and has a trust balance of
$24.8 million (1.1%).  For the trailing six months ended June 30,
2009, the reported DSC was 0.84x and the occupancy was 73.4%, down
from 1.16x and 86.7%, respectively, at year-end 2008.  The
reported DSC for the Portfolio loan for the trailing six months
ended June 30, 2009, was 1.11x and the occupancy was 76.2%, down
from 1.22x and 94.8%, respectively, at year-end 2008.

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

      Ratings Lowered And Removed From Creditwatch Negative

     Banc of America Commercial Mortgage Loan Trust 2008-LS1
          Commercial mortgage pass-through certificates

           Rating
           ------
     Class     To     From            Credit enhancement (%)
     -----     --     ----            ----------------------
     A-4B      A      AAA/Watch Neg                    33.12
     A-4BF     A      AAA/Watch Neg                    33.12
     A-1A      A      AAA/Watch Neg                    33.12
     A-SM      A-     AAA/Watch Neg                    30.11
     A-M       BBB-   AAA/Watch Neg                    20.07
     A-J       BB+    AAA/Watch Neg                    15.81
     B         BB     AA+/Watch Neg                    14.43
     C         BB-    AA/Watch Neg                     13.17
     D         B+     AA-/Watch Neg                    12.17
     E         B+     A+/Watch Neg                     11.16
     F         B+     A/Watch Neg                      10.04
     G         B+     A-/Watch Neg                      9.03
     H         B      BBB+/Watch Neg                    7.78
     J         B      BBB/Watch Neg                     6.52
     K         B      BBB-/Watch Neg                    5.27
     L         B-     BB+/Watch Neg                     4.89
     M         B-     BB/Watch Neg                      4.52
     N         B-     BB-/Watch Neg                     4.14
     O         B-     B+/Watch Neg                      3.89
     P         B-     B/Watch Neg                       3.51
     Q         CCC+   B-/Watch Neg                      3.01

                        Ratings Affirmed

     Banc of America Commercial Mortgage Loan Trust 2008-LS1
          Commercial mortgage pass-through certificates

            Class     Rating    Credit enhancement (%)
            -----     ------    ----------------------
            A-1       AAA                        33.12
            A-2       AAA                        33.12
            A-3       AAA                        33.12
            A-4A      AAA                        33.12
            XW        AAA                          N/A

                       N/A - Not applicable.


BANC OF AMERICA: S&P Junks Ratings on 2007-R1 Class A-2 Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
A-2 certificate from Banc of America Funding 2007-R1 Trust, a U.S.
residential mortgage-backed securities resecuritized real estate
mortgage investment conduit transaction.  S&P lowered its rating
on class A-2 to 'CCC' from 'AAA'.  At the same time, S&P affirmed
its 'AAA' rating on class A-1.

The downgrade reflects the significant deterioration in
performance of the loans backing the underlying certificates.
Although this performance deterioration is severe, because class
A-2 provides additional credit enhancement to class A-1, the
credit enhancement within BAF 2007-R1 is sufficient to maintain
the rating on class A-1.

BAF 2007-R1, which closed in September 2007, is collateralized by
two underlying classes that support both classes within the re-
REMIC.  The loans securing the two underlying classes, which are
from a single trust, consist predominantly of long-reset
adjustable-rate Alternative-A mortgage loans.

The A-1 and A-2 classes from BAF 2007-R1 are supported by the
class A-1 and A-3 certificates from Countrywide Home Loans
Alternative Loan Trust 2007-HY6 (both currently rated 'CCC').  The
performance of the loans securing this trust has declined
precipitously in recent months.  This pool had experienced losses
amounting to 5.35% of the original balance as of the September
2009 distribution, and delinquent loans total approximately 48.18%
of the current pool balance.  Based on the losses to date, the
current pool factor of 0.7626 (76.26%), which represents the
outstanding pool balance as a proportion of the original balance,
and the pipeline of delinquent loans, S&P's current projected loss
for this pool is 24.34%, which exceeds the level of credit
enhancement available to cover losses to the A-2 class of the re-
REMIC.

Over the past two years, S&P has revised its RMBS default and loss
assumptions, and consequently S&P's projected losses, to reflect
the continuing decline in mortgage loan performance and the
housing market.  The performance deterioration of most U.S. RMBS
has continued to outpace the market's expectations.

                          Rating Lowered

               Banc of America Funding 2007-R1 Trust

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-2        05953BAB7     CCC                  AAA

                          Rating Affirmed

              Banc of America Funding 2007-R1 Trust

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        05953BAA9     AAA


BEAR STEARNS: S&P Downgrades Ratings on 17 2007-BBA8 Certificates
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 17
classes of commercial mortgage pass-through certificates from Bear
Stearns Commercial Mortgage Securities Trust 2007-BBA8, a U.S.
commercial mortgage backed securities transaction.  Concurrently,
S&P affirmed its ratings on 10 classes from the same transaction.
S&P removed all 27 ratings from CreditWatch with negative
implications, where S&P placed them on April 7, 2009.

S&P based its downgrades on its revised valuations for the
remaining assets, which averaged 24% below S&P's valuations at
issuance.  Based on S&P's analysis of the hotel collateral, the
revenue per available room for many of the hotel properties has
declined substantially in 2009.  Many of the office properties are
experiencing higher vacancies and lower rents than at issuance.

S&P affirmed its ratings on the interest-only certificates based
on its 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.

Standard & Poor's rates two pooled loans that are raked to the
"MS" and "PH" certificates.  S&P lowered and affirmed its ratings
on these raked certificates.  Details of the loans backing these
classes are:

The Meristar Portfolio loan has a whole-loan balance of
$284.5 million that consists of a $47.9 million senior pooled
component and a $236.6 million subordinate nonpooled component
that is raked to the "MS" certificates.  In addition, the
borrower's equity interests in the property secure a mezzanine
loan totaling $249.3 million.  The whole-loan balance reflects
$550.5 million (66% of the whole-loan balance) in paydowns since
issuance due to collateral releases.  The remaining collateral
includes a portfolio of 11 full-service hotels with a total of
4,048 rooms in six states and the District of Columbia.  Overall
occupancy for the remaining collateral was 71% as of the trailing-
12-months (TTM) through June 2009.  Based on Standard & Poor's
review of the borrower's operating statements for the TTM ended
June 30, 2009, and its 2009 budget, S&P's adjusted valuation for
this loan has declined by 16% since issuance.  The loan matures in
May 2010 and has one 12-month extension option available.

The Prime Hospitality Portfolio loan has a whole-loan balance of
$141.6 million that consists of a $99.3 million senior pooled
component, a $16.4 million subordinate nonpooled component that is
raked to the "PH" certificates, and a $25.9 million junior
participation that is held outside of the trust.  In addition, the
borrower's equity interests in the property secure a mezzanine
loan totaling $36.0 million.  The whole-loan balance reflects
$33.8 million (19% of the whole-loan balance) in paydowns since
issuance due to collateral releases.  The remaining collateral
includes a portfolio of 14 full-service, limited-service, and
extended-stay hotels with a total of 1,954 rooms in three states.
Overall occupancy for the remaining collateral was 65% as of the
TTM through June 2009.  Based on Standard & Poor's review of the
borrower's operating statements for the TTM ended June 30, 2009,
and its 2009 budget, S&P's adjusted valuation for this loan has
declined by 29% since issuance.  The loan matures in May 2010 and
has one 12-month extension option available.

The Le Meridien Dallas loan is the one loan in the pool that is
with the special servicer, Bank of America N.A.  (Bank of
America).  It was transferred to Bank of America on April 9, 2009,
due to imminent default.  This loan has a whole-loan balance of
$32.0 million, which is divided into a $20.7 million senior
participation interest (2% of the pooled trust balance) and a
$11.3 million junior nonpooled participation interest.  The hotel
was slated to be reflagged to a Le Meridien Dallas from a Prava
Suites by late 2007; however, the conversion project was not
completed until April 2009.  The master servicer, also Bank of
America, reported a negative net cash flow for the property for
the 12 months ended Dec. 31, 2008.  The loan was 60 days
delinquent as of the Oct. 15, 2009, remittance report.  Standard &
Poor's expects a moderate loss upon the resolution of this loan.

                    Summary of Hotel Properties

Hotel properties secure eight loans totaling $722.7 million (73%
of the pool trust balance).  S&P based its hotel analysis on a
review of the borrowers' operating statements for the six months
ended June 30, 2009, and the year ended Dec. 31, 2008, as well as
their 2009 budgets.  The lodging collateral performance has been
significantly affected by the reduction in business and leisure
travel.  In its analysis, S&P factored in its assumption that
average 2009 RevPAR in the industry would decline between 14% and
16% and considered local lodging market conditions.  The details
of S&P's lodging forecast can be found in "Standard & Poor's
Lowers Its 2009 And Publishes Its 2010 RevPAR Assumptions In the
U.S. Lodging Industry," published April 16, 2009, on
RatingsDirect.  Highlights of these loans are: The Felcor Lodging
Trust, the second-largest hotel loan in the pool, has a trust
balance of $96.2 million (10% of the pool trust balance) and a
whole-loan balance of $250.0 million.  The loan is secured by 12
full-service hotels with a total of 2,930 rooms in eight states.
Overall occupancy for the portfolio was 68% as of the TTM through
June 2009.  The loan matures in November 2010 and has one 12-month
extension option available.  Based on Standard & Poor's review of
the borrower's operating statements for the TTM ended June 30,
2009, and its 2009 budget, S&P's adjusted valuation for this loan
has declined by 23% since issuance.  The Ashford MIP Portfolio,
the third-largest hotel loan in the pool, has a trust balance of
$92.2 million (9% of the pool trust balance) and a whole-loan
balance of $203.4 million.  The whole-loan balance reflects
$15.6 million (7% of the whole-loan balance) in paydowns since
issuance due to the release of one property.  The remaining
collateral includes a portfolio of five full-service hotels with a
total of 1,447 rooms in four states.  Overall occupancy for the
portfolio was 64% as of the TTM through June 2009.  The loan
matures in December 2009 and has two 12-month extension options
available.  Based on Standard & Poor's review of the borrower's
operating statements for the TTM ended June 30, 2009, and its 2009
budget, S&P's adjusted valuation for this loan has declined by 27%
since issuance.

The Larkspur Hotel Portfolio, the fourth-largest hotel loan in the
pool, has a trust and whole-loan balance of $51.5 million (5% of
the pool trust balance).  The loan is secured by five full-service
hotels with a total of 623 rooms in California and Oregon.
Overall occupancy for the portfolio was 67% as of the TTM through
June 2009.  The loan matures in February 2010 and has two 12-month
extension options available.  Based on Standard & Poor's review of
the borrower's operating statements for the TTM ended June 30,
2009, and its 2009 budget, S&P's adjusted valuation for this loan
has declined by 56% since issuance.

                   Summary of Office Properties

Office properties secure five loans (25% of the pool trust
balance).  S&P based its analysis on a review of the borrowers'
most recent operating statements as well as their 2009 budgets.
Highlights of these loans are:

The Westcore Colorado Portfolio is the largest loan secured by
office properties and the fourth-largest loan in the pool.  The
loan has a trust balance of $80.2 million (8% of the pool trust
balance) and a whole-loan balance of $152.5 million.  The whole-
loan balance reflects $31.3 million (17% of the whole-loan
balance) in paydowns since issuance due to collateral releases.
The remaining collateral includes a portfolio of 14 class A/B
suburban/flex office properties and one industrial property
totaling 1.2 million sq. ft. in Colorado.  The master servicer
reported a debt service coverage of 4.08x for the year-ended
Dec. 31, 2008, and occupancy of 78% as of June 2009.  The loan
matures in November 2009 and has two 12-month extension options
available.  Standard & Poor's valuation for this loan declined 31%
since issuance, primarily due to a decline in occupancy.

The 980 Madison Avenue loan is the second-largest loan secured by
an office property and the fifth-largest loan in the pool.  The
$80.0 million whole loan is split into a senior pooled trust
balance of $62.5 million (8%) and a $17.5 million nonpooled
subordinate component that supports the "MA" raked certificates,
which Standard & Poor's does not rate.  The loan is secured by a
six-story, 119,400-sq.-ft. class A office building in Manhattan.
The master servicer reported a DSC of 2.64x for the year-ended
Dec. 31, 2008, and occupancy of 92% as of June 2009.  The loan
matures in October 2010 and has one 12-month extension option
remaining.  Standard & Poor's valuation for this loan has declined
45% since issuance, primarily due to a decline in rents.
The Thanksgiving Tower is the third-largest loan secured by an
office property and the sixth-largest loan in the pool.  The loan
has a trust balance of $58.5 million (6% of the pool trust
balance) and a whole-loan balance of $75.9 million.  The loan is
secured by a 1.36-million-sq.-ft. office building in Dallas,
Texas.  The master servicer reported a DSC of 2.50x for the year-
ended Dec. 31, 2008, and occupancy of 55% as of June 2009.  The
loan matures in March 2010 and has two 12-month extension options
remaining.  Standard & Poor's valuation for this loan has declined
41% since issuance.

                       Transaction Summary

According to the Oct. 15, 2009, remittance report, pool statistics
are:

There are 14 loans in the pool including four whole loans, the
pari passu piece of one A/B loan, the pari passu piece of one
whole loan, the senior interest of eight participated whole loans,
and the subordinate unpooled interests of four of these loans.
All of the loans are indexed to one-month LIBOR.

Near-term maturities (within the next three months and not
discussed above) for the loans in the pool are:

The Embassy Suites loan, the ninth-largest loan in the pool, has a
trust and whole-loan balance of $31.0 million (3% of the pooled
trust balance).  In addition, the borrower's equity interests in
the properties secure a mezzanine loan totaling $30.0 million.
The loan is secured by a full-service, 288-room hotel in downtown
Philadelphia, Pa.  The loan matures on Dec. 12, 2009.  The
borrower has not given notice that it will extend the loan, which
has two 12-month extension options remaining.  Bank of America
reported a 3.93x DSC for the 12 months ending Dec. 31, 2009.
S&P's adjusted valuation for this loan has fallen 14% since
issuance.

The CarrAmerica Portfolio loan, the smallest loan in the pool, has
a trust balance of $11.6 million (1%) and a whole-loan balance of
$27.0 million.  The whole loan consists of two $11.6 million pari
passu senior components and two $1.9 million pari passu junior
components.  This transaction includes an $11.6 million senior
component and a $1.9 million junior component that secures the
"CA" certificates, which S&P does not rate.  The remaining
components outside the trust were included in the COMM 2007-FL14
CMBS transaction.  One property was released, thus reducing the
whole-loan amount to $27.0 million from $70.0 million.  The
remaining collateral includes two office/flex buildings in
Sunnyvale and Mountain View, Calif.  comprising 297,081 sq. ft.
The master servicer reported a DSC of 5.12x for the year ended
Dec. 31, 2008, and a 55% occupancy as of June 2009.  The loan
matures in January 2010 and has two 12-month extension options
remaining.  The borrower has not given notice that it will extend
the loan.  Standard & Poor's valuation for this loan has declined
50% since issuance.

       Ratings Lowered And Removed From Creditwatch Negative

    Bear Stearns Commercial Mortgage Securities Trust 2007-BBA8
           Commercial mortgage pass-through certificates

        Class   To     From          Credit enhancement (%)
        -----   --     ----          ----------------------
        A-2     AA+    AAA/Watch Neg                  41.91
        B       AA-    AAA/Watch Neg                  36.22
        C       BBB+   AA+/Watch Neg                  30.53
        D       BB+    AA/Watch Neg                   24.84
        E       BB     A+/Watch Neg                   18.89
        F       BB-    A/Watch Neg                    15.27
        G       B+     A-/Watch Neg                   11.90
        H       B      BBB+/Watch Neg                  9.32
        J       CCC+   BBB/Watch Neg                   6.58
        K       CCC-   BBB-/Watch Neg                  3.10
        L       CCC-   BBB-/Watch Neg                  0.00
        MS-5    BBB-   BBB/Watch Neg                    N/A
        MS-6    BB     BBB-/Watch Neg                   N/A
        MS-7    BB-    BB+/Watch Neg                    N/A
        PH-1    CCC-   BB+/Watch Neg                    N/A
        PH-2    CCC-   BB/Watch Neg                     N/A
        PH-3    CCC-   BB-/Watch Neg                    N/A

                       N/A - Not Applicable.

     Ratings Affirmed And Removed From Creditwatch Negative

   Bear Stearns Commercial Mortgage Securities Trust 2007-BBA8
          Commercial mortgage pass-through certificates

        Class   To     From          Credit enhancement (%)
        -----   --     ----          ----------------------
        A-1     AAA    AAA/Watch Neg                  83.18
        X-1B    AAA    AAA/Watch Neg                    N/A
        X-2     AAA    AAA/Watch Neg                    N/A
        X-4     AAA    AAA/Watch Neg                    N/A
        X-2M    AAA    AAA/Watch Neg                    N/A
        MS-1    AA+    AA+/Watch Neg                    N/A
        MS-2    AA     AA/Watch Neg                     N/A
        MS-3    A+     A+/Watch Neg                     N/A
        MS-4    BBB+   BBB+/Watch Neg                   N/A
        MS-X    AA+    AA+/Watch Neg                    N/A

                       N/A - Not Applicable.


BEAR STEARNS: S&P Downgrades Ratings on Two 2007-R6 Certificates
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class I-A-1and II-A-1 certificates from Bear Stearns Structured
Products Inc. Trust 2007-R6, a U.S. residential mortgage re-
securitized real estate mortgage investment conduit transaction.
The remaining classes in the re-REMIC either were not rated by
Standard & Poor's or were residual classes.

The downgrades reflect the significant deterioration in
performance of the loans backing the underlying certificates and
insufficient credit enhancement within the re-REMIC structure.
This performance deterioration is so severe that the credit
enhancement for BSSP 2007-R6 is insufficient to maintain the
previous ratings on the re-REMIC classes.

BSSP 2007-R6, which closed in August 2007, is collateralized by
six underlying classes that support two independent groups within
the re-REMIC.  The loans securing the six underlying classes,
which are included in six different trusts, consist predominately
of fixed- and long-reset adjustable-rate Alternative-A mortgage
loans.

The class I-A-1 and I-A-2 certificates from BSSP 2007-R6 are
supported by the class II-1A-1 from Bear Stearns ALT-A Trust 2005-
8 (currently rated 'CCC'), the class II-3A-1 from Bear Stearns
ALT-A Trust 2005-9 (currently rated 'CCC'), and the class II-5A-1
from Bear Stearns ALT-A Trust 2005-10 (currently rated 'CC').

The performance of the loans securing the class II-1A-1
certificate from Bear Stearns ALT-A Trust 2005-8 has declined
precipitously in recent months.  This pool had experienced losses
of 5.13% as of the October 2009 distribution, and currently has
approximately 27.00% in delinquent loans.  Based on the losses to
date, the current pool factor of 0.4951 (49.51%), which represents
the outstanding pool balance as a proportion of the original
balance, and the pipeline of delinquent loans, S&P's current
projected loss for this pool is 10.29%, which exceeds the level of
credit enhancement available to cover losses.

The performance of the loans securing the class II-3A-1
certificate from Bear Stearns ALT-A Trust 2005-9 has declined
precipitously in recent months.  This pool had experienced losses
of 4.06% as of the October 2009 distribution, and currently has
approximately 32.20% in delinquent loans.  Based on the losses to
date, the current pool factor of 0.5349 (53.49%), and the pipeline
of delinquent loans, S&P's current projected loss for this pool is
15.78%, which exceeds the level of credit enhancement available to
cover losses.

The performance of the loans securing the class II-5A-1
certificate from Bear Stearns ALT-A Trust 2005-10 has declined
precipitously in recent months.  This pool had experienced losses
of 7.73% as of the October 2009 distribution, and currently has
approximately 35.87% in delinquent loans.  Based on the losses to
date, the current pool factor of 0.4595 (45.95%), and the pipeline
of delinquent loans, S&P's current projected loss for this pool is
17.17%, which exceeds the level of credit enhancement available to
cover losses.

The class II-A-1 and II-A-2 certificates from BSSP 2007-R6 are
supported by the class II-3A-1 from Bear Stearns ALT-A Trust 2006-
3 (currently rated 'CCC'), the class II-A-1 from Bear Stearns ALT-
A Trust 2007-2 (currently rated 'CCC'), and the class II-A-1 from
Bear Stearns ARM Trust 2007-2 (currently rated 'CCC').

The performance of the loans securing the class II-3A-1
certificate from Bear Stearns ALT-A Trust 2006-3 has declined
precipitously in recent months.  This pool had experienced losses
of 9.46% as of the October 2009 distribution, and currently has
approximately 45.27% in delinquent loans.  Based on the losses to
date, the current pool factor of 0.4360 (43.60%), and the pipeline
of delinquent loans, S&P's current projected loss for this pool is
19.93%, which exceeds the level of credit enhancement available to
cover losses.

The performance of the loans securing the class II-A-1 certificate
from Bear Stearns ALT-A Trust 2007-2 has declined precipitously in
recent months.  This pool had experienced losses of 6.97% as of
the October 2009 distribution, and currently has approximately
44.16% in delinquent loans.  Based on the losses to date, the
current pool factor of 0.6829 (68.29%), and the pipeline of
delinquent loans, S&P's current projected loss for this pool is
21.22%, which exceeds the level of credit enhancement available to
cover losses.

The performance of the loans securing the class II-A-1 certificate
from Bear Stearns ARM Trust 2007-2 has declined precipitously in
recent months.  This pool had experienced losses of 2.84% as of
the October 2009 distribution, and currently has approximately
32.06% in delinquent loans.  Based on the losses to date, the
current pool factor of 0.7330 (73.30%), and the pipeline of
delinquent loans, S&P's current projected loss for this pool is
16.12%, which exceeds the level of credit enhancement available to
cover losses.

Over the past two years, S&P has revised S&P's RMBS default and
loss assumptions, and consequently S&P's projected losses, to
reflect the continuing decline in mortgage loan performance and
the housing market.  The performance deterioration of most U.S.
RMBS has continued to outpace the market's expectation.

                          Ratings Lowered

       Bear Stearns Structured Products Inc. Trust 2007-R6
                         Series 2007-R6

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       I-A-1      07402FAA3     A+                   AAA
       II-A-1     07402FAC9     CCC                  AAA


BLACKROCK SENIOR: Moody's Downgrades Ratings on Various Classes
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by BlackRock Senior Income Series V,
Limited:

  -- US$75,000,000 Class A-1 Senior Multi-Currency Revolving Notes
     Due 2019 (current balance of $74,093,841.78), Downgraded to
     A1; previously on July 19, 2007 Assigned Aaa;

  -- US$180,000,000 Class A-2a Senior Notes Due 2019 (current
     balance of $176,227,586), Downgraded to Aa1; previously on
     July 19, 2007 Assigned Aaa;

  -- US$20,000,000 Class A-2b Senior Notes Due 2019, Downgraded to
     A3; previously on March 4, 2009 Aa1 Placed Under Review for
     Possible Downgrade;

  -- US$110,000,000 Class A-3 Senior Notes Due 2019 (current
     balance of $107,925,269), Downgraded to A1; previously on
     July 19, 2007 Assigned Aaa;

  -- US$17,000,000 Class B Senior Notes Due 2019, Downgraded to
     Baa2; previously on March 4, 2009 Aa2 Placed Under Review for
     Possible Downgrade;

  -- US$30,000,000 Class C Deferrable Mezzanine Notes Due 2019,
     Downgraded to Ba3; previously on March 13, 2009 Downgraded to
     Ba1 and Placed Under Review for Possible Downgrade;

  -- US$28,000,000 Class D Deferrable Mezzanine Notes Due 2019
     (current balance of $28,226,831), Downgraded to Caa3;
     previously on March 13, 2009 Downgraded to B2 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.  Such
credit deterioration 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 and
Class D Overcollateralization Tests.  In particular, the weighted
average rating factor has increased over the last year and is
currently 2665 as of the last trustee report, dated September 30,
2009.  Based on the same report, defaulted securities currently
held in the portfolio total about $11.2 million, accounting for
roughly 2.4% of the collateral balance, and securities rated Caa1
or lower make up approximately 9.6% of the underlying portfolio.
The Class C overcollateralization test was reported at 106.36%
versus a test level of 107.1% and the Class D
overcollateralization test was reported at 99.74% versus a test
level of 102.6%.

The rating actions also reflect Moody's revised assumptions with
respect to default probability, including certain stresses
pertaining to credit estimates, and the calculation of the
Diversity Score.  These revised assumptions are described in the
publication "Moody's Approach to Rating Collateralized Loan
Obligations," dated August 12, 2009.  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 (see Moody's Special
Comment titled "Strong Loan Issuance in Recent Years Signals Low
Recovery Prospects for Loans and Bonds of Defaulted U.S. Corporate
Issuers," dated June 2008).  Other assumptions used in Moody's CLO
monitoring are described in the publication "CLO Ratings
Surveillance Brief - Second Quarter 2009," dated July 17, 2009.
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, diversity score, and weighted average recovery
rate, may be different from the trustee's reported numbers.

BlackRock Senior Income Series V, Limited, issued in July 2007, is
a is a multicurrency collateralized loan obligation, backed
primarily by a portfolio of senior secured loans denominated in
U.S. dollars, euros and pounds sterling.

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.


C-BASS CBO: Fitch Downgrades Ratings on Four Classes of Notes
-------------------------------------------------------------
Fitch Ratings has downgraded four classes of notes issued by C-
BASS CBO XIII, Ltd./Corp. as a result of continued credit
deterioration in the portfolio since Fitch's last rating action in
August 2008.  Approximately 83.5% of the portfolio has been
downgraded since the last review.  The details of the rating
action follow at the end of this press release.

The downgrades to the portfolio have left approximately 74.2% of
the portfolio with a Fitch derived rating below investment grade
and 58.4% with a rating in the 'CCC' rating category or lower,
compared to 36% and 8%, respectively at last review.  Defaulted
securities, per the transaction's governing documents, now
comprise 40.9% of the portfolio, compared to 2.1% at last review.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  Due to the significant collateral
deterioration, even the 'CCC' rating loss rate, the lowest rating
level loss projected by PCM, exceeds the credit enhancement levels
available to all classes of notes.  For these classes, Fitch
compared the respective credit enhancement levels to the amount of
underlying assets considered distressed (rated 'CCC' and lower).

The class A notes are downgraded to 'CC' and the class B notes are
downgraded to 'C' due to the degree of deterioration within the
underlying portfolio.  While these classes are still receiving
timely interest distributions, Fitch believes that based on the
current credit quality of the portfolio and the credit enhancement
levels of 33% and 17%, respectively, default is probable for the
class A notes and inevitable for the class B notes at or prior to
maturity.

The class C and D notes are no longer receiving interest
distributions and are not expected to receive any proceeds going
forward.  Therefore the notes are downgraded to 'C' to indicate
Fitch's belief that default is inevitable at or prior to maturity.

C-BASS XIII is a structured finance collateralized debt obligation
(SF CDO) that closed on March 17, 2005, and is monitored by C-BASS
Investment Mangement LLC.  The portfolio is composed of RMBS
(81.9%), CDOs (9.5%), commercial mortgage-backed securities
(6.4%), and asset-backed securities (2.2%).

Fitch has downgraded these classes of C-BASS XIII:

  -- $158,452,434 class A notes to 'CC' from 'BBB+';
  -- $39,500,000 class B notes to 'C' from 'BB+';
  -- $12,000,000 class C notes to 'C' from 'BB-';
  -- $18,186,132 class D notes to 'C' from 'B-'.


CAF ABS: S&P Downgrades Ratings on Medium-term Notes to 'B'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class A-1A, A-1B, and A-2 medium-term notes issued by CAF ABS
Investment LLC to 'B' from 'BBB' and removed them from CreditWatch
with negative implications.  S&P subsequently withdrew the ratings
on these notes.

The downgrades follow CAFI's purchase of a portfolio of 24
collateralized loan obligations, collateralized debt obligations,
credit card asset-backed securities, and residential mortgage-
backed securities with ratings ranging from 'AAA' to 'CCC' and
with maturity dates ranging from May 20, 2013, to Nov. 5, 2041
(according to the Oct. 15, 2009, servicer report provided by the
manager, Chicago Asset Funding LLC).  The maturity dates for all
24 of these securities exceed the final maturity date of the class
A-1 notes (Jan. 16, 2012), and the maturity dates for eight of the
securities exceed the final maturity date of the class A-2 notes
(Jan. 15, 2021).  Given the maturity date mismatch, S&P believes
it is likely that the manager will have to liquidate the CAFI
portfolio in order to repay the class A-1 notes by their final
maturity date.  Furthermore, the manager has indicated a desire to
continue to opportunistically sell securities in the CAFI
portfolio and purchase new securities.

S&P withdrew its ratings on the notes because the current
operational framework of CAFI -- which exposes the holders of the
notes to market-value risks associated with the ongoing purchase
and sale of portfolio securities -- is no longer consistent with
the framework under which S&P initially assigned its ratings.
Furthermore, the current program documents do not, in its view,
provide a sufficient basis upon which to maintain its ratings
given the changes in the operational framework.  In addition, the
manager has submitted a request for the ratings to be withdrawn.

S&P initially assigned 'AAA' ratings to the CAFI notes on Feb. 7,
2006, based on the 'AAA' rating on a single underlying ABS, which
CAFI purchased at issuance on a match-funded basis (that is, the
maturity date and interim interest payment dates of the CAFI notes
mirrored those of the underlying 'AAA' ABS).  The 'AAA' rating on
the underlying ABS reflected a surety bond provided by Financial
Guaranty Insurance Co., which was rated 'AAA' at the time.  S&P
subsequently lowered its ratings on the CAFI notes several times
following rating actions on FGIC: to 'AA/Watch Dev' on Feb. 21,
2008; to 'A/Watch Dev' on Feb. 26, 2008; to 'A/Watch Neg' on
March 24, 2008; and to 'BBB' (Standard & Poor's underlying rating,
or SPUR) on March 31, 2008.

CAFI sold the underlying ABS in October 2008, and S&P learned in
August 2009 that it had used the proceeds from the sale, which it
initially had invested in short-term high-quality eligible
investments, to purchase the portfolio of CLOs, CDOs, credit card
ABS, and RMBS.  On Aug. 21, 2009, S&P placed its ratings on the
notes on CreditWatch negative after learning from the manager that
it had used the proceeds to purchase the CLOs, CDOs, credit card
ABS, and RMBS.

                          Rating Action

                     CAF ABS Investment LLC

                               Rating
                               ------
        Class     To           Interim       From
        -----     --           -------       ----
        A-1A      NR           B             BBB/Watch Neg
        A-1B      NR           B             BBB/Watch Neg
        A-2       NR           B             BBB/Watch Neg

                          NR - Not rated.


CALIFORNIA COLLEGE: Moody's Affirms Rating on 2001 & 2005 Bonds
---------------------------------------------------------------
Moody's Investors Service has affirmed the Baa3 rating on
California College of the Arts' Series 2001 and 2005 bonds.  All
bonds were issued through the California Educational Facilities
Authority.  The College's rating outlook remains stable.

The College also participated in the 2007 College and University
Financing Program, rated Ba1 with a stable outlook, issued through
the California Educational Facilities Authority.  Although the CCA
is a member of the pooled financings, the rating and outlook is
based on the relative share of each participant in the pool, bond
maturities, the participants' underlying credit quality and the
corresponding expected loss (default frequency times loss
severity) for their rating categories.  See the Moody's report
dated April 9, 2009, for more information on this borrowing.

Legal Security: General obligation of the College, as well as a
gross revenue pledge and various specific mortgage pledges on
CCA's campuses.

Debt Related Derivatives: None.

                            Strengths

* The CCA maintains a stable market niche as an urban art and
  design college located on two campuses in Oakland and San
  Francisco, CA.  The College reported a second year of enrollment
  gain in the fall 2009 to 1,739 full-time equivalents (FTE),
  following a 4% decline in fall 2007.  Approximately 80% of the
  College's students are undergraduates.  The San Francisco campus
  houses CCA's undergraduate programs in architecture and design
  as well as all of its graduate programs.  The College has made
  notable investments in these academic programs in recent years
  and continues to expand its offerings which are expected to
  increase student demand.  The College has also made substantial
  capital investment in its campus over the past several years
  which Moody's expects will help to at least maintain the current
  student market position going forward.

* Sustained growth in net tuition revenue, a key issue as the
  College relies heavily on student charges for total revenues.
  Net tuition revenue has increased an average of 7% annually over
  the past four years, and increased a healthy 11% in fiscal 2009
  despite continued growth of tuition discount rates.  In FY 2009
  CCA's operating cash flow margin was thin at 8.0%; providing
  adequate debt service coverage of 1.0 times.  Management expects
  stronger results for FY2010 as enrollment figures for the fall
  are higher than budgeted, with growth in both undergraduate and
  graduate programs.  In addition, management has made several
  expenditure reductions to accommodate a reduced endowment spend.

* The College continues to diversify its investment portfolio,
  currently with five external managers.  Overall, the College
  maintains a conservative portfolio (38% equities, 20% fixed
  income, 18% hedged equity, 15% cash equivalents and 9% hedged
  funds).  In calendar year 2008, the College had a negative 21%
  investment return.  The calendar year to date return as of
  August 31, 2009, was 11%.

* No borrowing plans for the next several years; all of the
  College's debt is in a fixed-rate mode

                            Challenges

* Strong competition in California for higher education, as
  evidenced by CCA's declining yield rate.  CCA competes with
  other private art and design schools located in California and
  around the country, including Otis College of Art and Design
   (rated Baa3) as well as the State's public university systems.
  CCA's yield rate continues to decline, now at 24% in fall 2009
  compared to 30% just five years ago.  Dependency on student
  charges (87% of FY2009) as the primary source of operating
  revenue stresses the importance of continued successful
  recruitment and retention of students as demand and market
  position continued to be pressured over the longer term.

* Due to its dependency on student charges and budgeting for
  break-even operations, the College's operating performance is
  highly dependent upon enrollment success.  In FY2008, operating
  performance declined to a very weak negative 3.2% operating
  margin, with operating cash flow providing less than one times
  debt service coverage.  Management notes weakened performance
  due to increased investment in academic programs while
  experiencing a decline in enrollment in fall 2007.  FY2009
  fiscal results were slightly better with a negative 1.7%
  operating margin as the College experienced healthy enrollment
  growth.  Moody's believes that stabilization of operations and a
  return to at least break-even performance will be important to
  sustaining credit quality.

* Due to investment losses, the College's total financial
  resources declined by 23% in FY2009.  Expendable resources
  declined by a dramatic 44% to $11.9 million in FY2009, from an
  already thin $21.2 million in FY2008.  With these lower levels,
  expendable resources to debt and operations now measure at a
  limited 0.27 times and 0.26 times, respectively.  Given these
  lower levels, Moody's believes the College has no additional
  debt capacity at the current rating level.  In addition, debt
  service continues to consume almost 8% of operations and direct
  debt to revenues measures at almost one times.  Moody's believes
  debt capacity could only increase with significant further
  growth in revenue and reserves.

                              Outlook

The stable outlook reflects Moody's expectation CCA will continue
to grow enrollment and achieve positive operations going forward,
as well as grow expendable financial resources to better cushion
debt and operations.

                 What Could Change the Rating - UP
Unlikely in the near term; substantial increase in financial
flexibility through growth in unrestricted and expendable reserves
combined with healthy operating performance and stabilization of
enrollment and yield rates.

                What Could Change the Rating - DOWN

Continued deterioration in operating performance, unrestricted and
expendable financial resources, or enrollment levels; additional
borrowing without significant growth in financial resources and
operating cash flow.

Key Indicators (Fall 2009 enrollment data and FY2009 financial
data):

* Total Full-Time Equivalent (FTE) Enrollment: 1,739
* Selectivity Rate: 74.9%
* Matriculation Rate: 24.0%
* Unrestricted Financial Resources: $1.9 million
* Expendable Financial Resources: $11.9 million
* Total Financial Resources: $30.2 million
* Total Debt $43.6 million
* Expendable Financial Resources-to-Operations: 0.27 times
* Expendable Financial Resources-to- Debt: 0.26 times
* Average three-year operating margin: negative 1.5%

Rated Debt:

* CEFA Series 2005, 2001: Baa3
* CEFA Series 2007 (Pooled Rating): Ba1

The last rating action was on September 2, 2009, when Moody's
affirmed the Baa3 rating and stable outlook of the California
College of the Arts.


CMBSPOKE 2005-III: Moody's Assigns Provisional Ratings on Notes
---------------------------------------------------------------
Moody's Investors Service announced that it assigned, as of
October 30, 2009, these provisional ratings to the Notes issued by
CMBSpoke 2005-III, Ltd.:

* (P)Baa1 to the US$66,666,667 Class A Notes due 2047;
* (P)Baa3 to the US$13,666,667 Class B Notes due 2047;
* (P) Ba2 to the US$50,000,000 Class C Notes due 2047.

Moody's issues provisional ratings in advance of the final sale of
financial instruments, but these ratings only represent Moody's
preliminary credit opinions.  Upon a conclusive review of the
transaction and associated documentation, Moody's will endeavor to
assign definitive ratings.  A definitive rating (if any) may
differ from a provisional rating.

The reference portfolio for the synthetic transaction is comprised
of 100 equally referenced classes of commercial mortgage backed
securities certificates from 100 separate transactions (100% of
the reference portfolio balance).  The CMBS securities are from
pools securitized in 2002 (26%), 2003 (31%), 2004(24%) and
2005(19%).

Moody's uses a weighted average rating factor as an overall
indicator of the credit quality of a synthetic CRE CDO
transaction.  Based on Moody's analysis, the current WARF is 9
with the rating distribution: Aaa (69.9% of the reference
portfolio balance), Aa1(5.0%), Aa2(16.1%), Aa3(6.0%), A1(3.0%).
Moody's reviewed the ratings or performed credit estimates on all
the reference obligations supporting the Notes.

When assigning the ratings on the Notes Moody's applied stressed
loss assumptions on the underlying pool of mortgages remaining in
each of the underlying CMBS transaction.  The stressed assumptions
considered, among other factors, the underlying transaction's
collateral attributes, past and current performance and Moody's
performance outlook for commercial real estate.  Moody's used
CDOROM v2.5 to model the transaction.

Based upon the material provided by the Issuer and the results of
the analysis commissioned by the Issuer, Moody's ratings reflect
the likelihood of the ultimate receipt of interest and principal
by the holders of the Class A, Class B, and Class C Notes.

These provisional ratings are based upon the quality of the
underlying collateral and the legal structure.  Moody's
provisional ratings address only the credit risks associated with
the transaction.  Other non-credit risks, such as those associated
with the timing of principal prepayments have not been addressed
and may have a significant effect on yield to investors.

The assigned ratings are not a recommendation to buy, sell or hold
securities or any interest therein.


CREDIT SUISSE: Moody's Reviews Ratings on 14 2005-C4 Certificates
-----------------------------------------------------------------
Moody's Investors Service placed 14 classes of Credit Suisse First
Boston Mortgage Securities Corp. Commercial Mortgage Pass-Through
Certificates, Series 2005-C4 on review for possible downgrade due
to higher expected losses for the pool resulting from losses from
loans in special servicing and increased leverage of the
collateral pool.  Currently, there are five loans in special
servicing, representing 4% of the pool balance.  The rating action
is the result of Moody's on-going surveillance of commercial
mortgage backed securities transactions.

As of the October 19, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 4% to
$1.28 billion from $1.33 billion at securitization.  The
Certificates are collateralized by 157 mortgage loans ranging in
size from less than 1% to 5% of the pool, with the top ten non-
defeased loans representing 30% of the pool.

Twenty four loans, representing 7% 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.  Not all loans on the
watchlist are delinquent or have significant issues.

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

Moody's rating action is:

  -- Class A-J, $93,008,000, currently rated Aaa, on review for
     possible downgrade; previously assigned Aaa on 09/06/2005

  -- Class B, $23,253,000, currently rated Aa2, on review for
     possible downgrade; previously assigned Aa2 on 09/06/2005

  -- Class C, $13,286,000, currently rated Aa3, on review for
     possible downgrade; previously assigned Aa3 on 09/06/2005

  -- Class D, $23,252,000, currently rated A2, on review for
     possible downgrade; previously assigned A2 on 09/06/2005

  -- Class E, $16,609,000, currently rated A3, on review for
     possible downgrade; previously assigned A3 on 09/06/2005

  -- Class F, $16,609,000, currently rated Baa1, on review for
     possible downgrade; previously assigned Baa1 on 09/06/2005

  -- Class G, $13,287,000, currently rated Baa2, on review for
     possible downgrade; previously assigned Baa2 on 09/06/2005

  -- Class H, $16,608,000, currently rated Baa3, on review for
     possible downgrade; previously assigned Baa3 on 09/06/2005

  -- Class J, $4,983,000, currently rated Ba1, on review for
     possible downgrade; previously assigned Ba1 on 09/06/2005

  -- Class K, $8,304,000, currently rated Ba2, on review for
     possible downgrade; previously assigned Ba2 on 09/06/2005

  -- Class L, $6,643,000, currently rated Ba3, on review for
     possible downgrade; previously assigned Ba3 on 09/06/2005

  -- Class M, $1,661,000, currently rated B1, on review for
     possible downgrade; previously assigned B1 on 09/06/2005

  -- Class N, $4,983,000, currently rated B2, on review for
     possible downgrade; previously assigned B2 on 09/06/2005

  -- Class O, $4,982,000, currently rated B3, on review for
     possible downgrade; previously assigned B3 on 09/06/2005


CREDIT SUISSE: S&P Downgrades Ratings on Eight 2008-2R Certs.
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of certificates from Credit Suisse First Boston Mortgage
Securities Corp. CSMC Series 2008-2R, a U.S. residential mortgage
backed securities re-securitized real estate mortgage investment
conduit transaction.

The downgrades reflect the significant deterioration in the
performance of the loans backing the underlying certificates.
This performance deterioration is so severe that the credit
enhancement for CSMC 2008-2R is insufficient to maintain the 'AAA'
ratings.

CSMC 2008-2R, which closed in May 2008, is collateralized by three
underlying classes that support three independent groups within
the re-REMIC.  Certain classes within the re-REMIC groups also
benefit from additional credit support provided by applicable
support classes.  The loans securing the three underlying classes,
which are included in three different trusts, consist
predominately of fixed-rate prime and Alternative-A mortgage
loans.

Classes 1-A-1 and 1-A-2 from CSMC 2008-2R are supported by the
III-A-3 class from Wells Fargo Alternative Loan 2007-PA3 Trust
(currently rated 'CCC').  The performance of the loans securing
this trust has declined precipitously in recent months.  This pool
had experienced losses of 2.24% as of the September 2009
distribution date, and it had approximately 22% in delinquent
loans as a percentage of the current pool balance.  Based on the
losses to date, the pool factor of 0.8238 (82.38%), which
represents the outstanding pool balance as a proportion of the
original balance, and the pipeline of delinquent loans, S&P's
current projected loss for this pool is 9.81%, which exceeds the
level of credit enhancement available to cover losses to class
III-A-3.

Classes 2-A-1, 2-A-2, 2-A-3, and 2-A-4 from CSMC 2008-2R are
supported by the 1-A-15 class from JPMorgan Mortgage Trust 2007-S2
(currently rated 'CC').  The performance of the loans securing
this trust continues to erode beyond reasonable expectations.
This pool had experienced losses of 0.47% as of the September 2009
distribution date, and it had approximately 14.6% in delinquent
loans as a percentage of the current pool balance.  Based on the
losses to date, the pool factor of 0.7721 (77.21%), and the
pipeline of delinquent loans, S&P's current projected loss for
this pool is 6.40%, which exceeds the level of credit enhancement
available to cover losses to the 1-A-15 class.

The 3-A-1 and 3-A-2 classes from CSMC 2008-2R are supported by the
1-A-35 class from JPMorgan Mortgage Trust 2007-S3 (currently rated
'CCC').  The performance of the loans securing this trust has
declined significantly in recent months.  This pool had
experienced losses of 0.42% as of the September 2009 distribution
date, and it had approximately 15.45% in delinquent loans as a
percentage of the current pool balance.  Based on the losses to
date, the pool factor of 0.8078 (80.78%), and the pipeline of
delinquent loans, S&P's current projected loss for this pool is
7.45%, which exceeds the level of credit enhancement available to
cover losses to class 1-A-35.

Over the past two years S&P has revised its RMBS default and loss
assumptions, and consequently its projected losses, to reflect the
continuing decline in mortgage loan performance and the housing
market.  The performance deterioration of most U.S. RMBS has
continued to outpace the market's expectations.

                         Ratings Lowered

       Credit Suisse First Boston Mortgage Securities Corp.
                       CSMC Series 2008-2R

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        1-A-1      225492AA5     AA                   AAA
        1-A-2      225492AC1     CCC                  AAA
        2-A-1      225492AE7     CCC                  AAA
        2-A-2      225492AG2     CC                   AAA
        2-A-3      225492AJ6     CCC                  AAA
        2-A-4      225492AL1     CCC                  AAA
        3-A-1      225492AN7     CCC                  AAA
        3-A-2      225492AQ0     CC                   AAA


DELPHINUS CDO: Macquarie Bank Deal Won't Affect Fitch's Ratings
---------------------------------------------------------------
Fitch Ratings has reviewed the effect of the Macquarie Bank
Limited or its affiliate's proposed acquisition of Delaware
Management Holdings, Inc., and its subsidiaries from Lincoln
National Corp. and determined that this transaction will not
affect the ratings currently assigned to Delphinus CDO 2007-1,
LLC/Ltd.  Delphinus is managed by Delaware Asset Advisers, a
subsidiary of Delaware Management Holdings, Inc.

On Oct. 8, 2009, Fitch was notified that pursuant to applicable
law, an assignment of the Delphinus collateral management
agreement would be deemed to occur upon MBL's acquisition of
Delaware.  Although the ultimate ownership of Delaware will change
as a result of the acquisition, the organizational structure and
investment capabilities of the existing entity responsible for
managing Delphinus will remain in place.  Fitch's initial and on-
going rating of CDO transactions includes a review of the CDO
asset manager to determine whether they meet the appropriate
standards.

Delaware, the asset management arm of the Lincoln National Corp.,
is headquartered in Philadelphia, PA.  As of June 30, 2009,
Delaware had approximately $124.4 billion in assets under
management and had 569 employees, including 156 investment
professionals covering structured products, corporate bonds,
private placements, municipal obligations, and international and
emerging markets.  Established in 1969 as a wholly owned
subsidiary of UK-based Hill Samuel Bank Limited, MBL is part of
Macquarie Group Limited.  MBL's long- and short-term Issuer
Default Ratings are currently rated 'A+' and 'F1', respectively,
with a Stable Outlook by Fitch.

Fitch emphasizes that the scope of its review was solely to
determine whether Delaware, under new ownership, meets Fitch's
minimum guidelines to manage Delphinus within the context of
Fitch's stated review procedure for replacement managers.
Furthermore, this review was in the context of the current
management responsibilities associated with Delphinus and the
current ratings assigned to the CDO by Fitch.  Fitch is not a
party to the transaction and therefore does not provide consent or
approval, as that remains the sole preserve of the transaction
parties.  Fitch expects to be notified by the trustee when or if
the proposed transfer of asset management responsibilities is
completed.

Delphinus is a hybrid structured finance CDO which closed on
July 19, 2007.  The liability structure consists of partially
funded super senior liquidity facility (super senior notes) above
the funded notes.  The portfolio is comprised of primarily 2006
and 2007 vintage subprime residential mortgage backed securities,
Alternative-A RMBS, and CDOs.  As a result of the class A Par
Value Coverage Ratio falling below 100%, the CDO entered an Event
of Default on Jan. 2, 2008.  The super senior notes and classes A-
1A, A-1B, A-1C, S, A-2, A-3, B are currently rated 'CC'.  The
classes C, D-1, D-2, D-3, E are rated 'C'.


FORD CREDIT: Moody's Downgrades Ratings on 2006-4 Floorplan Notes
-----------------------------------------------------------------
Moody's Investors Service has downgraded ratings on Ford Credit
Master Owner Trust, Series 2006-4 dealer floorplan asset-backed
notes.  The rating actions reflect an analysis that evaluates the
protection available to noteholders under stressed scenarios.
These scenarios incorporate, among other factors, stresses that
could be realized in bankruptcy scenarios that differ from the
recent orderly bankruptcy experiences of Chrysler and General
Motors.

Ford Credit Master Owner Trust, Series 2006-4 (FCMOT 2006-4)

  -- Class A Notes, Downgraded to A3 from Aa2; previously on
     1/28/2009, Downgraded from Aaa to Aa2 with review for further
     possible downgrade.

  -- Class B Notes, Downgraded to Ba2 from Baa3; previously on
     1/28/2009, Downgraded from A1 to Baa3 with review for further
     possible downgrade.

                            Rationale

Since the rating actions taken on the Ford Credit auto floorplan
transactions on January 28, 2009, Moody's further assessed, among
other things, Moody's experience in evaluating protections to
rated notes under stressed scenarios from the recent Chrysler and
General Motor bankruptcies.  The current rating actions reflect
Moody's updated view of the key factors driving performance in the
floorplan transactions following the review process since the
original rating actions on November 25, 2008, and January 28,
2009.

The rating actions are not driven by current performance, as the
FCMOT 06-4 deal is performing well by traditional standards,
exhibiting a minimal level of charge-offs.  The rating downgrades
reflect protection levels available to FCMOT 06-4 notes under
contemplated stressed scenarios.  These scenarios incorporate,
among other factors, stresses that could be realized in bankruptcy
scenarios that differ from the recent orderly bankruptcy
experience of Chrysler and General Motors.  The stresses address
the level of dealer defaults, monthly payment rate triggers and
related payment rate declines, and recovery rates in a future
bankruptcy that might be more disruptive than recent bankruptcy
experience.

For each stressed scenario, losses were projected and compared to
available enhancement.  Loss coverage ratios were analyzed in all
scenarios along with the corresponding potential impact on bond
ratings.

                       Rating Methodology

Moody's floorplan analysis is based on a joint-default probability
analysis of both the manufacturer and dealers with loss given
default determined by collateral at risk net of recoveries.  The
total collateral at risk with a joint-default is the remaining
unpaid floorplan loan calculated based on the monthly payment rate
prior to dealer default.

The analysis is implemented through a simulation model, which
simulates losses during a two year amortization period following
an event of default based on a set of key modeled assumptions:

  -- Manufacturer bankruptcy scenarios
  -- Dealer default rates
  -- Recovery rates
  -- Payment rates

In addition, Moody's includes other modeled assumptions in the
simulation model such as linkage of default probability between
manufacturer and dealer to macroeconomic activity, linkage between
manufacturer and dealer default probability, and sold-out-of-trust
assumptions.

Modeled assumptions form the basis of the quantitative analysis
executed through a simulation model.  Manufacturer default is
simulated, which is further specified into Chapter 11 and Chapter
7 bankruptcies.  Manufacturer default probability is modeled based
on committee assessment, often with reference to the manufacturer
rating.  Next, the simulation model simulates dealer default,
which takes place randomly throughout the two year amortization
period.  The final step in simulation is to calculate total
principal collections.  For non-defaulting dealers, outstanding
floorplan balances are assumed to be paid in full at the end of
the two year amortization period and losses will be zero.  For
defaulted dealers, the model calculates total collateral at risk
determined by payment rate prior to dealer default and then
applies a recovery rate under different circumstances where the
manufacturer is either in a non-bankrupt status, a Chapter 11
bankruptcy or a Chapter 7 bankruptcy.

Each simulation run simulates a total loss and corresponding
internal rate of return reduction for each bond.  This IRR
reduction helps form the quantitative basis of Moody's rating
assessment.  Moody's also evaluates qualitative factors such as
the quality of provided information, servicer strength, and
dealership profile.  Combining the qualitative and quantitative
analysis, a final rating level is determined.

In addition to applying Moody's standard simulation-based
approach, Moody's conducted a static scenario analysis to assess
protections available to rated notes under contemplated stressed
scenarios.  In this approach, Moody's considered numerous possible
manufacturer bankruptcy scenarios, each with a different set of
assumptions including dealer default rates, recovery rates,
payment rates, and other major factors that could drive floorplan
performance.  Under each scenario, losses were projected and
compared to available enhancement.  Loss coverage ratios were
analyzed in all scenarios along with the corresponding potential
impact on bond ratings.

                            Servicer

Ford Credit provides wholesale, retail, and lease financing,
primarily to Ford dealers and is the world's largest auto finance
company.  Ford Motor Company, headquartered in Dearborn, is one
the world's largest auto manufacturers.  Ford's long-term
unsecured bonds are rated Caa1 with stable outlook.  Ford Credit's
long-term unsecured bonds are rated Caa1, and the rating is
currently under review for possible upgrade.


GENWORTH FINANCIAL: Moody's Downgrades Ratings on $750 Mil. Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of $750 million of insured insurance-linked securities
issued out of a series of trusts associated with River Lake
Insurance Company III, a special purpose reinsurer sponsored by
Genworth Financial, Inc.

The $250 million of INC Term Securities, Series RLIII 2006-1 due
2036 were downgraded to Baa3 from A2 and five separate
$100 million each of the INC Money Market Securities, Series RLIII
2006-1 through 5 due 2036 were downgraded to Ba3 from A3.  The
outlook on the ratings of the Term Securities and MM Securities is
developing.  The rating action concludes Moody's review for
possible downgrade which was initiated on June 29, 2009.  The
River Lake III Securities' ratings will be withdrawn for business
reasons.

River Lake III is sponsored by and wholly-owned by Genworth Life
and Annuity Insurance Company (A2 for insurance financial
strength/negative outlook), which is ultimately wholly-owned by
Genworth Financial, Inc. (senior debt at Baa3/negative outlook).
River Lake III is a special purpose captive reinsurer established
for the purpose of financing collateral for the excess statutory
reserves associated with distinct blocks of business ceded by
GLAIC.  The reinsurance agreement between GLAIC and River Lake III
covers defined blocks of level premium term life policies subject
to the statutory reserve requirements of Regulation XXX.

Moody's said the downgrade is driven by higher funding costs due
to Dutch Auction failures and increased expectations of economic
losses in the investment portfolio.  These factors meaningfully
increased the estimates of expected loss and probability of
default derived under various scenarios using deterministic and
stochastic modeling of the underlying investment assets and
insurance cashflows of the term life business reinsured to River
Lake III.  Notwithstanding weaker than expected investment
performance, Moody's noted that the performance of the underlying
insurance risk has generally been consistent with original
expectations.

The higher funding costs (almost 200 basis points per annum)
associated with the ongoing Dutch Auction failure lead to a
significantly higher estimated PD for the MM Securities and to a
lesser extent the Term Securities.  Although the Dutch Auction
failures are expected to continue for the foreseeable future, the
rating agency noted that the PD and EL for the transaction is
highly sensitive to the assumptions made about future funding
costs.  A favorable resolution of the Dutch Auction failures for
River Lake III could significantly lower the PD and EL, whereas a
permanent failure for the life of the transaction could elevate
the PD and EL beyond those indicated by the current ratings.

The downgrade of the River Lake III Securities' ratings is also
driven by the significant increase in expected credit losses on
the residential mortgage-backed securitiesand commercial mortgage-
backed securities in River Lake III's investment portfolio.  The
rating agency expects elevated credit losses in the corporate bond
portfolio, particularly under stress scenarios, which would
diminish the equity cushion and elevate the expected losses to
noteholders.  "The investment losses have been exacerbated by the
stressful economic and credit environment," according to Moody's
analyst Shachar Gonen.  The rating agency noted that a significant
portion of the investment portfolio is currently held in cash and
short-term investments which somewhat mitigates the elevated level
of future investment losses, but also causes an ongoing negative
spread between the transaction's investment return and funding
cost.

Moody's stated that the developing outlook reflects the potential
for further deterioration in the investment portfolio and
permanent Dutch Auction failure, which could result in a lower
rating, as well as the potential for additional future recapture
of business by GLAIC and resolution of the Dutch Auction failure,
which could result in a higher rating.  The River Lake III
Securities have already benefited from the recapture of about 35%
of the total statutory reserves to-date by GLAIC.  Additionally,
GLAIC has obtained regulatory approval and has applied the use of
the 2001 CSO Mortality Table for calculating reserves effective as
of September 30, 2009, rather than the 1980 CSO table.  While this
change reduces redundant statutory reserve strain by approximately
20% to 25%, it also diminishes GLAIC's need to effect additional
recaptures.

Moody's ratings on securities that are guaranteed or "wrapped" by
a financial guarantor are maintained at a level equal to the
higher of a) the rating of the guarantor or -- as in this case --
b) the published underlying rating.  The Baa3 rating for the Term
Securities and the Ba3 rating for the MM Securities reflect this
modified "credit substitution" approach and are equal to the
underlying ratings on these securities.  Moody's approach to
rating wrapped transactions is outlined in Moody's Special Comment
entitled "Assignment of Wrapped Ratings When Financial Guarantor
Falls Below Investment Grade" (May, 2008).  All of the securities
are insured under a financial guaranty policy, which covers timely
interest payment and ultimate principal payment, provided by
Financial Guaranty Insurance Company (FGIC, not rated).

These ratings were downgraded with a developing outlook and will
be withdrawn:

  -- $250 million INC Term Securities, Series RLIII 2006-1 debt
     rating to Baa3 from A2;

  -- $100 million INC Money Market Securities, Series RLIII 2006-1
     debt rating to Ba3 from A3;

  -- $100 million INC Money Market Securities, Series RLIII 2006-2
     debt rating to Ba3 from A3;

  -- $100 million INC Money Market Securities, Series RLIII 2006-3
     debt rating to Ba3 from A3;

  -- $100 million INC Money Market Securities, Series RLIII 2006-4
     debt rating to Ba3 from A3;

  -- $100 million INC Money Market Securities, Series RLIII 2006-5
     debt rating to Ba3 from A3.

The last rating action on the River Lake III Securities occurred
on June 29, 2009, when Moody's continued its review of the ratings
but changed the direction of the review to possible downgrade from
direction uncertain.

The River Lake III Securities' ratings were assigned by evaluating
factors believed to be relevant to the credit profile of the River
Lake III Securities such as (i) the demographics and actuarial
experience of the referenced block of (re)insurance business, (ii)
relevant industry experience for similar products/underwriting,
(iii) review of independent actuarial report, including
assumptions underlying projected cash flows, (iv) expected loss
and probability of default estimated via stochastic and
deterministic modeling of the insurance cashflows and the
performance of invested assets, and (v) other factors believed to
be applicable to the assessment of the creditworthiness of the
transaction, such as a review of the structural, legal, and
regulatory risks.


HASTINGS: S&P Gives Stable Outlook on Bonds; Keeps 'BB+' Rating
---------------------------------------------------------------
Standard & Poor's Ratings Services revised its outlook to stable
from negative and affirmed its 'BB+' long-term and underlying
rating on the City of Hastings, Minnesota's series 1998 health
care facility revenue bonds, issued on behalf of Regina Medical
Center.

"The outlook revision reflects the center's improved operating
margins and liquidity position," said Standard & Poor's credit
analyst Antionette Maxwell.  The stable outlook reflects Regina
Medical Center's operational turnaround to positive results after
two years of losses.  Although the center's operations have been
turned around to positive results after two years of losses, it is
Standard & Poor's opinion that the balance sheet provides limited
financial flexibility.  Thus, to stay at the current rating, the
center must have continued positive operations and maintain
current liquidity levels."

In October 2007, Regina Medical Center enhanced its relationship
with Allina Health System (A+) when it entered into a joint
venture, in which Allina obtained a 25% interest in Regina.  This
closer affiliation is viewed positively by Standard & Poor's as
Regina has benefited from and is expected to continue to benefit
from certain operational efficiencies and economies of scale
available to it via the joint venture.

Regina Medical Center, a 40-staffed bed acute-care hospital
(licensed for 57 staffed beds) located in Hastings, Minn., ('AA+'
general obligation debt rating).  It also includes a 61-bed
nursing home and a 134-bed assisted-living facility.


ILLINOIS STUDENT: Fitch Downgrades Ratings on Student Loans
-----------------------------------------------------------
Fitch Ratings downgrades three subordinate classes and places all
classes on Rating Watch Negative from the Federal Family Education
Loan Program student loan asset-backed notes issued by the
Illinois Student Assistance Commission 2002 General Resolution.
The trust is under-collateralized and under significant stress
with negative excess spread and declining parity.  The Global SF
Rating Criteria were used to review the transaction.

The rating actions are tied to deteriorating trust performance
with continuous decline in trust parity over the past 18 months.
As of the June 2009 Distribution Report, the total parity has
declined to 98.37% due to high trust expenses which are currently
approximately 1.2% with a cap of 1.9%.  Increased cost associated
with the failed auction of the auction-rate securities has also
put stress on the trust.

The subordinate bonds are particularly under pressure because they
do not benefit from any credit enhancement.  Although the senior
classes benefit from a parity ratio of 106.83%, they are also
under pressure as the ratio has steadily declined.  The senior
classes are not being paid down, so the parity decline has been in
step with the trust parity decline.  Both senior and subordinated
classes will be on Rating Watch Negative, as any continued
deterioration is expected to cause additional downgrades.

The subordinate classes were put on Rating Watch Negative in
December 2008 after the issuer informed Fitch of inaccuracies in
the reported parity calculations.  The reporting issue has been
resolved but the analysis based on updated information was the
basis for the most recent rating actions.

The collateral supporting the bonds consists of federally
guaranteed loans originated under the FFELP.  FFELP loans are
guaranteed by an eligible guarantor to at least 97% of principal
and accrued interest, depending on loan origination date.  The
FFELP loans are also reinsured by the U.S. Department of Education
up to the same amounts.

The student loan portfolio is serviced by ISAC acting through the
Illinois Designated Account Purchase Program, Nelnet Loan
Servicers Inc., ACS Education Services Inc, Sallie Mae Servicing
L.P., National Education Servicing LLC., Great Lakes Educational
Loan Services, Inc., Educational Services of America, Inc., and
American Education Services/Pennsylvania Higher Education
Assistance Agency.  Fitch only rates GLELSI, ACS and Sallie Mae
all of which are rated 'Proficient Plus'.

Fitch places these senior classes on Rating Watch Negative:

Illinois Student Assistance Commission 2002 General Resolution
(IL) 2002

  -- Class I-3 'AAA/LS1'.

Illinois Student Assistance Commission 2002 General Resolution
(IL) 2003

  -- Class IV-1 'AAA/LS1';
  -- Class IV-3 'AAA/LS1'.

Illinois Student Assistance Commission 2002 General Resolution
(IL) 2004

  -- Class VI-3 'AAA/LS1'.

Illinois Student Assistance Commission 2002 General Resolution
(IL) 2005

  -- Class VIII-1 'AAA/LS1';
  -- Class VIII-2 'AAA/LS1';
  -- Class VIII-3 'AAA/LS1';
  -- Class VIII-4 'AAA/LS1';
  -- Class VIII-5 'AAA/LS1';
  -- Class VIII-6 'AAA/LS1';
  -- Class VIII-7 'AAA/LS1';
  -- Class VIII-8 'AAA/LS1'.

Additionally, Fitch downgrades these subordinate notes and
maintains the Rating Watch Negative:

Illinois Student Assistance Commission 2002 General Resolution
(IL) 2002

  -- Class II to 'BB/LS3' from 'A/LS3'.

Illinois Student Assistance Commission 2002 General Resolution
(IL) 2005

  -- Class IX-1 to 'BB/LS3' from 'A/LS3';
  -- Class IX-2 to 'BB/LS3' from 'A/LS3'.


MADISON AVENUE: 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 Madison Avenue CDO I, Limited:

  -- US$24,500,000 Class C1 Floating Rate Notes due 2013 (current
     balance of US$22,989,495), Downgraded to B1; previously on
     August 24, 2006 Upgraded to Ba2;

  -- US$24,500,000 Class C2 Fixed Rate Notes due 2013, Downgraded
     to B1 (current balance of US$22,989,495); previously on
     August 24, 2006 Upgraded to Ba2.

According to Moody's, the rating actions reflect Moody's revised
assumptions with respect to default probability and the
calculation of the Diversity Score.  These revised assumptions are
described in the publication "Moody's Approach to Rating
Collateralized Loan Obligations," dated August 12, 2009.  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.  Other assumptions used in
Moody's CLO and CBO monitoring are described in the publication
"CLO Ratings Surveillance Brief - Second Quarter 2009," dated
July 17, 2009.  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, diversity score, and weighted
average recovery rate, may be different from the trustee's
reported numbers.

The rating actions taken on the notes also take into consideration
moderate credit deterioration of the underlying portfolio which is
observed through an increase in the proportion of securities from
issuers rated Caa1 and below.  In particular, securities from
issuers rated Caa1 or below by Moody's make up 21.7% of the
underlying portfolio, as of the last trustee report, dated
October 7, 2009.

Madison Avenue CDO I, Limited, issued in August of 2000, is a
collateralized bond obligation backed primarily by a portfolio of
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 and specific
documentation features.  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.


MASTR ADJUSTABLE: S&P Junks Ratings on Two 2007-R5 Certificates
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on two
classes of certificates from MASTR Adjustable Rate Mortgages Trust
2007-R5, a residential mortgage-backed securities re-securitized
real estate mortgage investment conduit transaction.  S&P lowered
its rating on class A1 to 'CCC' from 'AAA', and S&P lowered its
rating on class A2 to 'CC' from 'AAA'.

The downgrades reflect the significant deterioration in
performance of the loans backing the underlying certificate.  This
performance deterioration is so severe that the credit enhancement
for MARM 2007-R5 is insufficient to maintain the previous ratings
on the re-REMIC classes.

MARM 2007-R5, which closed in September 2007, is collateralized by
one underlying class that supports the re-REMIC classes.  The
loans securing the underlying class consist predominately of long-
reset adjustable-rate Alternative-A mortgage loans.

Classes A1 and A2 from MARM 2007-R5 are supported by the II-2A-1
class from Bear Stearns Alt-A Trust 2005-9 (currently rated
'CCC').  The performance of the loans securing this trust has
declined precipitously in recent months.  This pool had
experienced losses of 4.06% as of the October 2009 distribution,
and currently has approximately 32.20% in delinquent loans as a
percentage of the current balance.  Based on the losses to date,
the current pool factor of 0.5349 (53.49%), which represents the
outstanding pool balance as a proportion of the original balance,
and the pipeline of delinquent loans, S&P's current projected loss
for this pool is 15.78%, which exceeds the level of credit
enhancement available to cover losses.

Over the past two years, S&P has revised its RMBS default and loss
assumptions, and consequently S&P's projected losses, to reflect
the continuing decline in mortgage loan performance and the
housing market.  The performance deterioration of most U.S. RMBS
has continued to outpace the market's expectation.

                         Ratings Lowered

          MASTR Adjustable Rate Mortgages Trust 2007-R5
                         Series 2007-R5

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       A1         57645WAA8     CCC                  AAA
       A2         57645WAB6     CC                   AAA


ML-CFC COMMERCIAL: S&P Downgrades Ratings on 2007-9 Securities
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 21
classes of commercial mortgage-backed securities from ML-CFC
Commercial Mortgage Trust 2007-9 and removed them from CreditWatch
with negative implications.  In addition, S&P affirmed its ratings
on six classes from the same transaction.

The downgrades follow its analysis of the transaction using its
U.S. conduit and fusion CMBS criteria, which was the primary
driver of the rating actions.  The downgrades of the subordinate
and mezzanine classes also reflect the credit support erosion that
S&P anticipates will occur upon the eventual resolution of several
specially serviced loans.  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 1.32x and a loan-to-value ratio
of 114.6%.  S&P further stressed the loans' cash flows under its
'AAA' scenario to yield a weighted average DSC of 0.84x and an LTV
of 158.7%.  The implied defaults and loss severity under the 'AAA'
scenario were 93.7% and 38.6%, respectively.  All of the DSC and
LTV calculations S&P noted above exclude seven of the 11 specially
serviced loans ($92.8 million 3.3%).  S&P separately estimated
losses for these loans, which S&P included in its 'AAA' scenario
implied default and loss figures.

The affirmation of the ratings on the principal and interest
certificates reflects subordination levels that adequately support
the outstanding ratings.  S&P affirmed its ratings on the class XC
and XP interest-only certificates based on its current criteria.
S&P published a request for comment proposing changes to its IO
criteria on June 1, 2009.  After S&P finalizes its criteria
review, S&P may revise its IO criteria, which may affect
outstanding ratings, including the ratings on the IO certificates
that S&P affirmed.

                         Credit Concerns

As of the October 2009 remittance report, 11 assets
($248.8 million, 8.9%) in the pool are with the special servicer,
LNR Partners Inc., including two of the top 10 loans, which S&P
discuss in detail below.  The specially serviced loans by payment
status are: two are real estate owned ($6.0 million 0.2%); one is
in foreclosure ($10.2 million, 0.4%); four are more than 90 days
delinquent ($27.1 million, 1.0%); one is 60 days delinquent
($2.4 million, 0.1%); two are 30 days delinquent ($143.2 million,
5.1%); and one is less than 30 days delinquent ($60.0 million,
2.2%).

The DLJ West Coast Hotel Portfolio loan is the second-largest loan
in the pool and the largest loan with the special servicer.  The
loan has a trust balance of $130.1 million (4.7%) and is secured
by six hotel properties, five in California and one in Oregon,
totaling 1,159 rooms.  The reported DSC for the portfolio as of
year-end 2008 was 0.92x, down from 1.22x at issuance.  The loan
was transferred to the special servicer on May 15, 2009, due to a
significant drop in asset performance, and was 30 days delinquent
as of the October 2009 remittance report.  LNR is discussing
several options with the borrower at this time, and Standard &
Poor's will continue to monitor this loan.

The Janss Marketplace loan is the fourth-largest loan in the pool
and the second-largest loan with the special servicer.  The loan
has a trust balance of $60.0 million (2.2%) and is secured by a
421,196-sq.-ft. open-air lifestyle center in Thousand Oaks, Calif.
The loan was transferred to the special servicer on Aug. 18, 2009,
due to imminent default, and is less than 30 days delinquent as of
the October 2009 remittance report.  The property has two dark
tenants (Mervyn's and Linen 'n Things) who are still paying rent.
At this time, Standard & Poor's expects a moderate loss upon the
resolution of the loan.

The remaining specially serviced loans have balances that
individually represent less than 0.5% of the total pool balance.

                      Transaction Summary

As of the October 2009 remittance report, the collateral pool
balance was $2.79 billion, down slightly from $2.81 billion at
issuance.  The number of loans in the pool, at 246, is unchanged
since issuance.  The master servicers for the transaction, Wells
Fargo Bank N.A. and Midland Loan Services Inc., provided financial
information for 96.6% of the pool; 94.1% of the financial
information was full-year 2008 data or interim-2009 data.  S&P
calculated a weighted average DSC of 1.34x for the pool based on
the reported figures.  S&P's adjusted DSC and LTV were 1.32x and
114.6%, respectively.  S&P's adjusted DSC and LTV figures exclude
seven of the 11 specially serviced loans ($92.8 million 3.3%), for
which S&P separately estimated losses.  Wells Fargo provided DSC
figures for four of these loans, and based on these figures, S&P
calculated a weighted average DSC of 0.72x.  The transaction has
not experienced any principal losses to date.  Sixty-one loans
($571.9 million, 20.5%) are on master servicer's watchlist,
including three of the top 10 loans, which are discussed below.
Forty-eight loans ($676.2 million, 24.2%) have a reported DSC
below 1.10x, and 30 of these loans ($464.2 million, 16.6%) have a
reported DSC of less than 1.0x.

                      Summary of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$1.1 billion (39.2%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.32x for the top 10 loans.
Two of the top 10 loans ($190.1 million, 6.8%) are with the
special servicer, and three of the top 10 loans ($206.8 million,
7.4%) appear on master servicer's watchlist and are discussed in
detail below.  S&P's adjusted DSC and LTV for the top 10 loans are
1.32x and 116.5%, respectively.  These calculated numbers exclude
the fourth-largest loan in the pool, which is with the special
servicer and has a DSC of 0.70x.  S&P separately estimated a loss
for this loan, which is included in the 'AAA' scenario implied
default and loss figures.

The 300 Capitol Mall loan is the third-largest loan in the pool
and the largest loan on the master servicer's watchlist, with a
trust balance of $104.3 million (3.7%).  The loan, which is
secured by a 383,283-sq.-ft. office property in Sacramento,
Calif., appears on the watchlist due to low DSC.  The property was
built in 1985 and renovated in 1996.  The servicer reported a
0.98x DSC for year-end 2008, down from 1.27x at issuance.
However, the borrower has signed new leases and the property
should see an improvement in DSC.

The St. Louis Flex Office Portfolio loan is the sixth-largest loan
in the pool and the second-largest loan on the master servicer's
watchlist, with a trust balance of $52.5 million (1.9%).  The loan
is secured by six properties totaling 864,540 sq. ft. in St.
Louis.  The loan appears on the watchlist due to a drop in DSC and
occupancy.  The servicer reported a 0.89x DSC for the six months
ended June 30, 2009, down from 1.18x at issuance.  The reported
net operating income DSC for the six months ended June 30, 2009,
was 1.05x.

The Hilton Embassy Row loan is the eighth-largest loan in the pool
and the third-largest loan on the master servicer's watchlist,
with a trust balance of $50.0 million (1.8%).  The loan is secured
by a 231-room hotel in Washington, D.C.  The reported DSC for
year-end 2008 was 1.11x with a 71.0% occupancy rate, down from
1.35x and 75.0%, respectively, at issuance.

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

     Ratings Lowered And Removed From Creditwatch Negative

             ML-CFC Commercial Mortgage Trust 2007-9
          Commercial mortgage pass-through certificates

            Rating
            ------
     Class     To      From            Credit enhancement (%)
     -----     --      ----            ----------------------
     A-4       A+      AAA/Watch Neg                    30.16
     A-1A      A+      AAA/Watch Neg                    30.16
     AM        BBB+    AAA/Watch Neg                    20.11
     AM-A      BBB+    AAA/Watch Neg                    20.11
     AJ        BB+     AAA/Watch Neg                    12.06
     AJ-A      BB+     AAA/Watch Neg                    12.06
     B         BB      AA+/Watch Neg                    10.93
     C         BB-     AA/Watch Neg                     10.18
     D         B+      AA-/Watch Neg                     9.17
     E         B+      A+/Watch Neg                      8.29
     F         B+      A/Watch Neg                       7.41
     G         B       A-/Watch Neg                      6.41
     H         B       BBB+/Watch Neg                    5.40
     J         B       BBB/Watch Neg                     4.52
     K         B-      BBB-/Watch Neg                    3.39
     L         CCC+    BB+/Watch Neg                     2.89
     M         CCC+    BB/Watch Neg                      2.51
     N         CCC     BB-/Watch Neg                     2.26
     P         CCC-    B/Watch Neg                       1.76
     Q         CCC-    B-/Watch Neg                      1.63
     S         CCC-    CCC+/Watch Neg                    1.26

                        Ratings Affirmed

             ML-CFC Commercial Mortgage Trust 2007-9
         Commercial mortgage pass-through certificates

         Class      Rating      Credit enhancement (%)
         -----      ------      ----------------------
         A-1        AAA                          30.16
         A-2        AAA                          30.16
         A-3        AAA                          30.16
         A-SB       AAA                          30.16
         XC         AAA                            N/A
         XP         AAA                            N/A

                      N/A - Not applicable.


MORGAN STANLEY: Moody's Downgrades Rating on 2007-10 Notes to 'B2'
------------------------------------------------------------------
Moody's Investors Service announced that it has downgraded its
rating on notes issued by Morgan Stanley ACES SPC 2007-10, a fixed
recovery rate collateralized debt obligation transaction
referencing a static portfolio of corporate entities.

The rating action is:

  -- US$200,000,000 Class IA Secured Floating Rate Notes due 2017
     Notes, Downgraded to B2; previously on February 25, 2009
     Downgraded to Ba3.

Moody's explained that the rating action taken is the result of
the deterioration of the credit quality of the reference
portfolio.  The 10 year weighted average rating factor of the
portfolio, not adjusted with forward looking measures, has
deteriorated from 153 initially to 580, equivalent to an average
rating of the current portfolio of Baa3.  In addition, the
percentage of non-investment grade assets has increased since the
last rating action.  Since the inception of the transaction, the
subordination of the rated tranche has been reduced due to credit
events on Federal Home Loan Mortgage Corporation and Federal
National Mortgage Association.  The portfolio has the highest
industry concentrations in Banking (10%), Oil and Gas (10%),
Sovereign and Public Finance (10%) and Telecommunications(9%).

Moody's monitors this transaction using primarily the methodology
for Corporate Synthetic Obligations as described in Moody's
Special Report below:

-- Moody's Approach to Rating Corporate Collateralized Synthetic
    Obligations (14 September 2009)

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 strength of the legal
framework as well as specific documentation features, and
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.


MORGAN STANLEY: Moody's Downgrades Rating on 2006-18 Notes
----------------------------------------------------------
Moody's Investors Service announced that it has downgraded its
rating on notes issued by Morgan Stanley ACES SPC, Series 2006-18,
a fixed recovery rate collateralized debt obligation transaction
referencing a static portfolio of corporate entities.

The rating action is:

  -- US$43,000,000 ACES Series 2006-18, Downgraded to Caa3;
     previously on February 5, 2009 Downgraded to B3

Moody's explained that the rating action taken is the result of
the deterioration of the credit quality of the reference
portfolio.  The 10 year weighted average rating factor of the
portfolio, not adjusted with forward looking measures, has
deteriorated from 1246 from the last rating action to 1545,
equivalent to an average rating of the current portfolio of Ba3.
The reference portfolio includes an exposure to Ambac Assurance
Corporation which has experienced substantial credit migration in
the past few months, and are now rated Caa2.  Since the last
rating action on the transaction, the subordination of the rated
tranche has been reduced due to credit events on Abitibi-
Consolidated Inc., Visteon Corporation, Syncora Guarantee, Inc.,
and Thomson S.A. Coupled with other credit events that have been
triggered since the inception of the transaction on Federal
National Mortgage Assocation, Quebecor World, Inc., and Tribune
Company, the subordination of the rated tranche has been reduced
by 1.8%.  The portfolio has the highest industry concentrations in
Telecommunications (11%), Chemicals, Plastics, & Rubber (11%),
Insurance (11%) and Beverage, Food & Tobacco (8%).

Moody's monitors this transaction using primarily the methodology
for Corporate Synthetic Obligations as described in Moody's
Special Report below:

-- Moody's Approach to Rating Corporate Collateralized Synthetic
    Obligations (14 September 2009)

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 strength of the legal
framework as well as specific documentation features, and
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.


PEGASUS AVIATION: Moody's Reviews Ratings on Three Securitizations
------------------------------------------------------------------
Moody's Investors Service announced that it is placing under
review for possible downgrade all of its outstanding ratings on
three separate pooled aircraft lease-backed securitizations issued
by Pegasus Aviation, Inc. The three transactions have been
experiencing further decline in their cash flows during the past
12 months.  The decline in the cash flows stems from these: (i)
lower lease rates on new lease agreements, (ii) a large number of
aircraft which are on the ground and are either not under lease
agreement or have prospective lease agreements for lower lease
rates, (iii) delinquent and bankrupt lessees, and (iv) increased
expenses.  In addition, recent appraisals of the aircraft in the
respective pools came in at more than 35% below their assumed
values.

The aircraft portfolio backing Pegasus Aviation Lease
Securitization Trust, Series 1999-1 contains many old-vintage,
less popular aircraft types, which have experienced large declines
in demand and whose values have declined notably over the last
couple of years.  This is evident by the portfolio value and the
number of aircraft on ground: the most recent portfolio value is
more than 40% below its assumed value and there are currently
seven aircraft on the ground out of 22 aircraft in the portfolio
(these aircraft account for approximately 11.5% of the portfolio
value).  In addition, since May 2003, the Class A Notes have not
received any principal payments.  The Class A principal payments
are subordinate to potentially high operational expenses and Class
B and C interest; therefore it is expected that the principal
payments on the Class A will continue to miss minimum levels in
future.

Pegasus Aviation Lease Securitization II, Series 2000-1 (PALS
2000) also contains many older and less popular aircraft types.
The portfolio value for this transaction is more than 35% below
its assumed value, and there are currently nine aircraft on ground
out of the 27 aircraft in the portfolio; the aircraft on the
ground account for approximately 22% of the portfolio value.  Some
of those aircraft have prospective lease agreements, but those are
expected to generate significantly lower lease rates compare to
the previous agreements.  The Class A notes receive some principal
payments, but has fallen further behind compared to their
scheduled amortization.

Pegasus Aviation Lease Securitization Trust III, Series 2001-1
(PALS 2001) has a younger and more marketable pool of aircraft
compared to the aircraft in the PALS 1999 and 2000 transactions.
Currently there are eight aircraft on the ground out of 39
aircraft in the portfolio.  Some of those aircraft have
prospective lease agreements, but those are expected to generate
significantly lower lease rates compare to the previous
agreements.  The transaction continues to make principal payments,
but only on the most senior class; the Class A-3 notes.
Nevertheless, the principal paydown on the Class A-3 has fallen
behind the extended payment schedule and there is a concern
whether the class A-3 will be fully repaid by its legal final
maturity of March 2014.

Moody's review will focus on several factors, including: (i) the
potential lease revenues that might be generated on the aircraft
that are currently off-lease or that will be coming off-lease
within the next twelve months; (ii) the impact of delinquent lease
payments on revenues; (iii) current and future expenses relating
to repossession, remarketing, and maintenance of aircraft from
current lessees; and (iv) the marketability of mid-life and old
technology aircraft in the current environment.

The complete ratings actions:

Issuer: Pegasus Aviation Lease Securitization Trust, Series 1999-1

  -- Class A-1, Caa1 Placed Under Review for Possible Downgrade;
     previously on July 2, 2004 Downgraded to Caa1

  -- Class A-2, Caa1 Placed Under Review for Possible Downgrade;
     previously on July 2, 2004 Downgraded to Caa1

Issuer: Pegasus Aviation Lease Securitization II (PALS), Series
2000-1

  -- Class A-1, B3 Placed Under Review for Possible Downgrade;
     previously on July 2, 2004 Downgraded to B3

  -- Class A-2, B3 Placed Under Review for Possible Downgrade;
     previously on July 2, 2004 Downgraded to B3

Issuer: Pegasus Aviation Lease Securitization III (PALS III),
Series 2001-1

  -- Class A-1, B2 Placed Under Review for Possible Downgrade;
     previously on Oct. 24, 2005 Downgraded to B2

  -- Class A-2, B2 Placed Under Review for Possible Downgrade;
     previously on Oct. 24, 2005 Downgraded to B2

  -- Class A-3, B2 Placed Under Review for Possible Downgrade;
     previously on Oct. 24, 2005 Downgraded to B2

  -- Class B-1, Caa2 Placed Under Review for Possible Downgrade;
     previously on Oct. 24, 2005 Downgraded to Caa2

  -- Class B-2, Caa2 Placed Under Review for Possible Downgrade;
     previously on Oct. 24, 2005 Downgraded to Caa2

  -- Class C-1, Caa3 Placed Under Review for Possible Downgrade;
     previously on Oct. 24, 2005 Downgraded to Caa3

  -- Class C-2, Caa3 Placed Under Review for Possible Downgrade;
     previously on Oct. 24, 2005 Downgraded to Caa3

  -- Class D-1, Caa3 Placed Under Review for Possible Downgrade;
     previously on July 2, 2004 Downgraded to Caa3


PETER COOPER: Fitch Downgrades Ratings on 19 Classes
----------------------------------------------------
Fitch Ratings has downgraded, revised Loss Severity ratings and
maintained a Negative Outlook on 19 classes from three U.S. CMBS
transactions due to increased loss expectations for the Peter
Cooper Village/Stuyvesant Town loan.

The affected transactions are:

  -- WBCMT 2007-C30;
  -- ML-CFC 2007-5;
  -- ML-CFC 2007-6.

A detailed list of rating actions follows at the end of this
release.

The downgrades are due to the recent ruling by the New York State
Court of Appeals and the continued underperformance of the PCV/ST
loan.  The adverse ruling against the loan sponsors, Tishman
Speyer Properties, LP and Blackrock Realty, is likely to stop the
conversion of rent-stabilized units to market rate units and has
made the owners liable for repayments of rent overcharges for unit
conversions now deemed illegal.

Fitch has lowered its value estimate of the property to
$1.8 billion based on second quarter 2009 (2Q'09) financials and a
cap rate of 7%.  In its analysis of the loan, Fitch no longer
assumes income growth form the conversion of rent stabilized units
to market based on the courts ruling that the owners cannot
continue to convert stabilized units to markets while receiving J-
51 tax benefits.  The amount of historical overcharges the
sponsors are now liable to repay is uncertain at this time and are
also not factored into Fitch's loss estimate due the uncertainty
of the amount.

Cash flow generated from the property remains significantly below
what is needed to service the current outstanding debt, and the
borrower continues to use debt service reserves to cover operating
shortfalls.  The balance of the debt service reserve as of October
2009 was $24.4 million and is likely to be sufficient to only make
the November and December debt service payments.  Once the
reserves have been depleted, Fitch believes a default of the loan
and transfer to the special servicer is likely.

Upon default, the special servicer will need an updated appraisal.
If this is significantly lower than the outstanding loan amount,
appraisal subordinate entitlement reductions (ASERs) based on an
appraisal reduction amount (ARA) will cause interest shortfalls on
multiple classes in the transactions.  Rating of these classes may
be downgraded further based on the recoverability of interest
shortfalls.  Based on Fitch's estimated value, Fitch projects the
monthly ASERs to affect these classes:

  -- WBCMT 2007-C30: Classes C (now rated 'BB') through S;
  -- ML-CFC 2007-5: Classes B (now rated 'BB') through Q;
  -- ML-CFC 2007-6: Classes F (now rated 'B-') through Q.

Fitch's expected losses, based on current cash flow, are 40% of
the $3 billion A note balance.  However, although a default is
expected in the near term, a lengthy workout is also expected and
full losses may not be realized until loan's maturity in 2016.
Fitch is recognizing 50% of potential future losses in its rating
actions due to Fitch's expectation of a complex workout of the
loan.  There are many factors to be considered including a
possible modification, potential legislative changes to rent
stabilization laws that may alter the value of the property, and
the low loan per unit ($267,213).

Fitch's recognized losses of $600 million on the entire A Note
include the potential principal losses to the individual
transactions and estimated costs associated with expected special
servicing fees, advances and potential legal fees.  Fitch will
continue to monitor this loan and adjust recognized losses as
events transpire, including any potential defaults or
modifications of the loan.

For the year ended 2008, the servicer reported debt service
coverage ratio on the mortgage was 0.69 times (x), as compared to
the year ended 2007 DSCR of 0.55x.  For 2Q'09, the servicer
reported DSCR was 0.65x.  As of July 2009, approximately 60% were
rent-stabilized units and 40% were market units with a vacancy
rate of approximately 4%.  In addition to the securitized balance,
there is an additional $1.5 billion of mezzanine debt held outside
the trust.

Stuyvesant Town/Peter Cooper Village is comprised of 56 multistory
buildings, situated on 80 acres, and includes a total of 11,227
apartments.  The loan sponsors, Tishman Speyer Properties, LP and
Blackrock Realty, acquired the property with the intent of
converting rent-stabilized units to market rents as tenants
vacated the property.

Fitch has taken these rating actions:

WBCMT 2007-C30

  -- $671.8 million class A-J to 'BB/LS4' from 'A/LS3'; Outlook
     Negative;

  -- $49.4 million class B to 'BB/LS5' from 'BBB/LS5'; Outlook
     Negative;

  -- $79 million class C to 'BB/LS5' from 'BBB-/LS5'; Outlook
     Negative;

  -- $69.2 million class D to 'B/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $59.3 million class E to 'B/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $69.2 million class F to 'B-/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $98.8 million class G to 'B-/LS5' from 'B/LS5'; Outlook
     Negative.

Additionally, Fitch has revised the Loss Severity (LS) Rating for
these 'AAA' rated classes to 'LS2' from 'LS1':

  -- $21.4 million class A-1;
  -- $100 million class A-2;
  -- $908.7 million class A-3;
  -- $195.5 million class A-4;
  -- $126.9 million class A-PB;
  -- $1.8764 billion class A-5;
  -- $2.2884 billion class A-1A.

ML-CFC 2007-5

  -- $211.5 million class AJ to 'BB/LS3' from 'A/LS3'; Outlook
     Negative;

  -- $175 million class AJ-FL to 'BB/LS3' from 'A/LS5'; Outlook
     Negative;

  -- $77.3 million class B to 'BB/LS5' from 'BBB-/LS5'; Outlook
     Negative;

  -- $33.1 million class C to 'BB/LS5' from 'BBB-/LS5'; Outlook
     Negative;

  -- $77.3 million class D to 'B-/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $38.6 million class E to 'B-/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $55.2 million class F to 'B-/LS5' from 'B/LS5'; Outlook
     Negative.

Fitch revises the Rating Outlook to Negative from Stable for these
'AAA' rated classes:

  -- $341.7 million class AM;
  -- $100 million class AM-FL.

Additionally, Fitch revises the LS Rating for these 'AAA' rated
classes to 'LS2' from 'LS1':

  -- $47.2 million class A-1;
  -- $63.3 million class A-2;
  -- $60 million class A-2FL;
  -- $153.4 million class A-3;
  -- $187.1 million class A-SB;
  -- $1.1998 billion class A-1A;
  -- $1.0902 billion class A-4;
  -- $245 million class A-4FL.

ML-CFC 2007-6

  -- $107.4 million class AJ to 'BB/LS4' from 'BBB-/LS3'; Outlook
     Negative;

  -- $75 million class AJ-FL to 'BB/LS4' from 'BBB-/LS5'; Outlook
     Negative;

  -- $42.9 million class B to 'B/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $16.1 million class C to 'B/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $34.9 million class D to 'B-/LS5' from 'B/LS5'; Outlook
     Negative.

Additionally, Fitch revises the LS Rating for these 'AAA' rated
classes to 'LS2' from 'LS1':

  -- $15.3 million class A-1;
  -- $170.4 million class A-2;
  -- $150 million class A-2FL;
  -- $60.7 million class A-3;
  -- $729 million class A-4;
  -- $363.4 million class A-1A.


RBSSP RESECURITIZATION: Moody's Puts Ratings on 2009-11 Securities
------------------------------------------------------------------
Moody's Investors Service has assigned the below-mentioned ratings
to the Securities issued in connection with RBSSP Resecuritization
Trust 2009-11.

Classes 1-A1 and 1-A2 are backed by Class A-I-6 ("Underlying
Security 1") issued by RAMP Series 2004-RS6 Trust.  The Underlying
Security 1 is backed primarily by first -lien, fixed-rate Subprime
residential mortgage loans.  Class 1-A1 is a senior class whereas
Class 1-A2 is a subordinate class which receives principal payment
after Class 1-A1 but absorbs losses before Class 1-A1.

Classes 2-A1 and 2-A2 are backed by Class IA-2 (the "Underlying
Security 2") issued by Bear Stearns Asset Backed Securities I
Trust 2006-HE6.  The Underlying Security 2 is backed primarily by
first -lien, fixed and adjustable-rate, Subprime residential
mortgage loans.  Class 2-A1 is a senior class whereas Class 2-A2
is a subordinate class which receives principal payment after
Class 2-A1 but absorbs losses before Class 2-A1.  Additionally,
Class 2-A2 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 2-A2 is used to pay down
Class 2-A1 certificate.

Classes 3-A1 and 3-A2 are backed by Class A-2 (the "Underlying
Security 3") issued by Carrington Mortgage Loan Trust, Asset-
Backed Pass-Through Certificates, Series 2006-NC4.  The Underlying
Security 3 is backed primarily by first -lien, fixed and
adjustable-rate, Subprime residential mortgage loans.  Class 3-A1
is a senior class whereas Class 3-A2 is a subordinate class which
receives principal payment after Class 3-A1 but absorbs losses
before Class 3-A1.  Additionally, Class 3-A2 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 3-A2 is used to pay down Class 3-A1 certificate.

Classes 4-A1, 4-A2 and 4-A3 are backed by Class A-2 (the
"Underlying Security 4") issued by Saxon Asset Securities Trust
2007-4.  The Underlying Security 4 is backed primarily by first -
lien, fixed and adjustable-rate, Subprime residential mortgage
loans.  Principal is distributed sequentially fist to Class 4-A1,
second to Class 4-A2, third to Class 4-A3.  Losses are distributed
sequentially first to Class 4-A3, second to Class 4-A2, third to
Class 4-A1.  Additionally, Classes 4-A2 and 4-A3 are "Accrual
Securities," i.e. they accrue the interest that would have been
paid to them.  Cashflows generated due to such accrual of interest
is distributed as principal sequentially to first Class 4-A1, and
second to Class 4-A2.

Classes 5-A1 and 5-A2 are backed by Class A-1 (the "Underlying
Security 5") issued by Morgan Stanley Structured Trust I 2007-1.
The Underlying Security 5 is backed primarily by first and second-
lien, fixed and adjustable-rate, Subprime residential mortgage
loans.  Class 5-A1 is a senior class whereas Class 5-A2 is a
subordinate class which receives principal payment after Class 5-
A1 but absorbs losses before Class 5-A1.  Additionally, Class 5-A2
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 5-A2 is used to pay down Class 5-A1
certificate.

The ratings on the Resecuritized Securities 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 stressed prepayment and loss
assumptions on the remaining pools of mortgages in each of the
underlying transactions.  The updated assumptions considered,
among other things, each 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 the proposed structure on each of the
Resecuritized Certificates.  Third, Moody's analyzed the loss on
the Resecuritized Securities at a rating-specific stress level,
and the sensitivity of loss for the Resecuritized Securities to
changes in prepayment and loss timing assumptions.  In Moody's
opinion the issuer's targeted levels of credit enhancement for
each of the Resecuritized Securities was consistent with the
respective rating.

In conformity with Moody's published methodology Moody's considers
that mortgage loan modifications will result in some reduction in
RMBS pool losses and that view is reflected in Moody's expectation
of losses.  At the same time, should the environment continue to
worsen the benefits from modifications may not be as significant.
Therefore, in assigning these ratings Moody's reduced the benefit
that modifications are likely to have on overall loss
expectations.  Additionally, Moody's conducted sensitivity tests
for losses across a range of prepayment and loss timing scenarios.
This sensitivity analysis was conducted for each of the Underlying
Security independently.  Under this range of scenarios the lowest
cumulative pool loss on each of the underlying deals that is
likely to result in credit losses to the each of the Resecuritized
tranches is given below.  This loss threshold is presented both as
a fraction of current pool balance and original pool balance, with
the latter including any cumulative losses till date.

  -- Cl. 1-A1, Assigned Aaa; RAMP Series 2004-RS6 Trust; 45%CB or
     18%OB

  -- Cl. 2-A1, Assigned A2; Bear Stearns Asset Backed Securities I
     Trust 2006-HE6; 73%CB or 46%OB

  -- Cl. 3-A1, Assigned Aa2; Carrington Mortgage Loan Trust,
     Series 2006-NC4; 76%CB or 55%OB

  -- Cl. 4-A1, Assigned Aa3; Saxon Asset Securities Trust 2007-4
     for Class 4-A1; 85%CB or 72%OB

  -- Cl. 4-A2, Assigned B2; Saxon Asset Securities Trust 2007-4;
     62%CB or 54%OB

  -- Cl. 5-A1, Assigned Baa2; Morgan Stanley Structured Trust I
     2007-1; 81%CB or 70%OB

  * Note: The above numbers are based on September, 2009
    remittance reports.

It should also be noted that the underlying RMBS securities for
all of the groups are owned by one trust.  With respect to
cashflow from the underlying RMBS securities, each of the Moody's
rated groups in the Resecuritized Transaction is an independent
structure, i.e. it collects the cashflow on a given underlying
RMBS security and passes it to the resecuritized tranches for that
given group.  Nevertheless, certain unexpected administrative
expenses may be shared by all the groups.

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.

Issuer: RBSSP Resecuritization Trust 2009-11

  -- Cl. 1-A1, Assigned Aaa
  -- Cl. 2-A1, Assigned A2
  -- Cl. 3-A1, Assigned Aa2
  -- Cl. 4-A1, Assigned Aa3
  -- Cl. 4-A2, Assigned B2
  -- Cl. 5-A1, Assigned Baa2


RESTRUCTURED ASSET: Moody's Downgrades Ratings on 2006-14-E Certs.
------------------------------------------------------------------
Moody's Investors Service announced that it has downgraded its
rating of these notes issued by Restructured Asset Certificates
with Enhanced Returns, Series 2006-14-E:

  -- US$20,200,000 Restructured Asset Certificates with
     Enhanced Returns, Series 2006-14-E Certificates due 2011
     (current balance of $8,566,132) Downgraded to Ba3;
     previously on October 30, 2006 Assigned Baa2.

According to Moody's, the rating action is the result of
deterioration in the underlying tranches of the repack.

RACERS, Series 2006-14-E, issued on October 30, 2006, is a repack
of the Class A-1 Senior Secured Floating Rate Notes due 2011, the
Class A-3 Senior Secured HYPPO Notes due 2011 and the Class B
Senior Subordinate Secured Fixed Rate Notes due 2001 issued by PPM
America High Yield CBO I Company Ltd., a collateralized bond
obligation backed primarily by a portfolio of senior unsecured
bonds, and the Class D Floating Rate Deferrable Notes due 2011
issued by EXUM Ridge CBO 2006-5, Ltd., a synthetic collateralized
bond obligation referencing primarily a portfolio of senior
unsecured bonds.  The Class A-1 Notes issued by PPM America High
Yield CBO I Company Ltd. was downgraded to Ca from Caa3 on
October 28, 2009.  The Class A-2 Notes and Class A-3 notes issued
by PPM America High Yield CBO I Company Ltd. are each rated C.
Finally, the Class D Notes issued by EXUM Ridge CBO 2006-5, Ltd.
is currently rated Baa2 and is deferring interest.

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.


RESIDENTIAL ASSET: S&P Downgrades Ratings on Three 2007-R1 Certs.
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on three
classes of certificates from Residential Asset Securitization
Trust 2007-R1, a U.S. residential mortgage-backed securities
resecuritized real estate mortgage investment conduit transaction.
S&P lowered the ratings on classes A-1 and A-2 to 'CCC' from 'AAA'
and lowered the rating on class A-3 to 'CC' from 'AAA'.  The
downgrades reflect significant deterioration in the performance of
the loans backing the underlying certificate.  This performance
deterioration is so severe that the credit enhancement for RAST
2007-R1 is insufficient to maintain the ratings on the re-REMIC
classes.

RAST 2007-R1, which closed in August 2007, is collateralized by
one underlying class that supports the re-REMIC.  The loans
securing the underlying class consist predominantly of fixed-rate
Alternative-A mortgage loans.

Classes A-1, A-2, and A-3 from RAST 2007-R1 are supported by the
2-A-1 class from Residential Asset Securitization Trust 2007-A2
(currently rated 'CCC').  The performance of the loans securing
this trust has declined precipitously in recent months.  This pool
had experienced losses amounting to 2.79% of the original pool
balance as of the October 2009 distribution, and delinquent loans
total approximately 28.69% of the current pool balance.  Based on
the losses to date, the current pool factor of 0.7683 (76.83%),
which represents the outstanding pool balance as a proportion of
the original balance, and the pipeline of delinquent loans, S&P's
current projected loss for this pool is 19.60%, which exceeds the
level of credit enhancement available to cover losses.

Over the past two years S&P has revised its RMBS default and loss
assumptions, and consequently S&P's projected losses, to reflect
the continuing decline in mortgage loan performance and the
housing market.  The performance deterioration of most U.S. RMBS
has continued to outpace the market's expectations.


RESIDENTIAL ASSET: S&P Downgrades Ratings on Two 2006-R1 Certs.
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class A-1 and A-2 certificates from Residential Asset
Securitization Trust 2006-R1, a U.S. residential mortgage-backed
securities resecuritized real estate mortgage investment conduit
transaction.  S&P lowered S&P's ratings on both classes to 'CC'
from 'AAA'.

The downgrades reflect significant deterioration in the
performance of the loans backing the underlying certificate.  This
performance deterioration is so severe that the credit enhancement
for RAST 2006-R1 is insufficient to maintain S&P's previous
ratings on the re-REMIC classes.

RAST 2006-R1, which closed in May 2006, is collateralized by one
underlying class that supports both classes within the re-REMIC.
The loans securing the underlying class consist predominantly of
fixed-rate Alternative-A mortgage loans.

Classes A-1 and A-2 from RAST 2006-R1 are supported by class A-1
from Residential Asset Securitization Trust 2006-A3CB (currently
rated 'CCC').  The performance of the loans securing this trust
has declined precipitously in recent months.  This pool had
experienced losses amounting to 4.85% of the original pool balance
as of the October 2009 distribution date, and delinquent loans
represent approximately 34% of the current pool balance.  Based on
the losses to date, the current pool factor of 0.636 (63.60%),
which represents the outstanding pool balance as a proportion of
the original balance, and the pipeline of delinquent loans, S&P's
current projected loss for this pool is 20.76%, which exceeds the
level of credit enhancement available to cover losses.

Over the past two years, S&P has revised S&P's RMBS default and
loss assumptions, and consequently S&P's projected losses, to
reflect the continuing decline in mortgage loan performance and
the housing market.  The performance deterioration of most U.S.
RMBS has continued to outpace the market's expectations.

                         Ratings Lowered

          Residential Asset Securitization Trust 2006-R1
                          Series 2006-R1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-1        76113MAA3     CC                   AAA
        A-2        76113MAB1     CC                   AAA


RESIDENTIAL MORTGAGE: Moody's Downgrades Rating on 2008-2 Notes
---------------------------------------------------------------
Moody's Investors Service has downgraded the rating on the Notes
issued in Residential Mortgage Securities Funding 2008-2.

The note in the resecuritization is backed by several securities,
which in turn are backed by residential mortgage loans.  This
rating action has been triggered by changes in performance and/or
Moody's ratings on the underlying residential mortgage-backed
securities (underlying securities).  The rating on the notes in
the resecuritization is based on:

   (i) The updated expected loss of the pool of loans backing the
       underlying securities portfolio and the updated ratings on
       the underlying securities portfolio

  (ii) The available credit enhancement on the underlying
       securities, and

(iii) The structure of the resecuritization transaction.

(1) Moody's first updated its loss assumptions on the underlying
    pool of mortgage loans (backing the underlying securities) and
    then arrived at updated ratings on the underlying securities.

Certain resecuritizations may contain underlying securities that
were not originally rated by Moody's.  In this case, lifetime
roll-rates (probabilities of transition to default) were applied
to the current delinquency pipeline buckets to calculate a
pipeline default rate.  This value was then multiplied by a
replication factor to account for additional loans that are
expected to default over the remaining life of the deal.  The
replication factor differed for each deal based on pool factor and
current delinquency pipeline (higher pool factors and lower
delinquency pipelines resulted in higher replication factors, for
example).  The final expected default number was then multiplied
by an expected loss severity (based on vintage and product type -
older vintages from better performing deals had lower expected
severities) to arrive at an estimated expected loss.  In addition,
expected losses for deals with 50 or fewer loans remaining (these
deals referred to as "low pool factor") were subject to additional
stresses for replication factors and severities to account for
increased volatility.  An implicit rating was determined by
comparing current available credit enhancement for the non-rated
tranche to the estimated expected loss for the deal.

The ratings on the underlying securities are then used to derive a
weighted average portfolio rating based on a weighted average
rating factor.  To determine the portfolio WARF, Moody's assigns
the ratings on the underlying securities a Rating Factor based on
Moody's published 10-yr idealized loss expectations.  Weights are
assigned to each Rating Factor based on the contribution (by
outstanding pledged balance) of the underlying security to the
resecuritized transaction.

(2) Second, Moody's determines the weighted average credit
    enhancement available to the portfolio security by evaluating
    the loss coverage level consistent with the ratings on the
    underlying securities and the underlying mortgage pool losses
    and weighting them based on the outstanding pledged balance of
    the underlying securities.

(3) Finally, the ratings on the bonds issued in the
    resecuritization are determined after taking into
    consideration additional structural aspects of the
    resecuritization.  For transactions where only a single
    tranche is issued, the weighted average portfolio rating (as
    determined in step 1 above) is the rating assigned to the
    tranche.  Where multiple securities are issued, the loss
    allocation and cash flow priority are taken into
    consideration.  For instance where the notes in the
    resecuritization are tranched into a super senior tranche and
    a support tranche, the support tranche is notched down to
    reflect a higher severity of loss to that tranche.  The rating
    on the super senior tranche is determined based on the total
    credit enhancement available i.e. the credit enhancement
    assessed in step (2) and the additional enhancement from the
    support tranche.

The probability of default for the junior-most note in the
resecuritization is the same as the probability of default for the
lowest rated underlying note.  However, Moody's anticipates a
higher loss severity on the junior-most class due to its
subordinate position (both in terms of principal distribution and
loss allocation) and smaller size (when compared to underlying
note).  Therefore, the ratings on junior notes in the
resecuritization are lower than the portfolio rating on the
combined underlying bonds.

Because the rating on the note in the resecuritization is linked
to the ratings on the underlying notes and their mortgage pool
performance, any rating action on the underlying notes may trigger
a further review of the rating on the note in the
resecuritization.  The rating on this note in the resecuritization
address the ultimate payment of promised interest and principal
and do not address any other amounts that may be payable on the
notes.

For securities insured by a financial guarantor, the rating on the
securities is equal to the higher of (i) the guarantor's financial
strength rating and (ii) the current underlying rating (i.e.,
absent consideration of the guaranty) on the security.  The
principal methodology used in determining the underlying rating is
the same methodology for rating securities that do not have a
financial guaranty and is as described above.

Complete Rating Action:

Issuer: Residential Mortgage Securities Funding 2008-2, Ltd.

  -- Notes, Downgraded to C; previously on Jul 15, 2009 Downgraded
     to Ba3


RFC CDO: Fitch Downgrades Ratings on Eight Classes of Notes
-----------------------------------------------------------
Fitch Ratings has downgraded eight classes of notes issued by RFC
CDO II, Ltd., as a result of continued credit deterioration in the
portfolio since Fitch's last rating action in March 2009.
Approximately 47.5% of the portfolio has been downgraded since the
last review.  The details of the rating action follow at the end
of this press release.

The downgrades to the portfolio have left approximately 51.5% of
the portfolio with a Fitch derived rating below investment grade
and 31.4% with a rating in the 'CCC' rating category or lower,
compared to 23% and 9%, respectively, at last review.  Defaulted
securities, per the transaction's governing documents, now
comprise 13.3% of the portfolio, compared to 2.6% at last review.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  These default levels were then
compared to the breakeven levels generated by Fitch's cash flow
model of the CDO under various default timing and interest rate
stress scenarios, as described in the report 'Global Criteria for
Cash Flow Analysis in Corporate CDOs'.  Based on this analysis,
the class A-1 notes' breakeven rates are generally consistent with
a 'BBB' rating.

The Negative Outlook on the class A-1 notes is due to the
concentration of residential mortgage-backed securities in the
portfolio, which are expected to continue to face ratings
volatility in the next one to two years.

The class A-1 notes are assigned a Loss Severity rating of 'LS3'.
The LS rating indicates a tranche's potential loss severity given
default, as evidenced by the ratio of tranche size to the base-
case loss expectation for the collateral, as explained in
'Criteria for Structured Finance Loss Severity Ratings'.  The LS
rating should always be considered in conjunction with the
probability of default for tranches.

The class A-2 notes are downgraded to 'CCC' and the class B-1 and
B-2 notes are downgraded to 'CC' due to the degree of
deterioration within the underlying portfolio.  While these
classes are still receiving timely interest distributions, Fitch
believes that based on the current credit quality of the
portfolio, default is a real possibility for the class A-2 notes
and highly probable for the class B-1 and B-2 notes at or prior to
maturity.

The class C, D, E, and F notes are no longer receiving interest
distributions due to the failing class A/B overcollateralization
test and are not expected to receive any proceeds going forward.
Therefore the notes are downgraded to 'C' to indicate Fitch's
belief that default is inevitable at or prior to maturity.

RFC II is a structured finance collateralized debt obligation that
closed on March 3, 2005, and is monitored by Castle Peak Capital
Advisors, LLC.  The portfolio is composed of RMBS (87.5%) and
commercial mortgage-backed securities (12.5%).

Fitch has downgraded and assigned LS ratings as indicated:

  -- $88,895,304 class A-1 notes to 'BBB' from 'AA'; Outlook
     Negative; assigned 'LS3';

  -- $39,000,000 class A-2 notes to 'CCC' from 'AA';

  -- $6,000,000 class B-1 notes to 'CC' from 'BB';

  -- $6,000,000 class B-2 notes to 'CC' from 'BB';

  -- $13,500,000 class C notes to 'C' from 'B';

  -- $3,380,203 class D notes to 'C' from 'CCC';

  -- $3,380,203 class E notes to 'C' from 'CCC';

  -- $3,000,000 class F notes to 'C' from 'CC'.


SAN JOAQUIN HILLS: Moody's Affirms 'Ba2' Rating on Two Bonds
------------------------------------------------------------
Moody's has affirmed the Ba2 underlying rating and negative
outlook for the revenue bonds of the San Joaquin Hills
Transportation Corridor Agency.  The rating applies to
$2.047 billion of outstanding Series 1993 and Series 1997 revenue
bonds issued by the agency to finance the construction of a 15-
mile limited access toll road (State Route 73) in Orange County
(Aa2 issuer rating).

The Ba2 rating is based on the sound economic profile of the
service area and Moody's expectation of continued traffic growth
and congestion; the availability of reserves and additional
liquidity provided by payments from its sister agency, the
Foothill/Eastern TCA (F/ETCA rated Baa3 stable outlook), pursuant
to a November 2005 mitigation and loan agreement.  On June 30,
2009 the agency received its last installment of $30 million of a
total of $120 million in mitigation payments.  Additional support
provided in the agreement includes up to $1.04 billion loans from
F/ETC if needed to meet SJHTCA's rate covenant.  The Ba2 rating is
dependent on the operating support from F/ETCA, accordingly
SJHTCA's rating is closely tied to the credit quality of F/ETCA.

Legal Security: Net toll road and other available revenues (mainly
account maintenance fees, violation fees and fines, investment
income and development impact fees) and mitigation payments and
loans from F/ETCA.

Interest Rate Derivatives: None.

                            Strengths

* The agency has independent toll raising ability, and service
  area socio-economic indicators are above average

* Mitigation payments set aside in a toll stabilization account
  combined with a cash funded debt service reserve of $211 million
  provide significant financial cushion.  Up to $1.04 billion in
  loans from F/ETCA could be available to help meet rate covenant

                           Challenges

* Toll transactions and revenues continue to severely lag the
  forecast (FY 2009 revenues are 65.8% of forecast; transactions
  49.2%)

* Debt service costs ramp up steadily and payment depends on
  continued revenue growth, regular toll rate increases and
  support from F/ETCA mitigation payments and loans

* Construction of the Foothill/South (F/S) project could pressure
  F/ETCA finances, depending on its cost, finance plan, and
  financial feasibility, thus constraining amount of funds
  available to make loans to SJHTCA

                        Recent Developments

Fiscal year 2009 traffic is down 10.8% and revenue down 5.5% due
to the impact of the economic recession.  These declines follow a
traffic drop of 3.3% and a revenue increase of 2.7% in FY 2008.
Through the first quarter of FY 2010, which ended in
September,traffic, is down 7.9%, and revenues also are down 1.5%
despite the 25 cent toll rate increase at the mainline and two
ramp plazas implemented at the start of the fiscal year.  Moody's
notes that traffic and revenues severely lag the traffic
consultant's 1999 projections, with FY 2009 transactions at 49.2%
and revenues at 65.8% of the forecast.  Since FY 1998 neither
transactions nor revenues have met the forecast.

The FY 2009 debt service coverage ratio was 1.35x including
$27.5 million in toll stabilization funds and 0.94x excluding this
amount.  This highlights the reliance of SJHTCA on F/ETCA for
operating support.  Traffic and revenue declines as well as lower
interest earnings on investments and reduced development impact
fee revenues continue to place negative credit pressure on the
agency.

The agency has some available liquidity at the start of FY 2010
with approximately $97.5 million available in cash and investments
($21 million unrestricted), including a $60 million stabilization
account fund balance, in addition the agency also has a
$211 million cash funded DSRF.  Moody's notes that $28.7 million
stabilization account balances have been budgeted towards meeting
the rate covenant in FY 2010, which will leave a balance of
$31.3 million for future years.

The FY 2010 budget was reduced by 28.4% from FY 2009.  Though most
of the cutbacks are for discretionary capital expenditures, the
agency trimmed operating expenditures through salary and position
freezes.  The budget assumes net toll revenues of $84.1 million,
which is approximately 63% of the 1997 forecast and a .7% increase
over FY 2009 toll revenues.  The revenue increase is due to a 25
cent toll increase implemented at the mainline and two ramp toll
plazas.  The FY 2010 DSCR is budgeted at 1.32x, which complies
with the rate covenant of 1.3x.  The agency is quite vulnerable to
escalating debt service requirements which rise from $96 million
in FY 2010 to $115 million in FY 2012 and peak at $225 million in
2033.  In addition to access to up to $1.04 billion in loans that
could be obtained under the mitigation agreement, which would have
to be repaid to F/ETCA, the agency is considering additional toll
increases and/or possible consolidation of the two agencies.

In November 2005 the agency entered into mitigation and loan
agreement to offset toll revenue diversion impact of the planned
Foothill South (F/S) extension to complete the 241 toll road and
connect to I-5.  F/ETCA has paid $120 million in mitigation
payments since then to help SJHTCA meet its 1.3x rate covenant.
These funds were deposited into the toll stabilization account
(TSA) and applied to SJHTCA debt service as necessary.  The
mitigation agreement with SJHTCA also allows F/ETCA to make up to
$1.04 billion in loans to help San Joaquin meet its rate covenant
although it could affect future liquidity at F/ETCA.  The last
required mitigation payment was made June 30 2009.  The payments
become loans if the F/S extension is not built.  In February 2009
the California Coastal Commission denied and the U.S. Department
sustained on appeal the required certification for permitting of
the extension project.  The boards and management of the two
agencies are currently evaluating all of their options including
whether to litigate the Coastal Commission decision.  The most
recent estimate of the extension project cost is $1.218 billion in
2010 dollars; however, this could increase with additional
implementation delays and/or significant design changes.

Background/Governance: SJTCA opened to traffic in 1996 as the
first publicly owned toll road in California.  The toll road is
15-mile limited access four to six lane facility that connects to
I-405 at the north and I-5 at the south alignment.  The agency is
a joint powers agency under state law and governed by independent
board comprised of 14 local government officials from 14 city and
county entities.  SJHTCA entities represented on the board are
Aliso Viejo, Costa Mesa, Dana Point, Irvine, Laguna Hills, Laguna
Niguel, Laguna Woods, Mission Viejo, Newport Beach, San Clemente,
San Juan Capistrano, Santa Ana, and the Orange Count's 3rd and 5th
Districts.  Eight of the SJHTCA member agencies sit on the F/ETCA
board.  In 1997 the agency restructured its debt and extended
payment of principal maturities by five years to improve its debt
service coverage ratio due to slower than projected traffic and
revenue ramp-up.

                             Outlook

The rating outlook is negative based on the agency's continued
operating revenue shortfalls due to slower than forecasted traffic
growth and reliance on financial support from F/ETCA to meet the
rate covenant.  Absent either continued financial support, debt
restructuring or dramatic increases in traffic and toll revenues
through rate increases and traffic growth, the agency likely will
not be able to meet escalating debt service requirements without
loans from Foothill.  Also reflected in Moody's outlook is Moody's
expectation that the F/S project costs will be manageable so that
F/ETCA will have sufficient liquidity to be able to advance loans
to help meet SJHTCA's rate covenant.

                 What Could Change the Rating -- UP

Upside potential for the rating would be closely correlated with
accelerated growth in traffic and revenues, improvement in
financial operations and debt service coverage, independent of
loans from F/ETCA and more certainty about the development plans
for Foothill South, and it's potential impact on traffic and
revenue.

               What Could Change the Rating -- DOWN

The agency's credit rating would be negatively impacted by
continued slower than forecasted traffic and revenue growth as
debt service escalates.  The rating is closely tied to the rating
of F/ETCA; any downward pressures on F/ETCA's rating would impact
the rating of SJHTCA.

                          Key Indicators

* Type of System: 15-mile limited access toll road in Orange
  County, from I-405 in Santa Ana to I -5.  Road is owned by
  CALTRANS

* FY 2009 Transactions: 26,810,468

* FY 2009 Toll Revenues: $86,419,923

* % Change Transactions, 2008-2009: -10.8%

* % Change Revenue, 2008-2009: -5.5%

* FY 2009 Toll Revenues to Forecast: 65.8% [1]

* FY 2008 Toll Transactions to Forecast: 49.2 % [1]

* FY 2009 DSCR: 0.94x/1.35x[2]

* FY 2008 DSCR:1.1x/1.31x [2]

* 5 Year CAGR, Toll Transactions: -1.8 %

* 5 Year CAGR Toll Revenue: 5.2%

* Total Outstanding Debt: $2.047 billion

* [1] Wilbur Smith 1999 T&R report.

* [2]Excluding/including Stabilization account transfers.

The last rating action on the SJHTCA was on May 24, 2007, when the
Ba2 rating and negative outlook were assigned.


SOLOSO CDO: Moody's Downgrades Ratings on Five Classes of Notes
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Soloso CDO 2007-1, Ltd.., a trust
preferred CDO:

  -- US$263,000,000 Class A-1LA Floating Rate Notes Due October
     2037, Downgraded to Ba1; previously on 3/27/2009 downgraded
     to Baa3;

  -- US$83,000,000 Class A-1LB Floating Rate Notes Due October
     2037, Downgraded to B1; previously on 3/27/2009 downgraded to
     Ba2;

  -- US$68,000,000 Class A-2L Deferrable Floating Rate Notes Due
     October 2037, Downgraded to Ca; previously on 3/27/2009
     downgraded to Caa2;

  -- US$40,000,000 Class A-3L Floating Rate Notes Due October
     2037, Downgraded to C; previously on 3/27/2009 downgraded to
     Ca;

  -- US$25,000,000 Class A-3F Fixed/Floating Rate Notes Due
     October 2037, Downgraded to C; previously on 3/27/2009
     downgraded to Ca.

According to Moody's, the rating actions taken on the notes are a
result of larger than anticipated par loss and credit
deterioration in the collateral pool as well as an increase on the
assumed defaulted amount.  Moody's took its last rating action on
this deal on March 27, 2009.  Since then, Moody's noticed a
significant increase on the assumed defaulted amount (from
$78.25 million to $134 million).  Excluding the assumed defaults,
the current model WARF is 1703, as compared to the model WARF of
1613 in March 2009.  In addition, according to the October 2009
trustee report, the transaction has experienced a failure in all
its coverage tests, including, Senior Overcollateralization Ratio
(124.74% actual as reported by trustee vs 131.02% the trigger),
Class A-2 Coverage Test (103.96% actual as reported by trustee vs
117.05% the trigger), Class A-3 Coverage Test (89.44% actual as
reported by trustee vs 104.81% the trigger), Class B Coverage Test
(85.363% actual as reported by trustee vs 102.99% the trigger),
Senior Interest Coverage Ratio (227.83% actual as reported by
trustee vs 131.02% the trigger) and Subordinate Interest Coverage
Ratio (47.09% actual as reported by trustee vs 102.99% the
trigger).

Furthermore, due to the significant increase in the actual
defaulted amount (an additional $17 million occurred this past
month), the transaction is now negatively impacted by an
unbalanced pay-fixed, receive-floating interest rate swap that
results in payments to the hedge counterparty that absorb a large
portion of the excess spreads in the deal.  The actions therefore
reflect that the burden of making hedge payment over the remaining
life of this transaction will significantly reduce the amount of
cash available to pay Class A-1L Notes and put interest payments
of Class A-1L at significant risk.

Moody's notes that this TRUP CDO is primarily backed by trust
preferred securities issued by small to medium sized U.S.
community banks.  The action also reflects the continued pressure
in this sector as the number of bank failures and interest payment
deferrals continue to increase.  According to FDIC data, 106 U.S.
banks have failed to date in 2009, as compared to 25 in 2008.
Although U.S. banks recently benefited from a dramatic improvement
in market conditions, the banking sector outlook remains negative.


SOLOSO CDO: Moody's Downgrades Ratings on Various 2005-1 Notes
--------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Soloso CDO 2005-1, Ltd., a trust
preferred CDO:

  -- US$45.5 million Class A-2L Deferrable Floating Rate Notes Due
     October 2035, Downgraded to Caa3; previously on 3/27/2009
     Downgraded to B3;

  -- US$19.0 million Class A-3A Fixed/Floating Rate Notes Due
     October 2035, Downgraded to C; previously on 3/27/2009
     Downgraded to Ca;

  -- US$19.0 million Class A-3B Fixed/Floating Rate Notes Due
     October 2035, Downgraded to C; previously on 3/27/2009
     Downgraded to Ca;

  -- US$40.0 million Class A-3L Floating Rate Notes Due October
     2035, Downgraded to C; previously on 3/27/2009 Downgraded to
     Ca;

  -- US$30.5 million Class B-1L Floating Rate Notes Due October
     2035, Downgraded to C; previously on 11/12/2009 Downgraded to
     C.

According to Moody's, the rating actions taken on the notes are a
result of larger than anticipated par loss and credit
deterioration in the collateral pool as well as an increase in the
assumed defaulted amount.  Moody's took its last rating action on
this deal on March 27, 2009.  Since then, Moody's noticed a
significant increase on the assumed defaulted amount (from $69 mm
to $114.98 mm).  Excluding the assumed defaults, the current model
WARF is 2273, as compared to the model WARF of 1781 in March 2009.
In addition, according to the October 2009 trustee report, the
realized defaulted amount increased (from $47.5 mm as of January
trustee report to $113 mm as of October report).  Furthermore, the
transaction has experienced a failure in all its coverage tests,
including, Senior Overcollateralization Test (127.001% actual as
reported by trustee vs 115% the trigger), Class A-2 Coverage Test
(111.058% actual as reported by trustee vs 112% the trigger),
Class A-3 Coverage Test (91.39% actual as reported by trustee vs
105.00% the trigger), Class B Coverage Test (85.47% actual as
reported by trustee vs 103.5% the trigger), Senior Interest
Coverage Test (332.12% actual as reported by trustee vs 115% the
trigger) and Subordinate Interest Coverage Test (142.04% actual as
reported by trustee vs 103.5% the trigger).

Moody's notes that this TRUP CDO is primarily backed by trust
preferred securities issued by small to medium sized U.S.
community banks.  The action also reflects the continuing pressure
in this sector as the number of bank failures and interest payment
deferrals continue to increase.  According to FDIC data, 106 U.S.
banks have failed to date in 2009, as compared to 25 in 2008.
Although U.S. banks recently benefited from a dramatic improvement
in market conditions, the banking sector outlook remains negative.


SOLSTICE ABS: Fitch Takes Rating Actions on Various Classes
-----------------------------------------------------------
Fitch Ratings has affirmed one and downgraded four classes of
notes issued by Solstice ABS CDO III, Ltd., as a result of
continued credit deterioration in the portfolio since Fitch's last
rating action in August 2008.  Approximately 78.9% of the
portfolio has been downgraded since the last review.  The details
of the rating action follow at the end of this press release.

The downgrades to the portfolio have left approximately 80.5% of
the portfolio with a Fitch derived rating below investment grade
and 53.6% with a rating in the 'CCC' rating category or lower,
compared to 37.3% and 25.2%, respectively at the last review.
According to the Sept. 28, 2009 trustee report, 42.3% of the
portfolio is considered defaulted per the transaction's governing
documents, compared to 13.9% at last review.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.

Despite the degree of credit deterioration within the portfolio,
the class A-1 notes have amortized significantly such that its
credit enhancement remains consistent with an 'AAA' rating loss
rate.  There is sufficient cushion above the 'AAA' rating loss
rate to outweigh the negative impact of principal proceeds
currently being used to pay part of class B accrued interest.

The class A-1 notes are assigned a Negative Rating Outlook due to
the concentration of residential mortgage-backed securities and
structured finance collateralized debt obligations in the
portfolio, which are expected to continue to face ratings
volatility in the next one to two years.

The class A-1 notes are assigned a Loss Severity rating of 'LS5'.
The LS rating indicates a tranche's potential loss severity given
default, as evidenced by the ratio of tranche size to the base-
case loss expectation for the collateral, as explained in
'Criteria for Structured Finance Loss Severity Ratings'.  The LS
rating should always be considered in conjunction with the
probability of default for tranches.

Due to the significant collateral deterioration, all PCM rating
loss rates exceed the credit enhancement available to classes A-2,
B, C-1 and C-2.  For these classes, Fitch compared the respective
credit enhancement levels to the amount of underlying assets
considered defaulted.

While the class A-2 and class B notes are receiving current
interest distributions, given the expected low recoveries for the
defaulted securities, the class A-2 notes are not expected to
receive full principal repayment by maturity, and the class B
notes are not expected to receive any principal repayment.
Therefore the class A-2 and class B notes are downgraded to 'C',
indicating Fitch's opinion that default is inevitable at or prior
to maturity.

The class C-1 and C-2 notes are not receiving interest
distributions due to the failing class A/B coverage tests and are
not expected to receive any proceeds going forward.  The class C
notes are downgraded to 'C' to indicate Fitch's belief that
default is inevitable at or prior to maturity.

Solstice III is a SF CDO that closed on Nov. 13, 2003, and is
monitored by Rabobank International.  The portfolio is composed of
RMBS (54.4%), SF CDOs (20.2%), Corporate CDOs (14.4%), asset-
backed securities (6.9%), and commercial mortgage-backed
securities (4.1%).

Fitch affirms and assigns a LS rating and Outlook to this class of
Solstice III:

  -- $22,966,836 class A-1 notes at 'AAA/LS5'; Outlook Negative.

Fitch downgrades these classes of Solstice III:

  -- $107,500,000 class A-2 notes to 'C' from 'BBB-';
  -- $47,500,000 class B notes to 'C' from 'B-';
  -- $20,469,500 class C-1 notes to 'C' from 'CC';
  -- $5,544,430 class C-2 notes to 'C' from 'CC'.


STRIPS CDO: S&P Puts Note Ratings on CreditWatch Developing
-----------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on 21
commercial real estate collateralized debt obligation classes from
STRIPs CDO Ltd.'s series 2002-1 and 2002-2, and on STRIPs III
Ltd.'s series 2003-1 and 2004-1 on CreditWatch with developing
implications.  At the same time, S&P placed its ratings on two
classes from STRIPs 2002-1 on CreditWatch with positive
implications.  S&P also affirmed its 'AAA' ratings on three
classes from STRIPs 2002-2 and STRIPs 2004-1.

The CreditWatch placements and affirmations follow its preliminary
analysis of each transaction.  Standard & Poor's will resolve the
CreditWatch placements when S&P finalizes its analysis, and, if
necessary, S&P may update its CreditWatch placements in the
interim as S&P continues its analysis.

To analyze the transactions, S&P stressed the collateral cash
flows by applying defaults and losses to the loans in the
underlying commercial mortgage-backed securities transactions that
issued the certificates, which serve as collateral for the
affected STRIPs deals.  S&P arrived at the loan level defaults and
losses through the application of its U.S. conduit/fusion
criteria.  S&P then used Trepp's cash flow model to project the
impact of the loan-level defaults and losses on the underlying
collateral securities.  Because the STRIPs deals are
collateralized by CMBS interest-only classes and CMBS IO strips,
S&P applied additional cash flow stresses when applying the loan
losses and recoveries to the underlying CMBS transactions.  The
additional stresses included timing adjustments for loan defaults
and losses.  S&P accelerated the timing of defaults and losses
from the assumptions S&P used in "U.S. CMBS 'AAA' Scenario Loss
And Recovery Application," published July 21, 2009, on
RatingsDirect.

                      Transaction Summaries

STRIPs CDO Ltd. and STRIPs III Ltd. each issued two series: STRIPs
CDO Ltd. issued series 2002-1 and 2002-2, and STRIPs III Ltd.
issued series 2003-1 and 2004-1.

S&P based its preliminary analysis of the STRIPs transactions
primarily on the information available in the September and
October 2009 note valuation reports.  STRIPs 2002-1 and 2002-2 are
collateralized by 46 IO classes ($6.7 billion aggregate notional
balance, 100%) from 34 distinct CMBS transactions issued between
1997 and 2002.  STRIPs 2003-1 and 2004-1 are collateralized by 29
IO classes ($3.0 billion aggregate notional balance, 61.2%) from
27 distinct CMBS transactions issued between 1998 and 2003; and 70
IO strips ($1.9 billion aggregate notional balance, 38.8%) from 56
distinct CMBS transactions issued between 1997 and 2003.

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 IO criteria resulting in rating actions
on the IO CMBS securities collateralizing the STRIPs transactions.
However, S&P would not necessarily take rating actions on the
outstanding ratings on any of the STRIPs transactions following a
revision to its IO criteria.  The ratings on the STRIPS
transactions are based on the underlying credit and cash flow
analysis of the underlying CMBS transactions and are not dependent
on the ratings on the underlying securities that collateralize the
deal.

             Ratings Placed on Creditwatch Developing

                         STRIPs CDO Ltd.
                          Series 2002-1

                                 Rating
                                 ------
                Class     To                   From
                -----     --                   ----
                L         BB+/Watch Dev        BB+
                M         BB/Watch Dev         BB
                N         BB-/Watch Dev        BB-

                         STRIPs CDO Ltd.
                          Series 2002-2

                                 Rating
                                 ------
                Class     To                   From
                -----     --                   ----
                G         A-/Watch Dev         A-
                J         BBB/Watch Dev        BBB
                K         BBB-/Watch Dev       BBB-
                L         BB+/Watch Dev        BB+
                M         BB/Watch Dev         BB
                N         BB-/Watch Dev        BB-

                         STRIPs III Ltd.
                         Series 2003-1

                                 Rating
                                 ------
                Class     To                   From
                -----     --                   ----
                G         A-/Watch Dev         A-
                J         BBB/Watch Dev        BBB
                K         BBB-/Watch Dev       BBB-
                L         BB+/Watch Dev        BB+
                M         BB/Watch Dev         BB
                N         BB-/Watch Dev        BB-

                         STRIPs III Ltd.
                          Series 2004-1

                                 Rating
                                 ------
                Class     To                   From
                -----     --                   ----
                G         A-/Watch Dev         A-
                J         BBB/Watch Dev        BBB
                K         BBB-/Watch Dev       BBB-
                L         BB+/Watch Dev        BB+
                M         BB/Watch Dev         BB
                N         BB-/Watch Dev        BB-

              Ratings Placed On Creditwatch Positive

                         STRIPs CDO Ltd.
                          Series 2002-1

                                 Rating
                                 ------
                Class     To                   From
                -----     --                   ----
                J         BBB/Watch Pos        BBB
                K         BBB-/Watch Pos       BBB-

                         Ratings Affirmed

                         STRIPs CDO Ltd.
                          Series 2002-2

                        Class     Rating
                        -----     ------
                        A-1       AAA
                        A-2       AAA

                         STRIPs III Ltd.
                          Series 2004-1

                        Class     Rating
                        -----     ------
                        A-1-FLT   AAA


SWIFT MASTER: Moody's Confirms Ratings on Various Floorplan Notes
-----------------------------------------------------------------
Moody's Investors Service has confirmed ratings on certain dealer
floorplan asset-backed notes issued by SWIFT Master Auto
Receivables Trust sponsored by GMAC Inc.  The rating confirmation
reflects an analysis that evaluates the protection available to
noteholders under stressed scenarios.  These scenarios
incorporate, among other factors, stresses that could be realized
in bankruptcy scenarios that differ from the recent orderly
bankruptcy experiences of Chrysler and General Motors.  In
addition, Moody's has upgraded to Aaa all outstanding notes issued
under Superior Wholesale Inventory Financing Trust 2007-AE-1, also
sponsored by GMAC.  The rating upgrades of SWIFT 2007-AE-1 are
based on the fact that all outstanding notes issued under the
trust are currently 100% covered by cash and are expected to be
fully paid off by the expected final maturity of January 2010.

Detailed rating actions are:

SWIFT Master Auto Receivables Trust Series 2007-1

  -- Class A Notes, Aa2 rating confirmed; previously on 1/28/2009,
     Downgraded from Aaa to Aa2 with review for further possible
     downgrade.

  -- Class B Notes, A3 rating confirmed; previously on 5/4/2009,
     Downgraded from Aa3 to A3 with review for further possible
     downgrade.

  -- Class C Notes, Ba1 rating confirmed; previously on 5/4/2009,
     Downgraded from Baa1 to Ba1 with review for further possible
     downgrade.

  -- Class D Notes, Ba3 rating confirmed; previously on 5/4/2009,
     Downgraded from Baa3 to Ba3 with review for further possible
     downgrade.

SWIFT Master Auto Receivables Trust Series 2007-2 ("SWIFT 2007-2")

  -- Class A Notes, Aa2 rating confirmed; previously on 1/28/2009,
     Downgraded from Aaa to Aa2 with review for further possible
     downgrade.

  -- Class B Notes, A3 rating confirmed; previously on 5/4/2009,
     Downgraded from Aa3 to A3 with review for further possible
     downgrade.

  -- Class C Notes, Ba1 rating confirmed; previously on 5/4/2009,
     Downgraded from Baa1 to Ba1 with review for further possible
     downgrade.

  -- Class D Notes, Ba3 rating confirmed; previously on 5/4/2009,
     Downgraded from Baa3 to Ba3 with review for further possible
     downgrade.

Superior Wholesale Inventory Financing Trust 2007-AE-1

  -- Class A Notes, Upgraded to Aaa from Aa2 with review for
     further possible downgrade; previously on 1/28/2009,
     Downgraded from Aaa to Aa2.

  -- Class B Notes, Upgraded to Aaa from A3 with review for
     further possible downgrade; previously on 5/4/2009,
     Downgraded from Aa3 to A3.

  -- Class C Notes, Upgraded to Aaa from Ba1 with review for
     further possible downgrade; previously on 5/4/2009,
     Downgraded from Baa1 to Ba1.

  -- Class D Notes, Upgraded from Aaa from Ba3 with review for
     further possible downgrade; previously on 5/4/2009,
     Downgraded from Baa3 to Ba3.

                            Rationale

Since the rating actions on the related GMAC floorplan
transactions on May 4, 2009, Moody's further assessed, among other
things, Moody's experience in evaluating protections to rated
notes under stressed scenarios from the recent Chrysler and
General Motor bankruptcies.  The current rating actions reflect
Moody's updated view of the key factors driving performance in the
floorplan transactions following the review process since the
original rating actions on November 25, 2008, January 28, 2009,
and May 4, 2009.

The rating confirmation of SWIFT 2007-1 and SWIFT 2007-2 reflects
an analysis that evaluates the protection available to noteholders
under stressed scenarios.  These scenarios incorporate, among
other factors, stresses that could be realized in bankruptcy
scenarios that differ from the recent orderly bankruptcy
experiences of Chrysler and General Motors.  The stresses address
the level of dealer defaults, monthly payment rate triggers and
related payment rate declines, and recovery rates in a future
bankruptcy that might be more disruptive than recent bankruptcy
experience.  For each stressed scenario, losses were projected and
compared to available enhancement.  Loss coverage ratios were
analyzed in all scenarios along with the corresponding potential
impact on bond ratings.

The rating upgrades of SWIFT 2007-AE-1 are based on the fact that
all outstanding notes issued under the trust are currently 100%
covered by cash and are expected to be fully paid off by the
expected final maturity of Jan 2010.

                       Rating Methodology

Moody's floorplan analysis is based on a joint-default probability
analysis of both the manufacturer and dealers with loss given
default determined by collateral at risk net of recoveries.  The
total collateral at risk with a joint-default is the remaining
unpaid floorplan loan calculated based on the monthly payment rate
prior to dealer default.

The analysis is implemented through a simulation model, which
simulates losses during a two year amortization period following
an event of default based on a set of key modeled assumptions:

  -- Manufacturer bankruptcy scenarios
  -- Dealer default rates
  -- Recovery rates
  -- Payment rates

In addition, Moody's includes other modeled assumptions in the
simulation model such as linkage of default probability between
manufacturer and dealer to macroeconomic activity, linkage between
manufacturer and dealer default probability, and sold-out-of-trust
assumptions.

Modeled assumptions form the basis of the quantitative analysis
executed through a simulation model.  Manufacturer default is
simulated, which is further specified into Chapter 11 and Chapter
7 bankruptcies.  Manufacturer default probability is modeled based
on committee assessment, often with reference to the manufacturer
rating.  Next, the simulation model simulates dealer default,
which takes place randomly throughout the two year amortization
period.  The final step in simulation is to calculate total
principal collections.  For non-defaulting dealers, outstanding
floorplan balances are assumed to be paid in full at the end of
the two year amortization period and losses will be zero.  For
defaulted dealers, the model calculates total collateral at risk
determined by payment rate prior to dealer default and then
applies a recovery rate under different circumstances where the
manufacturer is either in a non-bankrupt status, a Chapter 11
bankruptcy or a Chapter 7 bankruptcy.

Each simulation run simulates a total loss and corresponding
internal rate of return reduction for each bond.  This IRR
reduction helps form the quantitative basis of Moody's rating
assessment.  Moody's also evaluates qualitative factors such as
the quality of provided information, servicer strength, and
dealership profile.  Combining the qualitative and quantitative
analysis, a final rating level is determined.

In addition to applying Moody's standard simulation-based
approach, Moody's conducted a static scenario analysis to assess
protections available to rated notes under contemplated stressed
scenarios.  In this approach, Moody's considered numerous possible
manufacturer bankruptcy scenarios, each with a different set of
assumptions including dealer default rates, recovery rates,
payment rates, and other major factors that could drive floorplan
performance.  Under each scenario, losses were projected and
compared to available enhancement.  Loss coverage ratios were
analyzed in all scenarios along with the corresponding potential
impact on bond ratings.

Moody's also evaluates qualitative factors such as the quality of
provided information, servicer strength, and dealership profile.
Combining the qualitative and quantitative analysis, a final
rating level is determined.

                            Servicer

GMAC (senior unsecured rating of Ca under review for possible
upgrade) provides wholesale, retail, and lease financing,
primarily to GM dealers and is one of the world's largest auto
finance companies.  GM is one of the world's largest auto
manufacturers.


TRAINER WORTHAM: Fitch Downgrades Ratings on Three Classes
----------------------------------------------------------
Fitch Ratings has downgraded three and affirmed three classes of
notes issued by Trainer Wortham First Republic CBO III as a result
of continued credit deterioration in the portfolio since Fitch's
last rating action in August 2008.  Approximately 64.1% of the
portfolio has been downgraded since the last review.  The details
of the rating action follow at the end of this press release.

The downgrades to the portfolio have left approximately 62.3% of
the portfolio with a Fitch derived rating below investment grade
and 48.5% with a rating in the 'CCC' rating category or lower,
compared to 45.8% and 32.7%, respectively, at last review.
Defaulted securities, as defined in the transaction's governing
documents, now comprise 22.8% of the portfolio, compared to 17.4%
at last review.

While the classes A-1, A-2, and B notes are still receiving timely
interest distributions, Fitch believes that default is a real
possibility for the class A-1 notes and inevitable for the classes
A-2 and B notes.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  Based on this analysis, the credit
enhancement available to the class A-1 notes is generally
consistent with the PCM rating loss rate for the 'CCC' rating
category.

Due to the significant collateral deterioration, credit
enhancement levels available to all other classes of notes are
exceeded by even the 'CCC' rating loss rate, the lowest rating
level loss projected by PCM.  For these classes, Fitch compared
the respective credit enhancement levels to the amount of
underlying assets considered distressed (rated 'CCC' and lower).
Given the high probability of default of these assets and the
expected low recoveries upon default, classes A-2, and B were
downgraded to 'C' and classes C, D, and preferred shares were
affirmed at 'C'.

Trainer Wortham III is a structured finance collateralized debt
obligation that closed on Feb. 19, 2003 and is monitored by First
Republic Investment Management.  The portfolio is composed of RMBS
(91.2%), CDOs (6.8%), commercial mortgage-backed securities
(1.3%), and asset-backed securities (0.7%).

Fitch has downgraded and affirmed ratings as indicated:

  -- $76,588,260 class A-1 notes downgraded to 'CCC' from 'BBB-';
  -- $60,750,000 class A-2 notes downgraded to 'C' from 'CCC';
  -- $9,000,000 class B notes downgraded to 'C' from 'CC';
  -- $8,512,894 class C notes affirmed at 'C';
  -- $14,856,973 class D notes affirmed at 'C';
  -- $16,000,000 Preferred Shares affirmed at 'C'.


TIERS FLOATING: Moody's Junks Ratings on 2006-12 Certs. From 'B2'
-----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded its
rating on notes issued by TIERS Floating Rate Credit Linked Trust
Certificates under Series 2006-12, a collateralized debt
obligation transaction referencing a static portfolio of corporate
entities.

The rating action is:

Issuer: TIERS Floating Rate Credit Linked Trust Certificates,
Series 2006-12

  -- US$43,000,000 TIERS Floating Rate Credit Linked Trust
     Certificates Notes, Downgraded to Caa1; previously on Feb 25,
     2009 Downgraded to B2

Moody's explained that the rating action taken is the result of
the deterioration of the credit quality of the reference
portfolio.  The 10 year weighted average rating factor of the
portfolio, not adjusted with forward looking measures, has
deteriorated from 280 initially to 1157, equivalent to an average
rating of the current portfolio of Ba2.  The reference portfolio
includes an exposure to CIT Group, Inc. which has experienced
substantial credit migration in the past few months, and is now
rated Ca.  Since the last rating action on the transaction, the
subordination of the rated tranche has been reduced due to a
credit event on Thomson S.A. This credit event leads to a decrease
of approximately 0.22% of the subordination of the tranche.  The
portfolio has the highest industry concentrations in
Telecommunications (11%), Oil & Gas (10%), Insurance (7%) and
Finance (6%).

Moody's monitors this transaction using primarily the methodology
for Corporate Synthetic Obligations as described in Moody's
Special Report below:

-- Moody's Approach to Rating Corporate Collateralized Synthetic
    Obligations (14 September 2009)

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 strength of the legal
framework as well as specific documentation features, and
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.


TOURO INFIRMARY: Moody's Reviews 'Ba1' Long-Term Bond Rating
------------------------------------------------------------
Moody's Investors Service has placed Touro Infirmary's Ba1 long-
term bond rating on Watchlist for possible downgrade.  This rating
action affects $33.8 million of Series 1993 bonds and
$57.4 million of Series 1999A fixed rate bonds issued through the
Louisiana Public Facilities Authority.  This rating action follows
the continuing lack of disclosure of final audited fiscal year
2008 financial statements, continuation of internal reporting of
sizable operating losses, and weak liquidity.

Touro Infirmary has yet to file its fiscal year 2008 audit for its
audit year ended December 31, 2008.  Internal financial statements
showed a $20.2 million operating loss (-9.1% margin) for the year,
which followed three previous years of operating losses.  For the
first nine months of FY 2009 (September 30), Touro Infirmary is
reporting an operating loss of $11.4 million (-6.5% margin)
compared to a $12.6 million operating loss for the same period of
the prior year (-7.4% margin) and a budgeted loss of $8.4 million
(-4.7% margin).

Liquidity remains very low, with cash and board designated
investments generating $30 million of liquidity and 48 days cash
on hand at September 30, 2009.  Cash-to-debt is also low at 33%.
Liquidity is impaired partly by the requirement to post collateral
($12.6 million representing 20 days cash on hand) against
outstanding swap agreements.

In July 2009 Touro Infirmary announced an affiliation with
Louisiana Children's Medical Center.  There has not been, however,
any change in the security structure for Touro Infirmary's bonds.

Moody's plans to meet with management within the next 90 days to
discuss financial performance and strategic initiatives to improve
operating performance and liquidity.  Moody's will also discuss
projected benefits from the affiliation with LCMC.

The last rating action was on December 5, 2008, when the ratings
of Touro Infirmary were downgraded to Ba1 from Baa3 with a
negative outlook.


TRICADIA CDO: S&P Downgrades Ratings on Three 2004-2 Notes
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class A, B, and C notes issued by Tricadia CDO 2004-2 Ltd., a cash
flow collateralized debt obligation transaction backed by tranches
of structured finance CDOs.  At the same time, S&P removed two
ratings from CreditWatch negative, and S&P's rating on the class A
notes remains on CreditWatch negative.

The rating actions follow receipt of the notice dated Oct. 28,
2009, from the trustee that a majority of the controlling
classholders has directed the trustee to proceed with the
liquidation of the collateral backing the rated notes.

The rating actions are consistent with the criteria S&P use to
assess ratings on CDO transactions subject to acceleration or
liquidation after an event of default has occurred.

Earlier S&P received a notice that the transaction experienced an
event of default dated March 23, 2009.  The deal experienced the
EOD due to the failure of an overcollateralization-based EOD
trigger specified in section 5.1 (h) of the transaction's
indenture.

                  Rating And Creditwatch Actions

                    Tricadia CDO 2004-2 Ltd.

                            Rating
                            ------
           Class      To                From
           -----      --                ----
           A          CCC/Watch Neg     BBB/Watch Neg
           B          CC                B/Watch Neg
           C          CC                CCC/Watch Neg


TROPIC 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 Tropic CDO I, Ltd., a trust
preferred CDO.

  -- US$45,000,000 Class A-1L Floating Rate Notes Due October
     2033, Downgraded to Baa3; previously on March 27, 2009
     downgraded to A3;

  -- US$48,000,000 Class A-4L Floating Rate Notes Notes Due
     October 2033, Downgraded to Ca; previously on March 27, 2009
     downgraded to Caa3;

  -- US$32,000,000 Class A-4 Fixed/Floating Rate Due October 2033,
     Downgraded to Ca; previously on March 27, 2009 downgraded to
     Caa3;

  -- US$25,000,000 Class B-1L Floating Rate Notes Due October
     2033, Downgraded to C; previously on March 27, 2009
     downgraded to Ca.

Moody's took its last rating action on this deal on March 27,
2009.  Since then, Moody's noticed a significant increase in the
assumed defaulted amount (from $53.5mm to $116.47mm).  Excluding
the assumed defaults, the current model WARF is 1537, as compared
to the model WARF of 2506 in March 2009.  In addition, according
to the October 2009 trustee report, the transaction has
experienced failure in some of its coverage tests, including,
Subordinate Overcollateralization Test (68.19% actual vs. 105.00%
trigger) and Subordinate Interest Coverage Test (88.45% actual vs.
105.00% trigger).

Moody's notes that this TRUP CDO is backed primarily by trust
preferred securities issued by small to medium sized U.S.
community banks.  The action also reflects the continued pressure
in this sector as the number of bank failures and interest payment
deferrals continue to increase.  According to FDIC data, 106 U.S.
banks have failed to date in 2009, as compared to 25 in all of
2008.  Although U.S. banks recently benefited from a dramatic
improvement in market conditions, the banking sector outlook
remains negative.


TROPIC CDO: 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 Tropic CDO III, Ltd., a trust
preferred CDO.

  -- US$158,000,000 Class A-1L Floating Rate Notes Due 2034,
     Downgraded to Baa2; previously on March 27, 2009 downgraded
     to A2;

  -- US$31,000,000 Class A-3L Floating Rate Notes Due 2034,
     Downgraded to Caa3; previously on March 27, 2009 downgraded
     to B2;

  -- US$40,500,000 Class A-4A Fixed/Floating Rate Notes Due 2034,
     Downgraded to C; previously on March 27, 2009 downgraded to
     Ca;

  -- US$20,000,000 Class A-4B Fixed/Floating Rate Notes Due 2034,
     Downgraded to C; previously on March 27, 2009 downgraded to
     Ca;

  -- US$19,500,000 Class A-4L Floating Rate Notes Due 2034,
     Downgraded to C; previously on March 27, 2009 downgraded to
     Ca.

Moody's took its last rating action on this deal on March 27,
2009.  Since then, Moody's noticed a significant increase in the
assumed defaulted amount (from $56.5mm to $100.5mm).  Excluding
the assumed defaults, the current model WARF is 1068, as compared
to the model WARF of 1619 in March 2009.  In addition, according
to the October 2009 trustee report, the transaction has
experienced failure in most of its coverage tests, including,
Senior Overcollateralization Test (122.94% actual vs. 140.00%
trigger), Senior Subordinate Overcollateralization Test (105.05%
actual vs. 125.00% trigger), Subordinate Overcollateralization
Test (76.37% actual vs. 104.00% trigger), and Subordinate Interest
Coverage Test (71.37% actual vs. 104.00% trigger).

Moody's notes that this Trup CDO is backed primarily by trust
preferred securities issued by small to medium sized U.S.
community banks.  The action also reflects the continued pressure
in this sector as the number of bank failures and interest payment
deferrals continue to increase.  According to FDIC data, 106 U.S.
banks have failed to date in 2009, as compared to 25 in all of
2008.  Although U.S. banks recently benefited from a dramatic
improvement in market conditions, the banking sector outlook
remains negative.


TROPIC 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 Tropic CDO II, Ltd., a trust
preferred CDO.

  -- US$145,000,000 Class A-1L Floating Rate Notes Due April 2034,
     Downgraded to Baa2; previously on March 27, 2009 downgraded
     to A2;

  -- US$35,000,000 Class A-3L Floating Rate Notes Due April 2034,
     Downgraded to Caa1; previously on March 27, 2009 downgraded
     to B3;

  -- US$38,000,000 Class A-4L Floating Rate Notes Due April 2034,
     Downgraded to C; previously on March 27, 2009 downgraded to
     Ca;

  -- US$30,000,000 Class A-4 Fixed/Floating Rate Notes Due April
     2034, Downgraded to C; previously on March 27, 2009
     downgraded to Ca.

Moody's took its last rating action on this deal on March 27,
2009.  Since then, Moody's noticed a significant increase in the
assumed defaulted amount (from $81mm to $115mm).  Excluding the
assumed defaults, the current model WARF is 1314, as compared to
the model WARF of 1899 in March 2009.  In addition, according to
the October 2009 trustee report, the transaction has experienced
failure in some of its coverage tests, including, Senior
Overcollateralization Test (106.68% actual vs. 120.00% trigger)
and Subordinate Overcollateralization Test (76.23% actual vs.
104.00% trigger).

Moody's notes that this TruPS CDO is backed primarily by trust
preferred securities issued by small to medium sized U.S.
community banks.  The action also reflects the continued pressure
in this sector as the number of bank failures and interest payment
deferrals continue to increase.  According to FDIC data, 106 U.S.
banks have failed to date in 2009, as compared to 25 in all of
2008.  Although U.S. banks recently benefited from a dramatic
improvement in market conditions, the banking sector outlook
remains negative.


TROPIC CDO: Moody's Downgrades Ratings on Five Classes of Notes
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Tropic CDO IV, Ltd., a trust
preferred CDO:

  -- US$160,000,000 Class A-1L Floating Rate Notes Due April 2035,
     Downgraded to Ba1; previously on March 27, 2009 downgraded to
     A3;

  -- US$40,000,000 Class A-2L Floating Rate Notes Due April 2035,
     Downgraded to B1; previously on March 27, 2009 downgraded to
     Ba1;

  -- US$37,500,000 Class A-3L Deferrable Floating Rate Notes Due
     April 2035, Downgraded to Ca; previously on March 27, 2009
     downgraded to B3;

  -- US$35,000,000 Class A-4 Fixed/Floating Rate Notes Due April
     2035, Downgraded to C; previously on March 27, 2009
     downgraded to Ca;

  -- US$26,000,000 Class A-4L Floating Rate Notes Due April 2035,
     Downgraded to C; previously on March 27, 2009 downgraded to
     Ca.

Moody's took its last rating action on this deal on March 27,
2009.  Since then, Moody's noticed a significant increase in the
assumed defaulted amount (from $56.5mm to $113mm).  Excluding the
assumed defaults, the current model WARF is 1798, as compared to
the model WARF of 1832 in March 2009.  In addition, according to
the October 2009 trustee report, the transaction has experienced
failure in most of its coverage tests, including, Senior Principal
Coverage Test (123.79% actual vs. 140.00% trigger), Class A-3
Principal Coverage Test (103.80% actual vs. 112.00% trigger),
Class B Principal Coverage Test (76.95% actual vs. 103.00%
trigger), and Subordinate Interest Coverage Test (66.51% actual
vs. 103.00% trigger).

Moody's notes that this Trup CDO is primarily backed by trust
preferred securities issued by small to medium sized U.S.
community banks.  The action also reflects the continued pressure
in this sector as the number of bank failures and interest payment
deferrals continue to increase.  According to FDIC data, 106 U.S.
banks have failed to date in 2009, as compared to 25 in all of
2008.  Although U.S. banks recently benefited from a dramatic
improvement in market conditions, the banking sector outlook
remains negative.


TROPIC CDO: Moody's Reviews Ratings on Three Classes of Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has placed on watch
for possible downgrade the ratings of these notes issued by Tropic
CDO IV, Ltd., a trust preferred CDO:

  -- US$160,000,000 Class A-1L Floating Rate Notes Due April
     2035, Ba1 on watch for possible downgrade; previously on
     October 30, 2009 downgraded to Ba1;

  -- US$40,000,000 Class A-2L Floating Rate Notes Due April
     2035, B1 on watch for possible downgrade; previously on
     October 30, 2009 downgraded to B1;

  -- US$37,500,000 Class A-3L Deferrable Floating Rate Notes
     Due April 2035, Ca on watch for possible downgrade;
     previously on October 30, 2009 downgraded to Ca.

In a notice dated October 30, 2009, Wells Fargo Bank, N.A.,
trustee for Tropic CDO IV, stated that the holders in excess of 66
2/3% of the Preferred Shares directed the trustee to accept an
offer to sell certain securities to a third party.  This offer to
purchase part of the transaction collateral at a substantial
discount, if executed, will have a negative impact on the rated
notes.  The trustee has also stated that it intends to file an
interpleader action requesting a judicial determination regarding
how to proceed in respect of the offer.  The rating action
reflects the uncertainty surrounding the outcome of this
proceeding and the potential negative impact from the Offer.
Moody's is following the development of this situation closely.


WACHOVIA BANK: Moody's Reviews Ratings on 10 2005-C21 Certs.
------------------------------------------------------------
Moody's Investors Service placed ten classes of Wachovia Bank
Commercial Mortgage Trust Commercial Mortgage Pass-Through
Certificates, Series 2005-C21 on review for possible downgrade due
to higher expected losses for the pool resulting from losses from
loans in special servicing, concerns about refinancing risk
associated with loans approaching maturity, and increased
leverage.  Currently, there are ten loans, representing 4% of the
pool, in special servicing.  Ten loans, representing 13% of the
pool, mature within the next 24 months.  The rating action is the
result of Moody's on-going surveillance of commercial mortgage
backed securities transactions.

As of the October 19, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 15%
to $2.76 billion from $3.25 billion at securitization.  The
Certificates are collateralized by 226 mortgage loans ranging in
size from less than 1% to 8% of the pool, with the top ten loans
representing 44% of the pool.

Thirty nine loans, representing 10% 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.  Not all loans on the
watchlist are delinquent or have significant issues.

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

Moody's rating action is:

  -- Class A-J, $215,323,000, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 11/10/2005

  -- Class B, $65,003,000, currently rated Aa2, on review for
     possible downgrade; previously assigned at Aa2 on 11/10/2005

  -- Class C, $32,502,000, currently rated Aa3, on review for
     possible downgrade; previously assigned at Aa3 on 11/10/2005

  -- Class D, $60,941,000, currently rated A2, on review for
     possible downgrade; previously assigned at A2 on 11/10/2005

  -- Class E, $36,564,000, currently rated A3, on review for
     possible downgrade; previously assigned at A3 on 11/10/2005

  -- Class F, $40,627,000, currently rated Baa1, on review for
     possible downgrade; previously assigned at Baa1 on 11/10/2005

  -- Class G, $32,502,000, currently rated Baa2, on review for
     possible downgrade; previously assigned at Baa2 on 11/10/2005

  -- Class H, $40,627,000, currently rated Baa3, on review for
     possible downgrade; previously assigned at Baa3 on 11/10/2005

  -- Class J, $16,250,000, currently rated Ba1, on review for
     possible downgrade; previously assigned at Ba1 on 11/10/2005

  -- Class K, $16,251,000, currently rated Ba2, on review for
     possible downgrade; previously assigned at Ba2 on 11/10/2005


WACHOVIA BANK: S&P Downgrades Ratings on 19 2006-C28 Securitiess
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 19
classes of commercial mortgage-backed securities from Wachovia
Bank Commercial Mortgage Trust's series 2006-C28 and removed them
from CreditWatch with negative implications.  In addition, S&P
affirmed its ratings on five other classes from the same
transaction.

The downgrades follow its analysis of the transaction using its
U.S. conduit and fusion CMBS criteria, which was the primary
driver of its rating actions.  The downgrades of the subordinate
and mezzanine classes also reflect the credit support erosion that
S&P anticipate will occur upon the eventual resolution of several
specially serviced loans, as well as its analysis of six loans
(5.9%) that S&P consider credit-impaired.  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 1.29x and a loan-
to-value ratio of 115.5%.  S&P further stressed the loans' cash
flows under its 'AAA' scenario to yield a weighted average DSC of
0.81x and an LTV of 156.1%.  The implied defaults and loss
severity under the 'AAA' scenario were 88.5% and 41.2%,
respectively.  The weighted average DSC and LTV calculations
exclude seven specially serviced loans ($98.8 million; 2.8%) and
six loans that S&P deemed to be credit-impaired ($209.7 million;
5.9%).  S&P estimated losses separately for the specially serviced
and credit-impaired loans, which S&P included in its implied
default and loss severity figures.

The affirmations of the principal and interest certificates
reflect subordination levels that adequately support the
outstanding ratings.  S&P has affirmed its rating on the class IO
interest-only certificates based on its current criteria.  S&P
published a request for comment proposing changes to its IO
criteria on June 1, 2009.  Once the criteria review is finalized,
S&P may revise its current IO criteria, which may affect
outstanding ratings, including the rating on the IO certificates
S&P affirmed.

                         Credit Concerns

As of the Oct. 19, 2009, remittance date, nine assets
($132.5 million; 3.7%) in the pool were with the special servicer,
CWCapital Asset Management.  The payment status of the assets is:
seven are 90-plus-days delinquent (2.5%), one is less than 30 days
delinquent (0.7%), and one is real estate owned (0.5%).  Six of
the specially serviced assets have appraisal reduction amounts
(ARAs) in effect totaling $31.1 million.

In addition to the specially serviced assets, S&P deemed six loans
($209.7 million; 5.9%) to be credit-impaired.  The largest loan
S&P considered credit-impaired was transferred to the special
servicer on Oct. 29, 2009, after the Oct. 19, 2009, trustee
remittance report.  The Four Season Resort and Club - Dallas,
Texas loan ($175 million; 5.3%) is the fourth-largest loan in the
pool and was transferred to the special servicer due to imminent
default.  The borrower failed to make the scheduled monthly
payment due on Oct. 11, 2009, and has indicated that it does not
have sufficient funds to continue to support the operations of the
property.  The loan has a $175.0 million trust balance and a
$183 million whole-loan balance.  The whole loan consists of a
$175.0 million senior A note that is included in the trust and an
$8 million nonpooled junior participation that is not rated by
Standard & Poor's.  In addition to the first mortgage, there is a
$31.13 million mezzanine loan that is secured by the equity
interests in the borrower.  The loan is secured by a 397-room (357
rooms and 40 villas) full-service hotel in Irving, Texas.  The
nine-story building was constructed in 1986 and underwent a
$23 million renovation ($57,935 per key) from 1999 to 2005.  The
occupancy and DSC were 65% and 0.62x, respectively, for the 12
months ended June 30, 2009.  S&P expects a moderate loss upon the
resolution of this asset.

                       Transaction Summary

As of the October 2009 remittance report, the aggregate trust
balance was $3.60 billion (207 loans), compared with $3.57 billion
(207 loans) at issuance.  Wachovia Bank N.A., the master servicer,
reported financial information for 97% of the pool.  Ninety-six
percent of the financial information was either full-year 2008 or
partial-year 2009 data.  S&P calculated a weighted average DSC of
1.27x for the pool based on the master servicer's reported
figures.  S&P's adjusted DSC and LTV were 1.29x and 115.5%,
respectively.  Standard & Poor's adjusted DSC and LTV calculations
exclude seven specially serviced loans ($98.8 million; 2.8%), six
loans that S&P deems to be credit-impaired ($209.7 million; 5.9%),
and 12 loans that did not report financial data (2.9%).  S&P
separately estimated losses for the seven specially serviced loans
and the six credit-impaired loans.  Based on the servicer-reported
year-end 2008 DSC figures, S&P calculated a weighted average DSC
of 0.71x for these 13 loans.  The transaction has not experienced
any principal losses to date.  Fifty-four loans are on the
servicer's watchlist ($937.3 million; 26.2%).  Nine loans
($121.2 million, 3.4%) have reported DSC between 1.0x and 1.1x,
and 29 loans ($619.2 million, 17.3%) have reported DSC of less
than 1.0x.

                     Summary of Top 10 Loans

The top 10 loans have an aggregate outstanding balance of
$1.5 billion (42.4%).  Using servicer-reported information, S&P
calculated a weighted average DSC of 1.19x.  One of the top 10
loans appears on the master servicer's watchlist.  Another top 10
loan, The Four Season Resort and Club - Dallas, Texas, loan, was
transferred to the special servicer after the Oct. 19, 2009,
remittance date and is discussed above.  S&P's adjusted DSC and
LTV figures for the top 10 loans were 1.18x and 125.9%,
respectively.  These figures exclude the Four Season Resort and
Club - Dallas, Texas loan ($175.0 million; 4.9%).

The Montclair Plaza loan, the third-largest loan, was placed on
the servicer's watchlist due to the borrower's sponsor, General
Growth Properties, bankruptcy filing on April 16, 2009.  In
addition, the borrower failed to make the October payment, citing
insufficient cash flow.  The loan has a $190.0 (5.3%) million
trust balance and a $265 million whole-loan balance, which
consists of a $190.0 million senior A note included in the trust
and a $75 million subordinate B note that is held outside of the
trust.  The loan is secured by 875,085 sq. ft. of a 1.35-million-
sq.-ft. regional mall in Montclair, Calif.  Originally constructed
in 1968, the mall underwent an extensive renovation and
redevelopment in 1997.  The occupancy and DSC for year-end 2008
were 85% and 1.55x, respectively.  As of the June 30, 2009, rent
roll, the property was 80% occupied, and S&P estimated a DSC of
0.99x based on this rent roll.  S&P will continue to monitor
developments related to this loan and will take rating actions on
this transaction as S&P deem necessary.

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

      Ratings Lowered And Removed From Creditwatch Negative

             Wachovia Bank Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2006-C28

                  Rating
                  ------
     Class      To       From          Credit enhancement (%)
     -----      --       ----          ----------------------
     A-4        A+      AAA/Watch Neg          30.26
     A-4FL      A+      AAA/Watch Neg          30.26
     A-1A       A+      AAA/Watch Neg          30.26
     A-M        BBB     AAA/Watch Neg          20.17
     A-J        BB      AAA/Watch Neg          12.35
     B          BB-     AA+/Watch Neg          11.72
     C          B+      AA/Watch Neg           10.09
     D          B+      AA-/Watch Neg            9.20
     E          B       A/Watch Neg              7.82
     F          B       A-/Watch Neg             6.68
     G          B-      BBB+/Watch Neg           5.55
     H          B-      BBB/Watch Neg            4.41
     J          CCC     BBB-/Watch Neg           3.15
     K          CCC-    BB+/Watch Neg            2.65
     L          CCC-    BB-/Watch Neg            2.40
     M          CCC-    B+/Watch Neg             2.02
     N          CCC-    B/Watch Neg              1.89
     O          CCC-    B-/Watch Neg             1.64
     P          CCC-    CCC+/Watch Neg           1.39

                         Rating Affirmed

             Wachovia Bank Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2006-C28

             Class    Rating   Credit enhancement (%)
             -----    ------   ----------------------
             A-1       AAA          30.26
             A-2       AAA          30.26
             A-PB      AAA          30.26
             A-3       AAA          30.26
             IO        AAA           N/A

                      N/A - Not applicable.


* Fitch Puts Ratings on 58 Classes From 13 CRE CDOs on Neg. Watch
-----------------------------------------------------------------
Fitch Ratings has placed on Rating Watch Negative 58 classes from
13 commercial real estate collateralized debt obligations
containing a concentration of 2005 vintage commercial mortgage
backed securities.  The actions stem from Fitch placing classes
from the 2005 vintage CMBS on Rating Watch.

The affected transactions have greater than 10% exposure to 2005
vintage CMBS that are currently on Rating Watch Negative by Fitch
or another agency.

Similar to the Rating Watch actions for classes within CRE CDOs
taken when Fitch placed the 2006-2008 vintage CMBS classes on
Rating Watch Negative, Fitch is placing classes from CRE CDOs with
2005 vintage CMBS concentrations on Negative Watch.  Two of the
CRE CDOs affected in this action already had some of their bonds
on Negative Watch from that earlier action.  The magnitude of the
negative rating actions on the 2005 vintage CMBS is expected to be
less significant than the 2006-2008 vintage CMBS rating
downgrades.  Nevertheless, the expected CMBS downgrades still
exceed Fitch's expectation when the downgrade actions were taken
on these CRE CDO bonds earlier this year following the
implementation of revised criteria.

On Oct. 22, 2009, Fitch placed 247 classes from 22 fixed-rate CMBS
conduit transactions from the 2005 vintage on Rating Watch
Negative, with the expectation that the majority of the classes
will be downgraded approximately one category when the Rating
Watch Negative is resolved.

Fitch will be carrying out individual analyses on the affected
transactions in the coming months.

Fitch has placed these classes on Rating Watch Negative:

Ansonia CDO 2006-1 Ltd./LLC

  -- $203,311,214 class A-1FL notes 'BB';
  -- $75,488,472 class A-1FX notes 'BB';
  -- $57,479,000 class B notes 'B';
  -- $34,285,000 class C notes 'B-';
  -- $16,134,000 class D notes 'B-';
  -- $18,151,000 class E notes 'B-'.

Anthracite 2005-HY2 Ltd./Corp.

  -- $103,691,335 class A notes 'BBB';
  -- $52,593,000 class B notes 'BB+';
  -- $25,360,000 class C-FL notes 'BB';
  -- $7,000,000 class C-FX notes 'BB';
  -- $25,275,000 class D-FL notes 'B';
  -- $13,500,000 class D-FX notes 'B';
  -- $9,376,000 class E notes 'B-'.

Anthracite CRE CDO 2006-HY3 Ltd.

  -- $173,090,099 class A notes 'BB';
  -- $50,595,567 class B-FL notes 'B+';
  -- $8,876,415 class B-FX notes 'B+';
  -- $41,719,152 class C-FL notes 'B-';
  -- $7,101,132 class C-FX notes 'B-'.

Calculus CMBS 2007-3

  -- $16,000,000 Calculus CMBS 2007-3 07ML66764A 'BBB';
  -- $4,000,000 Calculus CMBS 2007-3 07ML66763A 'BBB';
  -- $2,000,000 Calculus CMBS 2007-3 07ML66762 'BBB';
  -- $1,000,000 Calculus CMBS 2007-3 07ML66757A 'BBB';
  -- $17,000,000 Calculus CMBS 2007-3 07ML66756A 'BBB-'.

CT CDO IV Ltd.

  -- $257,644,208 class A-1 notes 'BBB';
  -- $19,354,920 class A-2 notes 'BBB-';
  -- $19,362,454 class B notes 'BB+';
  -- $13,561,034 class C notes 'BB';
  -- $6,206,058 class D-FL notes 'B+';
  -- $3,964,519 class D-FX notes 'B+';
  -- $5,339,104 class E notes 'B';
  -- $2,386,096 class F-FL notes 'B-';
  -- $3,929,104 class F-FX notes 'B-'.

CWCapital COBALT Vr Ltd./Corp.

  -- $526,113,681 class A-1 notes 'BBB'.

Halcyon 2005-1, Ltd,

  -- Eur51,875,000 class A notes 'BBB+';
  -- Eur5115,000,000 class B notes 'BBB';
  -- $15,750,000 class C notes 'BBB-'.

Halcyon 2005-2, Ltd.

  -- Eur5138,400,000 class A notes 'BBB+';
  -- Eur5125,800,000 class B notes 'BBB';
  -- $15,750,000 class C notes 'BBB-'.

JER CRE CDO 2005-1, Ltd./LLC

  -- $80,852,991 class A notes 'BBB';
  -- $38,130,000 class B-1 notes 'BB+';
  -- $37,500,000 class B-2 notes 'BB+';
  -- $48,400,000 class C notes 'BB';
  -- $46,500,000 class D notes 'B+';
  -- $23,320,000 class E notes 'B';
  -- $15,000,000 class F notes 'B-';
  -- $10,000,000 class G notes 'B-'.

LNR CDO 2006-1, Ltd./LLC (IV)

  -- $474,385,000 class A notes 'BB-';
  -- $204,174,000 class B-FL notes 'B';
  -- $10,000,000 class B-FX notes 'B'.

N-Star Real Estate CDO V Ltd.

  -- $335,921,275 class A-1 notes 'A-';
  -- $46,472,397 class A-2 notes 'BBB'.

N-Star Real Estate CDO VII, Ltd.

  -- $338,250,000 class A-1 notes 'A-';
  -- $54,250,000 class A-2 notes 'BBB'.

Vertical CRE CDO 2006-1, Ltd./Corp.

  -- $189,709,055 class A notes 'BB';
  -- $29,000,000 class B notes 'B';
  -- $10,000,000 class C notes 'B-';
  -- $4,000,000 class D notes 'B-'.


* S&P Downgrades Ratings on 26 Classes From Nine RMBS Transactions
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 26
classes from nine residential mortgage-backed securities
transactions backed by U.S. subprime mortgage loan collateral
issued in 2003 and 2005.  S&P removed four of the lowered ratings
from CreditWatch with negative implications.  In addition, S&P
affirmed its ratings on 18 classes from eight of the downgraded
transactions and removed one of the affirmed ratings from
CreditWatch negative.

Standard & Poor's has established loss projections for each
subprime transaction rated in 2005.  S&P derived these losses
using the criteria that S&P outlined in "Standard & Poor's Revises
U.S. Subprime And Alternative-A RMBS Loss Assumptions For
Transactions Issued In 2005, 2006, And 2007," published July 6,
2009.  S&P's lifetime projected loss has changed for one of the
transactions in this release:

                                    Orig. bal.       Lifetime
Transaction                        (mil. $)         exp. loss (%)
-----------                        ----------       -------------
ASC Home Eq. Loan Trust 2005-SN1        165           11.81

The downgrades reflect S&P's opinion that projected credit support
for the affected classes is insufficient to maintain the previous
ratings, given S&P's current projected losses.

To assess the creditworthiness of each class, S&P reviewed the
individual delinquency and loss trends of each transaction for
changes, if any, in risk characteristics, servicing, and the
ability to withstand additional credit deterioration.  In order to
maintain a 'B' rating on a class, S&P assessed whether, in S&P's
view, a class could absorb the base-case loss assumptions S&P used
in its analysis.  In order to maintain a rating higher than 'B',
S&P assessed whether the class could withstand losses exceeding
S&P's base-case loss assumptions at a percentage specific to each
rating category, up to 150% for an 'AAA' rating.  For example, in
general, S&P would assess whether one class could withstand
approximately 110% of S&P's base-case loss assumptions to maintain
a 'BB' rating, while S&P would assess whether a different class
could withstand approximately 120% of S&P's base-case loss
assumptions to maintain a 'BBB' rating.  Each class with an
affirmed 'AAA' rating can, in S&P's view, withstand approximately
150% of S&P's base-case loss assumptions under its analysis.

S&P also lowered its ratings on certain senior classes due to
principal shortfalls/write-downs in the final period of particular
cash flow scenarios.  These classes may not have experienced any
principal shortfalls/write-downs in any of the prior periods of
the particular stress scenario; however, the structural mechanics
of the transaction created circumstances in which one or more
classes within a transaction may have relied on principal proceeds
to satisfy interest amounts due in earlier periods, thus resulting
in a write-down in the final period.

The use of principal to satisfy interest obligations is generally
created within structures that utilize cross-collateralization and
contain multiple loan groups.  Based on certain stress scenarios,
if a particular group is performing worse than another group or
set of groups, that group can become undercollateralized when S&P
compare the group collateral balance with the related senior class
balance(s).  Based on the defined interest amount needed to
satisfy the interest liability of the related class(es), interest
shortfalls may occur due to a group collateral balance that is
insufficient to produce the necessary interest obligations of the
related liabilities.  Generally, cross-collateralization is
designed to allow overcollateralized groups to provide cash flow
to undercollateralized groups in order to mitigate this issue.
However, if the overcollateralized group has a pass-through rate
that is lower than the pass-through rate of the
undercollateralized group, available interest may not be
sufficient to satisfy the undercollateralized group's interest
requirement.  Therefore, the principal portion of available funds
may be used to satisfy interest obligations based on the interest-
principal payment priority within the structure.

In the final period, a situation may occur in which available
funds are not sufficient to satisfy the interest and principal
requirements necessary to pay the bond in full, as principal in
prior periods was used to satisfy interest obligations.
Additionally, in some cases, even super-senior certificates can be
exposed to this issue because structures may pay principal pro
rata with senior support classes.  Although the senior class was
not exposed to a write-down in any of the prior periods, it could
be susceptible to a write-down in the final period due to the
aforementioned issues.

The affirmed ratings reflect S&P's belief that the amount of
credit enhancement available for these classes is sufficient to
cover losses associated with these rating levels.

Subordination provides credit support for the affected
transactions.  In addition, some classes also benefit from
overcollateralization (prior to its depletion) and excess spread.
The underlying pool of loans backing these transactions consists
of fixed- and adjustable-rate U.S. subprime mortgage loans secured
by first and second liens on one- to four-family residential
properties.

                          Rating Actions

   Ace Securities Corp. Home Equity Loan Trust, Series 2005-SN1
                          Series 2005-SN1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1        004421MQ3     AAA                  AAA/Watch Neg
    A-2        004421MV2     CCC                  AAA/Watch Neg
    M-1        004421MR1     CC                   AA+/Watch Neg
    M-2        004421MS9     CC                   A+/Watch Neg
    M-3        004421MT7     CC                   A-/Watch Neg

                Ameriquest Mortgage Securities Inc.
                           Series 2003-7

                                          Rating
                                          ------
         Class      CUSIP         To                   From
         -----      -----         --                   ----
         M-2        03072SHS7     BB                   AA+
         M-3        03072SHT5     CC                   A+
         M-4        03072SHU2     CC                   BB
         M-5        03072SHV0     CC                   CCC

    Asset Backed Securities Corporation Home Equity Loan Trust
                          Series 2003-HE3

                                          Rating
                                          ------
         Class      CUSIP         To                   From
         -----      -----         --                   ----
         M1         04541GEL2     A                    AA
         M2         04541GEM0     CCC                  BB
         M3         04541GEN8     CC                   CCC

    Asset Backed Securities Corporation Home Equity Loan Trust
                          Series 2003-HE4

                                          Rating
                                          ------
         Class      CUSIP         To                   From
         -----      -----         --                   ----
         M2         04541GEV0     BB-                  A
         M3         04541GEW8     CCC                  BB
         M4         04541GEX6     CC                   CCC

       Chase Funding Loan Acquisition Trust, Series 2003-C1
                          Series 2003-C1

                                          Rating
                                          ------
         Class      CUSIP         To                   From
         -----      -----         --                   ----
         IB         161542CS2     CC                   BBB

                Chase Funding Trust, Series 2003-4
                           Series 2003-4

                                          Rating
                                          ------
         Class      CUSIP         To                   From
         -----      -----         --                   ----
         IM-2       161546FY7     BB                   A
         IB         161546FZ4     CC                   BBB
         IIM-1      161546GC4     B+                   AA
         IIB        161546GE0     CC                   B

                       GSAMP Trust 2003-FM1
                          Series 2003-FM1

                                          Rating
                                          ------
         Class      CUSIP         To                   From
         -----      -----         --                   ----
         M-2        36228FNQ5     CC                   BB-
         B-1        36228FNR3     CC                   CCC

                        Mid-State Trust XI

                                          Rating
                                          ------
         Class      CUSIP         To                   From
         -----      -----         --                   ----
         M-2        59549WAC7     B                    A
         B          59549WAD5     CC                   BBB

                 Soundview Home Loan Trust 2003-1
                          Series 2003-1

                                          Rating
                                          ------
         Class      CUSIP         To                   From
         -----      -----         --                   ----
         M-3        83611MAK4     BBB                  AA-
         M-4        83611MAH1     CCC                  A
         M-5        83611MAJ7     CC                   BBB

                         Ratings Affirmed

                Ameriquest Mortgage Securities Inc.
                           Series 2003-7

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A          03072SHQ1     AAA
                 M-1        03072SHR9     AAA

    Asset Backed Securities Corporation Home Equity Loan Trust
                          Series 2003-HE4

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M1         04541GEU2     AA

       Chase Funding Loan Acquisition Trust, Series 2003-C1
                          Series 2003-C1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 IA-4       161542CN3     AAA
                 IA-5       161542CP8     AAA
                 IM-1       161542CQ6     AA
                 IM-2       161542CR4     A

                Chase Funding Trust, Series 2003-4
                           Series 2003-4

                 Class      CUSIP         Rating
                 -----      -----         ------
                 IA-4       161546FU5     AAA
                 IA-5       161546FV3     AAA
                 IA-6       161546FW1     AAA
                 IM-1       161546FX9     AA
                 IIA-2      161546GB6     AAA

                       GSAMP Trust 2003-FM1
                          Series 2003-FM1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        36228FNP7     AA

                        Mid-State Trust XI

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A          59549WAA1     AAA
                 M-1        59549WAB9     AA

                 Soundview Home Loan Trust 2003-1
                           Series 2003-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        83611MAD0     AAA
                 M-2        83611MAE8     AA+


* S&P Downgrades Ratings on 28 Classes From Three CDOs to 'D'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D' on
28 classes of notes from three hybrid and one cash flow
collateralized debt obligation transactions.  The cash flow CDO
transaction is backed predominantly by senior tranches of
residential mortgage-backed securities transactions, while the
hybrid CDO transactions are backed by mezzanine tranches of RMBS
transactions and tranches from other CDO transactions.

The rating actions follow an update to the criteria S&P use to
assess ratings on CDO transactions subject to acceleration or
liquidation after an event of default has occurred.  All of the
transactions in the list below have triggered an EOD, after which
the maturity of the notes was accelerated and the controlling
noteholders elected to liquidate the collateral assets.

S&P has received notices from the trustees stating that the
liquidation of the portfolio assets is complete and that the
available proceeds were insufficient to pay the noteholders in
full.

                          Rating Actions

                                                 Ratings
                                                 -------
Deal Name                          Class       To   From
---------                          -----       --   ----
Topanga CDO Ltd.                   A-1         D    CC
Topanga CDO Ltd.                   A-2         D    CC
Topanga CDO Ltd.                   B           D    CC
Topanga CDO Ltd.                   C           D    CC
Aurelius Capital CDO 2007-1 Ltd.   A           D    CCC-/Watch Neg
Aurelius Capital CDO 2007-1 Ltd.   C           D    CC
Aurelius Capital CDO 2007-1 Ltd.   D           D    CC
Aurelius Capital CDO 2007-1 Ltd.   E           D    CC
Tower Hill CDO II Ltd.             A-1Fund     D    B/Watch Neg
Tower Hill CDO II Ltd.             A-1Unfund   D    B/Watch Neg
Tower Hill CDO II Ltd.             A-X         D    B/Watch Neg
Tower Hill CDO II Ltd.             A-2Fund     D    CC
Tower Hill CDO II Ltd.             A-2Unfund   D    CC
Tower Hill CDO II Ltd.             B Type1Fun  D    CC
Tower Hill CDO II Ltd.             B Type2Fun  D    CC
Tower Hill CDO II Ltd.             B Type2Unf  D    CC
Tower Hill CDO II Ltd.             C Type1Fun  D    CC
Tower Hill CDO II Ltd.             C Type2Fun  D    CC
Tower Hill CDO II Ltd.             C Type2Unf  D    CC
Tower Hill CDO II Ltd.             D           D    CC
Tower Hill CDO II Ltd.             E           D    CC
Kleros Preferred Funding VI Ltd.   A-1S-1A     D    CC
Kleros Preferred Funding VI Ltd.   A-1S-1B     D    CC
Kleros Preferred Funding VI Ltd.   A-1S-2      D    CC
Kleros Preferred Funding VI Ltd.   A-1J        D    CC
Kleros Preferred Funding VI Ltd.   A-2         D    CC
Kleros Preferred Funding VI Ltd.   A-3         D    CC
Kleros Preferred Funding VI Ltd.   B           D    CC


* S&P Downgrades Ratings on 42 Classes From 22 RMBS Transactions
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 42
classes from 22 residential mortgage-backed securities
transactions backed by U.S. subprime mortgage loan collateral
issued from 1993 to 2001.  In addition, S&P affirmed its ratings
on 89 classes from 20 of the downgraded transactions, as well as
on 18 additional deals and removed two of the affirmed ratings
from CreditWatch negative.

The downgrades reflect S&P's opinion that projected credit support
for the affected classes is insufficient to maintain the previous
ratings, given S&P's current projected losses.

To assess the creditworthiness of each class, S&P reviewed the
individual delinquency and loss trends of each transaction for
changes, if any, in risk characteristics, servicing, and the
ability to withstand additional credit deterioration.  In order to
maintain a 'B' rating on a class, S&P assessed whether, in S&P's
view, a class could absorb the base-case loss assumptions S&P used
in its analysis.  In order to maintain a rating higher than 'B',
S&P assessed whether the class could withstand losses exceeding
S&P's base-case loss assumptions at a percentage specific to each
rating category, up to 150% for a 'AAA' rating.  For example, in
general, S&P would assess whether one class could withstand
approximately 110% of S&P's base-case loss assumptions to maintain
a 'BB' rating, while S&P would assess whether a different class
could withstand approximately 120% of S&P's base-case loss
assumptions to maintain a 'BBB' rating.  Each class with an
affirmed 'AAA' rating can, in S&P's view, withstand approximately
150% of its base-case loss assumptions under S&P's analysis.

The affirmed ratings reflect S&P's belief that the amount of
credit enhancement available for these classes is sufficient to
cover losses associated with these rating levels.

Subordination provides credit support for the affected
transactions.  Some classes also benefit from
overcollateralization (prior to its depletion) and excess spread.
The underlying pool of loans backing these transactions consist of
fixed- and adjustable-rate U.S. subprime mortgage loans that are
secured by first and second liens on one- to four-family
residential properties.

                          Rating Actions

                    Aames Mortgage Trust 2001-2
                        Series      2001-2

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-2        00253CGW1     CCC                  A

              Amortizing Residential Collateral Trust
                       Series      2001-BC1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M1         8635725Q2     CCC                  A

    Amresco Residential Securities Corp Mtg Loan Trust 1997-3
                        Series      1997-3

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-2F       03215PCZ0     BB+                  A

  AMRESCO Residential Securities Corp. Mortgage Loan Trust 1999-1
                        Series      1999-1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M1         03215PFP9     CCC                  BBB
        M2         03215PFQ7     CC                   CCC

    Asset Backed Securities Corporation Home Equity Loan Trust
                       Series      2001-HE1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        04541GBC5     CC                   AAA
        M-2        04541GBD3     CC                   BBB-

                  CSFB ABS Trust Series 2001-HE8
                       Series      2001-HE8

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        22540AB64     BB+                  AAA

Home Equity Mortgage Loan Asset-Backed Trust, Series SPMD 2000-A
                      Series      SPMD2000-A

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        MF-1       456606AG7     CC                   AA+
        MF-2       456606AH5     CC                   BB
        MV-1       456606AL6     BBB+                 AA
        MV-2       456606AM4     B-                   BB
        BV         456606AN2     CCC                  B

  Home Equity Mortgage Loan Asset-Backed Trust, Series SPMD 2000-B
                     Series      SPMD 2000B

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        MF-1       456606AT9     CC                   CCC
        MV-1       456606AY8     B+                   AA+
        MV-2       456606AZ5     B                    A

Home Equity Mortgage Loan Asset-Backed Trust, Series SPMD 2001-A
                      Series      SPMD2001-A

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        MF-1       456606BZ4     CC                   BBB-
        AV         456606CD2     BBB+                 AAA
        MV-1       456606CE0     CC                   AA
        MV-2       456606CF7     CC                   A

Home Equity Mortgage Loan Asset-Backed Trust, Series SPMD 2001-B
                      Series      SPMD2001-B

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        MF-1       456606CQ3     CC                   B
        MF-2       456606CR1     CC                   CCC

                 IMC Home Equity Loan Trust 1997-1
                        Series      1997-1

                                  Rating
                                  ------
   Class      CUSIP         To                   From
   -----      -----         --                   ----
   A-6        449670BX5     BBB-                 BBB-/Watch Neg
   A-7        449670BY3     BBB-                 BBB-/Watch Neg

                IMC Home Equity Loan Trust 1997-5
                        Series      1997-5

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        449670DG0     BB-                  AA
        M-2        449670DH8     CCC                  A

                IMC Home Equity Loan Trust 1998-1
                        Series      1998-1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        449670ED6     B                    AA
        M-2        449670EE4     CC                   A

                IMC Home Equity Loan Trust 1998-5
                        Series      1998-5

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        449670FA1     BBB+                 AA
        M-2        449670FB9     B-                   A
        B          449670FC7     CC                   B

               Long Beach Mortgage Loan Trust 2000-1
                        Series      2000-1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        542514AE4     CCC                  B

              Long Beach Mortgage Loan Trust 2001-1
                        Series      2001-1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        542514AM6     B-                   AA+
        M-2        542514AN4     CC                   B

       New Century Home Equity Loan Trust, Series 2001-NC1
                       Series      2001-NC1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-3        64352VCA7     CC                   BB

           Salomon Brothers Mortgage Securities VII Inc.
                       Series      1997-LB6

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        B-3        79548KYC6     CC                   B

           Salomon Brothers Mortgage Securities VII Inc.
                       Series      1998-NC3

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        79548KA73     A+                   AA

               Saxon Asset Securities Trust 2000-2
                        Series      2000-2

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        MF-2       805564GA3     CCC                  A

               Saxon Asset Securities Trust 2000-3
                        Series      2000-3

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        MF-2       805564GT2     CC                   A

             Soundview Home Equity Loan Trust 2001-2
                        Series      2001-2

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        83611PAR2     BB+                  AA
        M-2        83611PAS0     CCC                  A
        M-3        83611PAT8     CC                   BBB

                 Structured Asset Securities Corp.
                       Series      1999-SP1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M1         863572B69     BB                   A
        M2         863572B77     CCC                  BB

                         Ratings Affirmed

                    Aames Mortgage Trust 2001-1
                        Series      2001-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        00253CGL5     AAA
                 A-2        00253CGM3     AAA
                 M-1        00253CGP6     AA+
                 M-2        00253CGQ4     A

                    Aames Mortgage Trust 2001-2
                        Series      2001-2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        00253CGS0     AAA
                 A-2        00253CGT8     AAA
                 M-1        00253CGV3     AA+

   ACE Securities Corp. Home Equity Loan Trust, Series 1999-LB2
                       Series      1999-LB2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A          004421AD5     AAA
                 M-1        004421AE3     AA
                 M-2        004421AF0     A

   ACE Securities Corp. Home Equity Loan Trust, Series 2001-AQ1
                       Series      2001-AQ1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-2        004421AU7     BBB

              Amortizing Residential Collateral Trust
                       Series      2001-BC1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A1         8635725N9     AAA

     Amresco Residential Securities Corp Mtg Loan Trust 1997-3
                        Series      1997-3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-8        03215PCV9     AAA
                 A-9        03215PCW7     AAA
                 M-1A       03215PDD8     AAA
                 M-1F       03215PCY3     AA+

  AMRESCO Residential Securities Corp. Mortgage Loan Trust 1999-1
                        Series      1999-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A          03215PFN4     AAA

                  CSFB ABS Trust Series 2001-HE8
                       Series      2001-HE8

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        22540AB49     AAA

             First Alliance Mortgage Loan Trust 1994-3
                       Series      1994- 3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        31846LAL0     AAA
                 A-2        31846LAM8     AAA

           First Franklin Mortgage Loan Trust 2001-FF1
                       Series      2001-FF1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        32027NAD3     AAA
                 M-1        32027NAF8     AAA

Home Equity Mortgage Loan Asset-Backed Trust, Series SPMD 2000-A
                      Series      SPMD2000-A

                 Class      CUSIP         Rating
                 -----      -----         ------
                 AF-3       456606AF9     AAA

Home Equity Mortgage Loan Asset-Backed Trust, Series SPMD 2000-B
                      Series      SPMD 2000B

                 Class      CUSIP         Rating
                 -----      -----         ------
                 AF-1       456606AS1     AAA
                 BV         456606BA9     CCC

  Home Equity Mortgage Loan Asset-Backed Trust, Series SPMD 2001-A
                      Series      SPMD2001-A

                 Class      CUSIP         Rating
                 -----      -----         ------
                 AF-5       456606BW1     AAA
                 AF-6       456606BX9     AAA

                        HomEq Trust 2001-A
                        Series      2001-A

                 Class      CUSIP         Rating
                 -----      -----         ------
                 AC         43730PAA9     AAA
                 MC-1       43730PAB7     AA+
                 MC-2       43730PAC5     A+
                 BC         43730PAD3     BBB
                 MN-1       43730PAF8     AAA
                 MN-2       43730PAG6     AA+
                 BN         43730PAH4     A

                IMC Home Equity Loan Trust 1997-5
                        Series      1997-5

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-10       449670DE5     AAA
                 A-9        449670DD7     AAA

                 IMC Home Equity Loan Trust 1998-1
                        Series      1998-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-5        449670EA2     AAA
                 A-6        449670EB0     AAA

                 IMC Home Equity Loan Trust 1998-5
                        Series      1998-5

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-5        449670EX2     AAA
                 A-6        449670EY0     AAA

              Long Beach Mortgage Loan Trust 2000-1
                        Series      2000-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 AF-3       542514AC8     AAA
                 AF-4       542514AD6     AAA
                 AV-1       542514AH7     AAA

              Long Beach Mortgage Loan Trust 2001-1
                        Series      2001-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        542514AJ3     AAA
                 S          542514AL8     AAA

          New Century Home Equity Loan Trust Ser 1997-NC5
                       Series      1997-NC5

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-5        64352VAE1     AAA
                 A-6        64352VAF8     AAA
                 A-7IO      64352VAG6     AAA
                 M-1        64352VAH4     AA

        New Century Home Equity Loan Trust, Series 2001-NC1
                       Series      2001-NC1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-2        64352VBZ3     AA

              Residential Mortgage Loan Trust 1998-1
                        Series      1998-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A          76110NAA4     AAA
                 M-1        76110NAF3     AA+
                 M-2        76110NAG1     A+
                 B          76110NAH9     BBB-

           Salomon Brothers Mortgage Securities VII Inc.
                       Series      1997-NC5

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        79548KYG7     AAA

           Salomon Brothers Mortgage Securities VII Inc.
                       Series      1997-LB6

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-5        79548KXX1     AAA
                 A-6        79548KXY9     AAA
                 B-1        79548KYA0     AAA
                 B-2        79548KYB8     AAA

           Salomon Brothers Mortgage Securities VII Inc.
                       Series      1998-AQ1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-5        79548KZH4     AAA
                 A-6        79548KZJ0     AAA
                 A-7        79548KZK7     AAA
                 B-1        79548KZL5     AA

           Salomon Brothers Mortgage Securities VII Inc.
                       Series      1998-NC3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-5        79548KA57     AAA
                 A-6        79548KA65     AAA
                 M-2        79548KA81     B

           Salomon Brothers Mortgage Securities VII Inc.
                       Series      1998-NC4

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-2        79548KC71     A

               Saxon Asset Securities Trust 2000-2
                        Series      2000-2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 MF-1       805564FZ9     AA+

               Saxon Asset Securities Trust 2000-3
                        Series      2000-3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 MF-1       805564GS4     AA+

              Soundview Home Equity Loan Trust 2001-1
                        Series      2001-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A          83611PAJ0     AAA
                 A-IO       83611PAK7     AAA

             Soundview Home Equity Loan Trust 2001-2
                        Series      2001-2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 AF         83611PAP6     AAA

                 Structured Asset Securities Corp.
                        Series      1998-2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A          863572SE4     AAA
                 M-1        863572SF1     AA

                 Structured Asset Securities Corp.
                       Series      1999-SP1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A1         863572A94     AAA
                 A2         863572B28     AAA

      Structured Mortgage Asset Residential Trust, Series 93-1
                       Series      1993- 1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 BF         863573QY0     AAA
                 BY         863573QV6     AAA
                 G          863573QK0     AAA

                  WMC Mortgage Loan Trust 1997-1
                        Series      1997-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        22540ABL1     AAA
                 M-2        22540ABM9     A
                 B          22540ABN7     B

                  WMC Mortgage Loan Trust 1997-2
                        Series      1997-2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        22540AEG9     AAA
                 M-2        22540AEH7     A
                 B          22540AEJ3     BBB

                  WMC Mortgage Loan Trust 1998-A
                        Series      1998-A

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        92928SAB0     AAA
                 B          92928SAD6     BBB


* S&P Downgrades Ratings on 361 Tranches From 140 CDO Transactions
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 361
tranches from 140 U.S. cash flow and hybrid collateralized debt
obligation transactions and removed 38 of the lowered ratings from
CreditWatch with negative implications.

All of the tranches S&P downgraded come from CDO transactions that
have triggered an event of default and, according to S&P's review,
have missed an interest payment on a nondeferrable tranche
following an acceleration of the transaction's maturity that
modified the sequence in which payments are made to the various
classes of noteholders.

These rating actions reflect the implementation of S&P's recently
modified criteria for ratings on CDO transactions that have
triggered an EOD and may be subject to acceleration or
liquidation.

The U.S. cash flow and hybrid tranches S&P downgraded have a total
issuance amount of $38.479 billion and are part of these
transactions:

* Eighty-four mezzanine structured finance CDOs of asset-backed
  securities collateralized in large part by mezzanine tranches of
  residential mortgage-backed securities and other SF securities;

* Thirty-eight high-grade SF CDOs of ABS collateralized in large
  part by senior tranches of RMBS and other SF securities;

* Nine CDO of CDO transactions collateralized primarily by
  tranches from CDOs of ABS and other SF securities;

* Two CDO of CDO transactions collateralized primarily by tranches
  from corporate CDOs;

* Three collateralized loan obligation transactions collateralized
  primarily by loan obligations;

* Three CDO of trust preferred CDO transactions collateralized by
  trust preferred securities; and

* One CDO of commercial mortgage-backed securities collateralized
  by tranches from CMBS transactions and other commercial real
  estate assets.

S&P will continue to monitor the CDO transactions S&P rate and
will take rating actions, including CreditWatch placements, when
S&P believes appropriate.

                          Rating Actions

                                            Rating
                                            ------
  Transaction                   Class      To     From
  -----------                   -----      --     ----
  ACA ABS 2006-1 Ltd.           A-1LA      D      CCC-/Watch Neg
  ACA ABS 2006-1 Ltd.           A-1LB      D      CC
  ACA ABS 2006-1 Ltd.           A-2L       D      CC
  ACA ABS 2006-2 Ltd.           A1LA       D      CC
  ACA ABS 2006-2 Ltd.           A1LB       D      CC
  ACA ABS 2006-2 Ltd.           A2L        D      CC
  ACA ABS 2007-3 Ltd.           A-1LA      D      CC
  ACA ABS 2007-3 Ltd.           A-1LB      D      CC
  ACA ABS 2007-3 Ltd.           A-2L       D      CC
  ACA ABS 2007-3 Ltd.           X          D      CC
  Acacia CDO 6 Ltd.             A-2        D      BBB-/Watch Neg
  Acacia CDO 6 Ltd.             B          D      BB/Watch Neg
  Acacia Option ARM 1 CDO Ltd.  A-1J       D      CC
  Acacia Option ARM 1 CDO Ltd.  A-2        D      CC
  Airlie CDO I Ltd.             A          D      BBB/Watch Neg
  Airlie CDO I Ltd.             B          CC     BB+/Watch Neg
  Airlie CDO I Ltd.             C          CC     B+/Watch Neg
  Airlie CDO I Ltd.             D          CC     CCC/Watch Neg
  Airlie LCDO II (Pebble Creek  B          D      BBB/Watch Neg
   2007-1) Ltd.
  Airlie LCDO II (Pebble Creek  C          D      BB/Watch Neg
   2007-1) Ltd.
  Airlie LCDO II (Pebble Creek  D          CC     CCC/Watch Neg
   2007-1) Ltd.
  Anderson Mezzanine Funding    B          D     CC
   2007-1
  Attentus CDO II Ltd.          A-2        D      B/Watch Neg
  Attentus CDO II Ltd.          A-3A       D      CCC/Watch Neg
  Attentus CDO II Ltd.          A-3B       D      CCC/Watch Neg
  AVANTI Funding 2006-1 Ltd.    A-2        D      CC
  AVANTI Funding 2006-1 Ltd.    A-3        D      CC
  Ayresome CDO I Ltd.           B          D      CC
  Barramundi CDO I Ltd.         A-1        D      CC
  Barramundi CDO I Ltd.         A-2        D      CC
  Barramundi CDO I Ltd.         B          D      CC
  Barrington CDO Ltd.           A-1J       D      CC
  Barrington CDO Ltd.           A-2        D      CC
  Bering CDO I Ltd.             A-2        D      CC
  Bernoulli High Grade CDO      A-1B       D      CC
   II Ltd.
  Bernoulli High Grade CDO      B          D      CC
   II Ltd.
  Bernoulli High Grade CDO      C          D      CC
   II Ltd.
  Bluegrass ABS CDO III Ltd.    A-2        D      CC
  Bluegrass ABS CDO III Ltd.    B          D      CC
  Broderick CDO 2 Ltd.          A-1B       D      CC
  Broderick CDO 2 Ltd.          A-2        D      CC
  Broderick CDO 2 Ltd.          B          D      CC
  Broderick CDO 3 Ltd.          A-4        D      CC
  Broderick CDO 3 Ltd.          A-5        D      CC
  Broderick CDO 3 Ltd.          B          D      CC
  Brookville CDO I Ltd.         A-1        D      CCC-/Watch Neg
  Brookville CDO I Ltd.         A-2        D      CC
  Brookville CDO I Ltd.         A-3        D      CC
  Brookville CDO I Ltd.         B          D      CC
  Cairn High Grade ABS CDO II   A-J        D      CC
  Cairn High Grade ABS CDO II   A-S        D      CC
  Cairn High Grade ABS CDO II   B          D      CC
  Cairn Mezz ABS CDO II Ltd.    A-2a       D      CC
  Cairn Mezz ABS CDO II Ltd.    A-2b       D      CC
  Cairn Mezz ABS CDO II Ltd.    B-1        D      CC
  Cairn Mezz ABS CDO II Ltd.    B-2        D      CC
  Cairn Mezz ABS CDO III Ltd.   A2A        D      CC
  Cairn Mezz ABS CDO III Ltd.   A2B        D      CC
  Cairn Mezz ABS CDO III Ltd.   B1         D      CC
  Cairn Mezz ABS CDO III Ltd.   B2         D      CC
  CAMBER 7 plc                  A-2        D      CC
  CAMBER 7 plc                  A-3        D      CC
  CAMBER 7 plc                  B          D      CC
  Cascade Funding CDO I Ltd.    A-2        D      CC
  C-BASS CBO XVI Ltd.           A          D      CC
  C-BASS CBO XVI Ltd.           B          D      CC
  C-BASS CBO XVII Ltd.          A          D      CC
  C-BASS CBO XVII Ltd.          B          D      CC
  Centre Square CDO Ltd.        A-1        D      CC
  Centre Square CDO Ltd.        A-2A       D      CC
  Centre Square CDO Ltd.        A-2B       D      CC
  Centre Square CDO Ltd.        A-3        D      CC
  Centre Square CDO Ltd.        B          D      CC
  Centre Square CDO Ltd.        C          D      CC
  CETUS ABS CDO 2006-1 Ltd.     A-2        D      CC
  CETUS ABS CDO 2006-2 Ltd.     A-2        D      CC
  Cetus ABS CDO 2006-3 Ltd.     A-1B       D      CC
  Cetus ABS CDO 2006-3 Ltd.     A-2        D      CC
  Cetus ABS CDO 2006-3 Ltd.     B          D      CC
  Cetus ABS CDO 2006-3 Ltd.     S          D      CC
  Cetus ABS CDO 2006-4 Ltd.     A-2        D      CC
  Charles Fort CDO I Ltd.       A-2        D      CC
  Charles Fort CDO I Ltd.       B          D      CC
  Cherry Creek CDO II Ltd.      A1J        D      CC
  Cherry Creek CDO II Ltd.      A-1S       D      CCC/Watch Neg
  Cherry Creek CDO II Ltd.      A2         D      CC
  Class V Funding Ltd.          A2         D      CC
  Class V Funding Ltd.          B          D      CC
  Coda CDO 2007-1 Ltd.          A-1LB      D      CC
  Coda CDO 2007-1 Ltd.          A-2L       D      CC
  Coda CDO 2007-1 Ltd.          X          D      CC
  Crystal River CDO 2005-1 Ltd. D-1        D      CCC/Watch Neg
  Crystal River CDO 2005-1 Ltd. D-2        D      CCC/Watch Neg
  Diogenes CDO II Ltd.          A-1        D      CC
  Diogenes CDO II Ltd.          A-2        D      CC
  Diogenes CDO II Ltd.          B          D      CC
  Diversey Harbor ABS CDO Ltd.  A-2        D      CC
  Diversey Harbor ABS CDO Ltd.  A-3        D      CC
  Diversey Harbor ABS CDO Ltd.  A-4        D      CC
  Duke Funding XI Ltd.          A-1E       D      CC
  Duke Funding XI Ltd.          A-2E       D      CC
  Duke Funding XI Ltd.          X          D      CC
  Duke Funding High Grade III   B-1        D      CC
  Duke Funding High Grade III   B-2        D      CC
  Duke Funding High Grade       B-1        D      CC
   IV Ltd.
  Duke Funding High Grade       B-2        D      CC
   IV Ltd.
  Duke Funding High Grade V     B          D      CC
  Duke Funding IX Ltd.          A2F        D      CC
  Duke Funding IX Ltd.          A2V        D      CC
  Duke Funding VI Ltd.          A1J        D      CC
  Duke Funding VI Ltd.          A2         D      CC
  Duke Funding VII Ltd.         III-A      D      CC
  Duke Funding VII Ltd.         III-B      D      CC
  Dutch Hill Funding I Ltd.     A-1B       D      CC
  Dutch Hill Funding I Ltd.     A-2L       D      CC
  Dutch Hill Funding I Ltd.     A-2X       D      CC
  Dutch Hill Funding I Ltd.     B          D      CC
  E*Trade ABS CDO V Ltd.        A-1J       D      CC
  E*Trade ABS CDO V Ltd.        A-1S       D      CCC-/Watch Neg
  E*Trade ABS CDO V Ltd.        A-2        D      CC
  E*Trade ABS CDO VI Ltd.       A-1J       D      CC
  E*Trade ABS CDO VI Ltd.       A-2        D      CC
  Euler ABS CDO I Ltd.          B          D      CC
  Euler ABS CDO I Ltd.          C          D      CC
  Fort Dearborn CDO I Ltd.      A-1LB      D      CC
  Fort Dearborn CDO I Ltd.      A-2L       D      CC
  Fort Dearborn CDO I Ltd.      X          D      CCC
  Fortius II Funding Ltd.       A-1        D      CC
  Fortius II Funding Ltd.       A-2        D      CC
  Fortius II Funding Ltd.       B          D      CC
  Fulton Street CDO Ltd.        A-2        D      CC
  Gemstone CDO VI Ltd.          B          D      CC
  Glacier Funding CDO IV Ltd.   A-2        D      CC
  Glacier Funding CDO IV Ltd.   B          D      CC
  Glacier Funding CDO V Ltd.    A-1        D      CC
  Glacier Funding CDO V Ltd.    A-2        D      CC
  Glacier Funding CDO V Ltd.    A-3        D      CC
  Glacier Funding CDO V Ltd.    B          D      CC
  Glacier Funding CDO V Ltd.    C          D      CC
  Grand Avenue CDO I Ltd.       A-2        D      CC
  Grand Avenue CDO I Ltd.       B          D      CC
  Grand Avenue CDO III Ltd.     A-2        D      CC
  Grand Avenue CDO III Ltd.     A-3        D      CC
  Grand Avenue CDO III Ltd.     B          D      CC
  GSC ABS CDO 2006-2m Ltd.      A1B        D      CC
  GSC ABS CDO 2006-2m Ltd.      A-2        D      CC
  GSC ABS CDO 2006-2m Ltd.      B          D      CC
  GSC ABS CDO 2006-2m Ltd.      C          D      CC
  GSC ABS CDO 2006-4u Ltd.      A1         D      CC
  GSC ABS CDO 2006-4u Ltd.      A2         D      CC
  GSC CDO 2007-1r Ltd.          A-1LB      D      CC
  GSC CDO 2007-1r Ltd.          A-1LC      D      CC
  GSC CDO 2007-1r Ltd.          A-2LA      D      CC
  HG-COLL 2007-1 Ltd.           A-2L       D      CC
  High Grade Structured Credit  A-2        D      B/Watch Neg
   CDO 2005-1 Ltd.
  High Grade Structured Credit  B          D      CCC+/Watch Neg
   CDO 2005-1 Ltd.
  Highgate ABS CDO Ltd.         A-2        D      CC
  Highgate ABS CDO Ltd.         B          D      CC
  Highridge ABS CDO I Ltd.      A-1AD      D      CC
  Highridge ABS CDO I Ltd.      A-1AT      D      CC
  Highridge ABS CDO I Ltd.      A-2        D      CC
  Highridge ABS CDO I Ltd.      A-3        D      CC
  Highridge ABS CDO I Ltd.      B          D      CC
  Highridge ABS CDO I Ltd.      C          D      CC
  Highridge ABS CDO II Ltd.     A-1J       D      CC
  Highridge ABS CDO II Ltd.     A-2        D      CC
  Hillcrest CDO I Ltd.          A-2        D      CC
  Hillcrest CDO I Ltd.          B-1        D      CC
  Hillcrest CDO I Ltd.          B-2        D      CC
  HSPI Diversified CDO Fund II  A-2        D      CC
  HSPI Diversified CDO Fund II  A-3        D      CC
  HSPI Diversified CDO Fund II  A-4        D      CC
  Hudson Mezzanine Funding      A-1        D      CC
   2006-2
  Hudson Mezzanine Funding      A-2        D      CC
   2006-2
  Hudson Mezzanine Funding      B          D      CC
   2006-2
  IMAC CDO 2006-1 Ltd.          B          D      CC
  IMAC CDO 2006-1 Ltd.          C          D      CC
  IMAC CDO 2006-1 Ltd.          D          D      CC
  Independence V CDO Ltd.       A-2A       D      CC
  Independence V CDO Ltd.       A-2B       D      CC
  Independence V CDO Ltd.       B          D      CC
  Independence VI CDO Ltd.      A2         D      CC
  Independence VI CDO Ltd.      B          D      CC
  Independence VII CDO Ltd.     A-2        D      CC
  Independence VII CDO Ltd.     B          D      CC
  Ivy Lane CDO Ltd.             A-2        D      CC
  Ivy Lane CDO Ltd.             A-3        D      CC
  Jupiter High-Grade CDO        A-2        D      CC
   VI Ltd.
  Jupiter High-Grade CDO        A-3        D      CC
   VI Ltd.
  Jupiter High-Grade CDO        A-4        D      CC
   VI Ltd.
  Jupiter High-Grade CDO        B          D      CC
   VI Ltd.
  Jupiter High-Grade CDO        C          D      CC
   VI Ltd.
  Kent Funding III Ltd.         A-2        D      CC
  Kent Funding III Ltd.         A-3        D      CC
  Kent Funding III Ltd.         B          D      CC
  Khaleej II CDO Ltd.           B          D      CC
  Kleros Preferred Funding VIII B          D      CC
  Kleros Preferred Funding VIII X          D      CC
  Knollwood CDO Ltd.            A-2        D      CC
  Knollwood CDO Ltd.            B          D      CC
  Lacerta ABS CDO 2006-1 Ltd.   A-1        D      CCC-/Watch Neg
  Lacerta ABS CDO 2006-1 Ltd.   A-2        D      CC
  Lexington Capital Funding III A-1        D      CCC-/Watch Neg
  Lexington Capital Funding III A-2        D      CC
  Lexington Capital Funding III A-3        D      CC
  Lexington Capital Funding III B          D      CC
  Lexington Capital Funding III C          D      CC
  Lexington Capital Funding     A-2        D      CC
   V Ltd.
  Lexington Capital Funding     A-3        D      CC
   V Ltd.
  Lexington Capital Funding     B          D      CC
   V Ltd.
  Libertas Preferred Funding II A-2        D      CC
  Libertas Preferred Funding II B          D      CC
  Libertas Preferred Funding II X          D      CCC-/Watch Neg
  Libra CDO Ltd.                A          D      CC
  Libra CDO Ltd.                B          D      CC
  Lincoln Avenue ABS CDO Ltd.   A-2        D      CC
  Lincoln Avenue ABS CDO Ltd.   B          D      CC
  Manasquan CDO 2005-1 Ltd.     A-1LB      D      CC
  Manasquan CDO 2005-1 Ltd.     A-2L       D      CC
  Maxim High Grade CDO I Ltd.   A1         D      CC
  Maxim High Grade CDO I Ltd.   A2         D      CC
  Maxim High Grade CDO I Ltd.   A3         D      CC
  Maxim High Grade CDO I Ltd.   A4         D      CC
  Maxim High Grade CDO I Ltd.   A5         D      CC
  Maxim High Grade CDO I Ltd.   B          D      CC
  Maxim High Grade CDO I Ltd.   C          D      CC
  Maxim High Grade CDO II Ltd.  A-1        D      CC
  Maxim High Grade CDO II Ltd.  A-2        D      CC
  Maxim High Grade CDO II Ltd.  A-3        D      CC
  Maxim High Grade CDO II Ltd.  A-4        D      CC
  Maxim High Grade CDO II Ltd.  B          D      CC
  Maxim High Grade CDO II Ltd.  C          D      CC
  Millstone II CDO Ltd.         A-2        D      CC
  Millstone IV CDO Ltd.         A-2        D      CCC/Watch Neg
  Millstone IV CDO Ltd.         A-3        D      CC
  Millstone IV CDO Ltd.         B          D      CC
  MKP CBO IV Ltd.               A-2        D      BB/Watch Neg
  MKP CBO IV Ltd.               B          D      CC
  MKP CBO V Ltd.                A-2        D      CC
  MKP CBO V Ltd.                B          D      CC
  Montrose Harbor CDO I Ltd.    A-2        D      CC
  Montrose Harbor CDO I Ltd.    B-1        D      CC
  Montrose Harbor CDO I Ltd.    B-2        D      CC
  Mulberry Street CDO II Ltd.   A-2        D      CC
  Mulberry Street CDO Ltd.      A-2        D      CC
  North Cove CDO III Ltd.       C          D      CC
  NovaStar ABS CDO I Ltd.       A-2        D      CC
  NovaStar ABS CDO I Ltd.       B          D      CC
  Octans III CDO Ltd.           A-1        D      CC
  Octans III CDO Ltd.           A-2        D      CC
  Orion 2006-2 Ltd.             A-1B       D      CC
  Orion 2006-2 Ltd.             A-2        D      CC
  Orion 2006-2 Ltd.             B-1        D      CC
  Orion 2006-2 Ltd.             B-2        D      CC
  Orion 2006-2 Ltd.             S          D      CC
  Pacific Bay CDO Ltd.          B          D      B/Watch Neg
  Palmer ABS CDO 2007-1 Ltd.    A-2        D      CC
  Pascal CDO Ltd.               B          D      CC
  Pine CCS Ltd.                 A-1        D      CC
  Pine CCS Ltd.                 A-2        D      CC
  Pinnacle Point Funding        A-1B       D      CCC/Watch Neg
   II Ltd.
  Pinnacle Point Funding        A-2        D      CC
   II Ltd.
  Pinnacle Point Funding        B          D      CC
   II Ltd.
  Point Pleasant Funding        A-1        D      CC
   2007-1
  Point Pleasant Funding        A-2        D      CC
   2007-1
  Point Pleasant Funding        B          D      CC
   2007-1
  Point Pleasant Funding        S          D      CCC-
   2007-1
  Point Pleasant Funding        UnfdSrExpo Dsrp   CCsrp
   2007-1
  Port Jackson CDO 2007-1 Ltd.  A-1        D      CC
  Port Jackson CDO 2007-1 Ltd.  A-2        D      CC
  Port Jackson CDO 2007-1 Ltd.  A-3        D      CC
  Port Jackson CDO 2007-1 Ltd.  B          D      CC
  Pyxis ABS CDO 2006-1 Ltd.     B          D      CC
  Ridgeway Court Funding I Ltd. A2         D      CC
  Ridgeway Court Funding I Ltd. A3         D      CC
  Ridgeway Court Funding I Ltd. A4         D      CC
  Robeco High Grade CDO I Ltd.  A-3        D      CC
  Robeco High Grade CDO I Ltd.  A-4        D      CC
  Robeco High Grade CDO I Ltd.  B          D      CC
  Rockville CDO I Ltd.          A-2        D      CC
  Rockville CDO I Ltd.          A-3        D      CC
  Rockville CDO I Ltd.          B          D      CC
  Rockville CDO I Ltd.          C          D      CC
  Sharps CDO II Ltd.            A-2        D      CC
  Sharps CDO II Ltd.            A-3        D      CC
  Sharps CDO II Ltd.            B          D      CC
  Sherwood Funding CDO II Ltd.  A-2        D      CC
  Sherwood Funding CDO II Ltd.  B          D      CC
  Sherwood Funding CDO Ltd.     A-2        D      CC
  Sherwood Funding CDO Ltd.     B-1        D      CC
  Sherwood Funding CDO Ltd.     B-2        D      CC
  Sherwood III ABS CDO Ltd.     A1J        D      CC
  Sherwood III ABS CDO Ltd.     A1SA       D      CCC/Watch Neg
  Sherwood III ABS CDO Ltd.     A1SB       D      CCC/Watch Neg
  Sherwood III ABS CDO Ltd.     A2         D      CC
  Silver Elms CDO II Ltd.       A-2        D      CC
  Silver Elms CDO II Ltd.       A-3        D      CC
  Silver Marlin CDO I Ltd.      A-2        D      CC
  Silver Marlin CDO I Ltd.      A-3        D      CC
  Silver Marlin CDO I Ltd.      A-4        D      CC
  Silver Marlin CDO I Ltd.      B          D      CC
  Silver Marlin CDO I Ltd.      C          D      CC
  Slate CDO 2007-1 Ltd.         A1J        D      BB/Watch Neg
  Slate CDO 2007-1 Ltd.         A2         D      B/Watch Neg
  Sorin CDO VI Ltd.             A-2L       D      CC
  South Coast Funding VII Ltd.  A-2        D      CC
  South Coast Funding VII Ltd.  B          D      CC
  South Coast Funding VIII Ltd. A-2        D      CC
  South Coast Funding VIII Ltd. B          D      CC
  Squared CDO 2007-1 Ltd.       A-1        D      CC
  Squared CDO 2007-1 Ltd.       A-2a       D      CC
  Squared CDO 2007-1 Ltd.       A-2b       D      CC
  Squared CDO 2007-1 Ltd.       B          D      CC
  STACK 2007-2 Ltd.             A-1        D      CC
  STACK 2007-2 Ltd.             A-2        D      CC
  STACK 2007-2 Ltd.             B          D      CC
  STAtic ResidenTial CDO 2006-A B          D      CC
  STAtic ResidenTial CDO 2006-B A-1(a)     D      CC
  STAtic ResidenTial CDO 2006-B A-1(b)     D      CC
  STAtic ResidenTial CDO 2006-B A-2        D      CC
  STAtic ResidenTial CDO 2006-B B-1        D      CC
  Stillwater ABS CDO 2006-1     A-2        D      CC
   Ltd.
  Stillwater ABS CDO 2006-1     A-3        D      CC
   Ltd.
  Stillwater ABS CDO 2006-1     B          D      CC
   Ltd.
  Stockton CDO Ltd.             A-2        D      CC
  Stockton CDO Ltd.             A-3        D      CC
  Straits Global ABS CDO I Ltd. A-2        D      BB/Watch Neg
  Straits Global ABS CDO I Ltd. B-1        D      CC
  Straits Global ABS CDO I Ltd. B-2        D      CC
  TABERNA Preferred Funding III B-1        D      CCC-/Watch Neg
  TABERNA Preferred Funding III B-2        D      CCC-/Watch Neg
  TABERNA Preferred Funding     B-1        D      CCC-/Watch Neg
   IV Ltd.
  TABERNA Preferred Funding     B-2        D      CCC-/Watch Neg
   IV Ltd.
  Tabs 2005-4 Ltd.              B          D      CC
  Tabs 2005-4 Ltd.              C          D      CC
  TAHOMA CDO II Ltd.            A-2        D      CC
  TAHOMA CDO II Ltd.            B          D      CC
  Tazlina Funding CDO II Ltd.   A-3        D      CC
  Tazlina Funding CDO II Ltd.   B          D      CC
  Tazlina Funding CDO II Ltd.   C          D      CC
  Term CDO 2007-1 Ltd.          A-2L       D      CC
  Volans Funding 2007-1 Ltd.    A-1        D      CC
  Volans Funding 2007-1 Ltd.    A-2        D      CC
  Volans Funding 2007-1 Ltd.    B          D      CC
  Wadsworth CDO Ltd.            A-2        D      CC
  Wadsworth CDO Ltd.            B          D      CC
  Webster CDO I Ltd.            A-1LA      D      CC
  Webster CDO I Ltd.            A-1LB      D      CC
  Webster CDO I Ltd.            A-2L       D      CC
  West Trade Funding CDO III    A-4        D      CC
   Ltd.
  West Trade Funding CDO III    B          D      CC
   Ltd.
  West Trade Funding CDO III    C          D      CC
   Ltd.
  West Trade Funding II CDO     A-3        D      CC
   Ltd.
  West Trade Funding II CDO     A-4        D      CC
   Ltd.
  West Trade Funding II CDO     B          D      CC
   Ltd.
  West Trade Funding II CDO     C          D      CC
   Ltd.
  Zais Investment Grade Ltd. V  A-2        D      BB+/Watch Neg
  Zais Investment Grade Ltd.    A-2        D      B-/Watch Neg
   VII
  Zais Investment Grade Ltd.    A-3        D      CC
   VII
  Zais Investment Grade Ltd.    A-2        D      CC
   VIII
  Zais Investment Grade Ltd.    B          D      CC
   VIII



                           *********

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.  Howard C. Tolentino, 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 ***