TCR_Public/091115.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 15, 2009, Vol. 13, No. 316

                            Headlines



ABACUS 2006-17: Fitch Downgrades Ratings on Seven Classes
ABACUS 2006-13: Fitch Downgrades Ratings on 11 Classes of Notes
AROSA FUNDING: S&P Withdraws 'CCC' Rating on Two Series of Notes
BANC OF AMERICA: S&P Downgrades Ratings on 19 2007-5 Securities
CAPITAL TRUST: Fitch Downgrades Ratings on All Classes of Notes

CARBON CAPITAL: S&P Downgrades Ratings on Nine 2005-1 CRE CDOs
CITIGROUP MORTGAGE: S&P Downgrades Ratings on 11 2007-11 Certs.
CITIGROUP MORTGAGE: S&P Gives Ratings on 12 2009-2 Securities
CLOVERIE PLC: Fitch Withdraws Rating on 2006-3 Notes to 'D/RR6'
COMM 2006-CNL2: S&P Downgrades Ratings on 13 Securities

CORPORATE BACKED: Moody's Upgrades Ratings on Class A-1 Certs.
CORPORATE BACKED: Moody's Upgrades Ratings on 2001-36 Certs.
CORPORATE BACKED: S&P Raises Rating on 2001-36 Certs. to 'CCC'
CORPORATE BACKED: S&P Raises Rating on $25 Mil. Certs. to 'CCC'
CORTS TRUST: S&P Raises Rating on $219.584 Mil. Certs. to 'CCC'

CORTS TRUST: Moody's Raises Ratings on Certificates to 'Caa1'
CORTS TRUST: Moody's Upgrades Ratings on Certificates to 'Caa1'
CORTS TRUST: S&P Raises Rating on $300 Mil. Certs. to 'CCC'
CREDIT SUISSE: S&P Downgrades Ratings on Five 2001-SPG1 Securities
CREDIT SUISSE: S&P Downgrades Rating on 2005-TFL2 Certificates

DEUTSCHE MORTGAGE: S&P Downgrades Ratings on 38 2006-PR1 Certs.
DEUTSCHE ALT-A: S&P Downgrades Ratings on Three 2007-RS1 Certs.
FALL CREEK: Fitch Downgrades Ratings on Three Classes of Notes
FOLEY SQUARE: Moody's Reviews Ratings on Various 2007-1 Notes
GREENWICH CAPITAL: S&P Downgrades Ratings on 15 2007-RR2 Certs.

GS MORTGAGE: S&P Downgrades Ratings on 10 2007-GKK1 Securities
GSC PARTNERS: Moody's Downgrades Ratings on Various Classes
INDEPENDENCE II: Moody's Downgrades Ratings on Class A Notes
JPMORGAN CHASE: S&P Downgrades Ratings on 16 2006-LDP7 Securities
JPMORGAN CHASE: S&P Downgrades Ratings on 18 2006-LDP8 Securities

LBSBC NIM: S&P Downgrades Ratings on All Classes of Notes
LOAN FUNDING: Fitch Cuts & Withdraws Rating on 2003-1 Notes
MALIBU LOAN: Fitch Affirms Ratings on $110.8 Mil. Notes at 'CCC'
MARATHON CLO: Moody's Reviews Ratings on Two Classes of Notes
MERRILL LYNCH: S&P Downgrades Ratings on Three 1999-C1 Certs.

MILLENNIUM PARK: Moody's Reviews Ratings on Two Classes of Notes
MKP CBO: Fitch Downgrades Ratings on Three Classes of Notes
ML-CFC COMMERCIAL: S&P Downgrades Ratings on 39 Securities
MORGAN STANLEY: Moody's Reverses Rating Actions on $200 Mil. Notes
MORGAN STANLEY: S&P Downgrades Ratings on 14 2005-IQ10 Securities

MORGAN STANLEY: S&P Downgrades Ratings on 15 2006-IQ11 Securities
MORGAN STANLEY: S&P Downgrades Ratings on 14 2005-TOP17 Securities
PACIFICA CDO: Moody's Downgrades Ratings on Two Classes of Notes
POTOMAC LIFE: Moody's Withdraws Ratings on Insurance Securities
PPLUS TRUST: Moody's Upgrades Ratings on FMC-1 Certs. to 'Caa1'

PPLUS TRUST: S&P Raises Rating on $40 Mil. Certs. to 'CCC'
PREFERREDPLUS TRUST: Moody's Upgrades Ratings on Certs. to 'Caa1'
PUBLIC STEERS: S&P Raises Ratings on 1998 F-Z4 Certs. to 'CCC's
PREFERREDPLUS TRUST: S&P Raises Rating on $50 Mil. Certs. to 'CCC'
PUBLIC STEERS: Moody's Lifts Ratings on 1998 F-Z4 Certs. to 'Caa1'

ROCKALL CLO: Moody's Downgrades Ratings on Four Classes of Notes
ROSEMONT CLO: Fitch Affirms Ratings on Three Classes of Notes
SATURN VENTURES: Fitch Downgrades Ratings on Two Classes of Notes
SATURNS TRUST: Moody's Upgrades Ratings on 2003-5 Units to 'Caa1'
SATURNS TRUST: S&P Raises Rating on $75 Mil. Units to 'CCC'

SEAWALL SPC: S&P Withdraws Ratings on 24 Classes of Notes
STARWOOD HOTELS: Fitch Assigns 'BB+' Rating on Senior Notes
STRUCTURED ASSET: Moody's Adjusts Ratings on Tranche AXP1
TBW MORTGAGE-BACKED: S&P Corrects Ratings on 128 Securities
TIAA STRUCTURED: Moody's Downgrades Rating on Class A-1 Notes

TRICADIA CDO: Moody's Downgrades Ratings on Three Classes of Notes
TRUST CERTIFICATES: Moody's Lifts Ratings on 2002-1 Certs. to Caa1
TRUST CERTIFICATES: S&P Raises Rating on $32 Mil. Certs. to 'CCC'
WACHOVIA BANK: S&P Downgrades Ratings on 16 2006-C29 Securities
WACHOVIA BANK: S&P Downgrades Ratings on 22 2006-WHALE7 Certs.

WICKER PARK: Moody's Reviews Ratings on Four Classes of Notes
WIREFREE PARTNERS: Moody's Keeps 'BB' Ratings on Lease-Back Notes

* Fitch Takes Various Rating Actions on Five Re-Performing RMBS
* S&P Downgrades Ratings on 145 Tranches From 25 CLO Transactions



                            *********

ABACUS 2006-17: Fitch Downgrades Ratings on Seven Classes
---------------------------------------------------------
Fitch Ratings has downgraded seven classes and removed nine
classes issued by Abacus 2006-17 from Rating Watch Negative as a
result of significant negative credit migration within the
reference portfolio and within the eligible investment account.

As of the Aug. 21, 2009 trustee report, 37.9% of the eligible
investments are rated 'CC'.  According to the transaction
documents, a collateral default constitutes an Optional Early
Termination/Event of Default resulting in a Mandatory Redemption.
Given the credit ratings of the eligible investments, a collateral
default is probable.

If a Mandatory Redemption occurs, Goldman Sachs International
(GSI), as the put counterparty, would no longer be required to
purchase the eligible investments at 100% of par, resulting in the
eligible investments being subject to collateral market value
risk.  Upon any required liquidation of the below investment grade
collateral in the eligible account, Fitch expects low recoveries.
Additionally under a Mandatory Redemption, the issuer may owe
various termination payments to counterparties under swap and
other agreements associated with the transaction.  As a result,
Fitch anticipates significant losses in the event of a Mandatory
Redemption.

Classes marked paid in full have been fully redeemed under the
Optional Redemption provision.  The provision allows the issuer to
redeem the notes using principal proceeds from the eligible
investment account.  The notes may be redeemed without regard to
sequential order.  Principal proceeds may also be used to reinvest
under the eligible investment criteria.  Use of the proceeds are
under the sole discretion of the issuer (Goldman Sachs).

Since Fitch's last rating action in January 2009, approximately
53.3% of the reference portfolio has been downgraded, and 57.5%
was placed on Rating Watch Negative.  Approximately 97.5% of the
portfolio has a Fitch-derived rating below investment grade and
25% has a rating in the 'CCC' rating category or lower, compared
to 24.2% and 0%, respectively, at last review.  The reference
portfolio is composed of 50 commercial mortgage backed securities
and five structured finance collateralized debt obligations, of
which 90.8% are CMBS assets from the 2005 and 2006 vintages, 8.3%
are SF CDOs from the 2005 and 2006 vintages, and the balance are
CMBS assets from the 2004 vintage (0.8%).

This transaction was analyzed 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.  The rating assigned to the class A-
1 notes, however, is dependent on the rating of the lowest rated
eligible investment ('CC'), reflecting the risk of an Event of
Default and subsequent liquidation of the collateral.

Due to the significant collateral deterioration, all PCM rating
loss rates exceed the credit enhancement available to the class A-
2 notes and below.  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, the expected low
recoveries upon default, and the rating cap implied by the lowest
rated asset in the eligible investment account, these classes have
been assigned a 'CC' rating.

Abacus 2006-17 is a static synthetic CDO transaction issued in
December 2006 that references a US$600 million CMBS portfolio.
The transaction is designed to provide credit protection for
realized losses on the reference portfolio through a credit
default swap between the issuer and the swap counterparty, Goldman
Sachs Capital Markets, L.P., which is rated 'A+/F1+' with a Stable
Outlook by Fitch.

Proceeds from the securities are invested in a pool of eligible
investments, which are protected through the collateral put
agreement between the issuer and the put counterparty, GSI.  The
payment obligations of the put counterparty are guaranteed by GSI,
the swap counterparty guarantor, under all conditions except for a
Mandatory Redemption.  A Mandatory Redemption can occur in an
Event of Default or termination event.

Fitch has downgraded these classes as indicated and are removed
from Rating Watch Negative:

  -- $66,000,000 Class A-1 to 'CC' from 'BBB-' ;
  -- $72,000,000 Class A-2 to 'CC' from 'BB';
  -- $20,000,000 Class B to 'CC' from 'BB-' ;
  -- $16,500,000 Class C to 'CC' from 'BB-';
  -- $13,500,000 Class E to 'CC' from 'B';
  -- $6,000,000 Class L to 'CC' from 'CCC';
  -- $3,900,000 Class M to 'CC' from 'CCC'.

In addition classes D, F, G, H (also removed from Rating Watch
Negative), J, K, N, O , P, Q have been paid in full.


ABACUS 2006-13: Fitch Downgrades Ratings on 11 Classes of Notes
---------------------------------------------------------------
Fitch Ratings has downgraded 11 classes and removed 13 classes
issued by Abacus 2006-13 from Rating Watch Negative as a result of
significant negative credit migration within the reference
portfolio and within the eligible investment account.  A complete
list of rating actions follows at the end of this press release.

As of the Sept. 21, 2009 trustee report, 20.9% of the eligible
investments are rated below investment grade and 12.1% have a
rating in the 'CCC' category.  According to the transaction
documents, a collateral default constitutes an Optional Early
Termination/Event of Default resulting in a Mandatory Redemption.
Given the credit ratings of the eligible investments, a collateral
default is a real possibility.

If a Mandatory Redemption occurs, Goldman Sachs International, as
the put counterparty, would no longer be required to purchase the
eligible investments at 100% of par, resulting in the eligible
investments being subject to collateral market value risk.  Upon
any required liquidation of the below investment grade collateral
in the eligible account, Fitch expects low recoveries.
Additionally under a Mandatory Redemption, the issuer may owe
various termination payments to counterparties under swap and
other agreements associated with the transaction.  As a result,
Fitch anticipates significant losses in the event of a Mandatory
Redemption.

Classes marked paid in full have been fully redeemed under the
Optional Redemption provision.  The provision allows the issuer to
redeem the notes using principal proceeds from the eligible
investment account.  The notes may be redeemed without regard to
sequential order.  Principal proceeds may also be used to reinvest
under the eligible investment criteria.  Use of the proceeds are
under the sole discretion of the issuer (Goldman Sachs).

Since Fitch's last rating action in January 2009, approximately
45.4% of the reference portfolio has been downgraded, and 48.3%
was placed on Rating Watch Negative.  Approximately 78.2% of the
portfolio has a Fitch-derived rating below investment grade and
5.4% has a rating in the 'CCC' rating category or lower, compared
to 2.5% and 0%, respectively, at last review.  The reference
portfolio is composed of 79 commercial mortgage backed securities,
of which 58.4% are from the 2005 and 2006 vintages, with the
balance from the 2004 vintage and prior (41.7%).

This transaction was analyzed 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 each of classes B through F is generally
consistent with the PCM rating loss rate for the 'CCC' rating
category.  The rating assigned to the class A notes is dependent
on the rating of the lowest rated eligible investment ('CCC'),
reflecting the risk of an Event of Default and subsequent
liquidation of the collateral.

Due to the significant collateral deterioration, all PCM rating
loss rates exceed the credit enhancement available to class G and
below.  For these classes, Fitch compared the respective credit
enhancement levels to the amount of underlying assets with a
Fitch-derived rating of 'CCC', Given the high probability of
default of these assets, the expected low recoveries upon default,
and the rating cap implied by the lowest rated asset in the
eligible investment account, these classes have been assigned a
'CCC' rating.

Abacus 2006-13 is a static synthetic collateralized debt
obligation transaction issued in September 2006 that references a
US$795 million CMBS portfolio.  The transaction is designed to
provide credit protection for realized losses on the reference
portfolio through a credit default swap between the issuer and the
swap counterparty, Goldman Sachs Capital Markets, L.P., which is
rated 'A+/F1+' with a Stable Outlook by Fitch.

Proceeds from the securities are invested in a pool of eligible
investments, which are protected through the collateral put
agreement between the issuer and the put counterparty, GSI.  The
payment obligations of the put counterparty are guaranteed by GSI,
the swap counterparty guarantor, under all conditions except for a
Mandatory Redemption.  A Mandatory Redemption can occur in an
Event of Default or termination event.

Fitch has downgraded these classes and removed them from Rating
Watch Negative:

  -- $159,000,000 class A to 'CCC from 'BBB-';
  -- $44,718,750 class B to 'CCC' from 'BB+';
  -- $10,931,250 class C to 'CCC' from 'BB+';
  -- $11,925,000 class D to 'CCC' from 'BB';
  -- $11,925,000 class E to 'CCC' from 'BB';
  -- $8,000,000 class F to 'CCC' from 'BB-';
  -- $2,950,000 class G to 'CCC' from 'BB-';
  -- $4,000,000 class H to 'CCC' from 'B+';
  -- $2,943,750 class K to 'CCC' from 'B';
  -- $9,937,500 class L to 'CCC' from 'B-';
  -- $4,950,000 class M to 'CCC' from 'B-'.

In addition, classes J and N have paid in full.


AROSA FUNDING: S&P Withdraws 'CCC' Rating on Two Series of Notes
----------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its 'CCC' ratings on
the notes issued by Arosa Funding Ltd.'s series 2004-1 and 2006-1.
Both transactions are synthetic corporate investment-grade
collateralized debt obligations.  The ratings were previously on
CreditWatch with negative implications.

The rating withdrawals follow the repurchase of the notes by the
arranger.

                         Ratings Withdrawn

                         Arosa Funding Ltd.
                           Series 2004-1

                            Rating
                            ------
                  Class    To      From
                  -----    --      ----
                  A        NR      CCC/Watch Neg

                        Arosa Funding Ltd.
                          Series 2006-1

                            Rating
                            ------
                  Class    To      From
                  -----    --      ----
                  Notes    NR     CCC/Watch Neg

                          NR - Not rated.


BANC OF AMERICA: S&P Downgrades Ratings on 19 2007-5 Securities
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 19
classes of commercial mortgage-backed securities from Banc of
America Commercial Mortgage Trust 2007-5 and removed them from
CreditWatch with negative implications.  Concurrently, S&P
affirmed its ratings on five additional classes from this
transaction.

The downgrades follow S&P's 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
classes also reflect credit support erosion S&P anticipate will
occur upon the eventual resolution of the specially serviced
assets.  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 1.31x and a loan-to-value ratio of 119.1%.
S&P further stressed the loans' cash flows under S&P's 'AAA'
scenario to yield a weighted average DSC of 0.83x and an LTV of
163.2%.  The implied defaults and loss severity under the 'AAA'
scenario were 93.0% and 42.5%, respectively.  To date, there are
no defeased loans in the pool.  All of the DSC and LTV
calculations noted above exclude four ($52.8 million, 2.9%) of the
nine specially serviced assets.  S&P separately estimated losses
for these four loans and included them in S&P's 'AAA' scenario
implied default and loss figures.

The affirmations of S&P's ratings on the principal and interest
certificates reflect subordination levels that are consistent with
the outstanding ratings through various stress scenarios.  S&P
affirmed its ratings on the class XW interest-only certificate
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 finalize its criteria review, S&P may
revise its current IO criteria, which may affect outstanding
ratings, including the ratings on the IO certificates S&P
affirmed.

                      Credit Considerations

Nine assets ($137.9 million, 7.5%) in the pool are with the
special servicer, Centerline Servicing Inc. (Centerline).  A
breakdown of the specially serviced assets by payment status is:
two ($47.6 million, 2.6%) of these assets are in foreclosure; four
($12.7 million, 0.7%) are more than 90 days delinquent; one
($3.7 million, 0.2%) is more than 60 days delinquent; one
($67.5 million, 3.7%) is current; and one ($6.3 million, 0.3%) is
in its grace period.  Seven of the specially serviced loans have
appraisal reduction amounts in effect totaling $22.4 million.  One
specially serviced asset, the Green Oak Village Place loan
($67.5 million, 3.7%), is a top 10 loan.  S&P discuss this asset
in further detail below.

The West Hartford Portfolio loan ($36.9 million, 2.0%) is the
second-largest exposure with the special servicer and is secured
by a 23-building, 680-unit multifamily portfolio in Hartford,
Conn.  The loan was transferred to Centerline on Jan. 21, 2009,
due to imminent default and is currently in foreclosure.  Standard
& Poor's expects a significant loss upon the resolution of this
asset.

Apart from the Green Oak Village Place loan discussed below, the
remaining specially serviced loans have balances that individually
represent less than 1.0% of the total pool balance.  Loan
modifications are either in progress or being discussed for two
(0.4%) loans, one (0.2%) of which is a recent transfer.

                       Transaction Summary

As of the October 2009 remittance report, the collateral pool
consisted of 98 loans with an aggregate trust balance of
$1.84 billion, down from 100 loans and $1.86 billion at issuance.
The master servicer for the transaction is Bank of America N.A.
The master servicer provided financial information for 100% of the
loans in the pool, and 90.5% of the servicer-provided information
was full-year 2008 or interim-2009 data.  S&P calculated a
weighted average DSC of 1.32x for loans based on the reported
figures.  S&P's adjusted DSC and LTV were 1.31x and 119.1%,
respectively.  S&P's adjusted DSC and LTV figures excluded four
(2.6%) specially serviced loans, which S&P stressed separately.
Based on the servicer-reported DSC figures, S&P calculated a
weighted average DSC of 1.08x for two (0.4%) of these four assets.
To date, the transaction has experienced two principal losses
totaling $5.71 million.  Twenty-one loans ($390.6 million, 21.2%)
are on the master servicer's watchlist, including the fifth-
largest and ninth-largest loans.  Four loans ($100.8 million,
5.5%) have reported DSC between 1.0x and 1.10x, and 12 loans
($214.9 million, 11.7%) have reported DSC of less than 1.0x.

                     Summary of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$936.0 million (50.8%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.27x for the top 10 loans.
S&P's adjusted DSC and LTV for the top 10 loans were 1.23x and
126.9%, respectively.  Of these loans, one is with the special
servicer and two are on the master servicer's watchlist.

The Green Oak Village Place loan ($67.5 million, 3.7%) is the
seventh-largest loan in the pool and the largest exposure with the
special servicer.  The loan is secured by a 315,094-sq.-ft.
lifestyle center built in 2006 in Brighton, Mich., 45 miles
northwest of Detroit.  The loan was transferred to Centerline on
Jan. 26, 2009, due to imminent default.  A modification of the
loan has been approved, which will allow the borrower access to
debt service reserve funds for various uses, including property
improvements that may improve operating performance.  The loan was
current as of the Oct. 13, 2009, remittance report.  Reported
year-end 2008 DSC was 1.21.

The Smith Barney Building loan ($99.6 million, 5.4%) is the fifth-
largest loan in the pool and the largest loan on the watchlist.
The loan is secured by a 188,232-sq.-ft., 10-story office tower in
the Golden Triangle/UTC submarket in San Diego.  For the 12 months
ended June 30, 2009, reported DSC was 0.76x.  The lease for the
largest tenant (28.7% net rentable area) at the space expired in
February 2009, and the space is now vacant.  Consequently,
occupancy at the property has decreased to 62.0% from 92.0% at
issuance.  However, there is currently a leasing prospect for half
of this space.

The Sherman Oaks Marriott loan ($53.9 million, 2.9%) is the ninth-
largest loan in the pool and the second-largest loan on the
watchlist.  The loan is secured by a 213-room limited-service
hotel in Sherman Oaks, Calif., built in 1966 and renovated in
2005.  For the 12 months ended June 30, 2009, reported DSC was
0.89x and occupancy was 65.8%.  However, the reported DSC based on
net operating income is 1.02x.

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

        Banc of America Commercial Mortgage Trust 2007-5
   Commercial mortgage pass-through certificates series 2007-5

                 Rating
                 ------
     Class     To      From             Credit enhancement (%)
     -----     --      ----             ----------------------
     A-4       A+      AAA/Watch Neg                    29.97
     A-1A      A+      AAA/Watch Neg                    29.97
     A-M       BBB     AAA/Watch Neg                    19.88
     A-J       BB      AAA/Watch Neg                    12.31
     B         BB-     AA+/Watch Neg                    11.17
     C         B+      AA/Watch Neg                     10.41
     D         B+      AA-/Watch Neg                     9.28
     E         B+      A+/Watch Neg                      8.27
     F         B+      A/Watch Neg                       7.64
     G         B       A-/Watch Neg                      6.63
     H         B       BBB+/Watch Neg                    5.49
     J         B-      BBB/Watch Neg                     4.61
     K         B-      BBB-/Watch Neg                    3.60
     L         B-      BB+/Watch Neg                     2.97
     M         CCC+    BB/Watch Neg                      2.59
     N         CCC+    BB-/Watch Neg                     2.34
     0         CCC     B+/Watch Neg                      1.96
     P         CCC     B/Watch Neg                       1.84
     Q         CCC-    B-/Watch Neg                      1.58

                         Ratings Affirmed

         Banc of America Commercial Mortgage Trust 2007-5
    Commercial mortgage pass-through certificates series 2007-5

     Class     Rating                  Credit enhancement (%)
     -----     ------                  ----------------------
     A-1       AAA                                      29.97
     A-2       AAA                                      29.97
     A-3       AAA                                      29.97
     A-SB      AAA                                      29.97
     XW        AAA                                        N/A


CAPITAL TRUST: Fitch Downgrades Ratings on All Classes of Notes
---------------------------------------------------------------
Fitch Ratings downgrades all classes of Capital Trust RE CDO 2004-
1 reflecting Fitch's base case loss expectation of 38.5%.  Fitch's
performance expectation incorporates prospective views regarding
commercial real estate market value and cash flow declines.  A
detailed list of rating actions follows at the end of this
release.

CT 2004-1 is mostly collateralized by subordinate commercial real
estate debt (80% of total collateral is either B-notes or
mezzanine loans).  Fitch expects significant losses upon default
for these assets since they are generally highly leveraged, thin
debt classes.  Further, six assets (22.6%) are currently
defaulted, five (19%) of which are B-notes or mezzanine loans, and
one (3.6%) of which is a real estate bank loan.  Fitch expects
nearly 100% loss on these defaulted assets.

Both the A/B and the C/D/E overcollateralization tests have
breached their respective covenants.  As a result, classes C and
below are no longer receiving any proceeds as of the October 2009
trustee report.  All excess interest proceeds (after class B) and
any principal proceeds are currently being redirected to redeem
the class A-1 notes.  Given its expectations of further defaults,
Fitch considers it unlikely that classes below the C/D/E OC test
will receive any further proceeds over the life of the
transaction.  Additionally, Fitch expects that classes C through E
will receive minimal to no proceeds over the remaining life of the
transaction.

CT 2004-1 is a $314.1 million CRE collateralized debt obligation
managed by CT Investment Management Co., LLC.  The transaction had
a five-year reinvestment period which ended July 2008.  As of the
October 2009 trustee report and per Fitch categorizations, the CDO
was substantially invested: B-notes (55.3%), CRE mezzanine loans
(24.8%), commercial mortgage-backed securities (CMBS; 8.9%), a
defeased CRE loan (7.3%), and a real estate bank loan (3.6%).

Under Fitch's updated methodology, approximately 43.6% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the modeled average
cash flow decline is 12.6% from first quarter 2009 trailing-12-
month cash flows.  Fitch estimates that average recoveries will be
low at 11.7%, due to the highly leveraged and subordinate nature
of the assets.

The largest component of Fitch's base case loss expectation is a
B-note (7.7%) that matured in October 2009 and was not repaid.
The loan is secured by a 374,000 square foot office park located
in Menlo Park, California.  The property is currently
approximately 76% occupied; additionally, the leases of its two
largest tenants (58% of net rentable SF), which are significantly
above market, expire in early 2010.

The next largest component of Fitch's base case loss expectation
is a term loan (4.7%) that became delinquent in July 2009.  The
loan is secured by first mortgages on three office properties and
equity interests in another 18 office properties.  The portfolio
is located mostly in Washington, D.C., and partially in northern
Virginia and suburban Maryland.  While performance of the
portfolio has been stable, the sponsor has stopped paying debt
service and is seeking to restructure the highly leveraged loan.

The third largest component of Fitch's base case loss expectation
is a B-note (3.3%) that became delinquent in July 2009.  The loan
is secured by three hotel/casinos.  Two of the hotel/casinos are
located in Mississippi, while the other is in Atlantic City, New
Jersey.  The Atlantic City hotel/casino has drastically
underperformed expectations, causing the overall portfolio cash
flow to decline significantly below debt service.

This transaction was analyzed according to the 'U.S. CREL CDO
Surveillance Criteria', which applies stresses to property cash
flows and uses DSCR tests to project future default levels for the
underlying portfolio.  Recoveries are based on stressed cash flows
and Fitch's long-term capitalization rates.  The default levels
were then compared to the breakeven levels generated by Fitch's
cash flow model of the CDO under the various default timing and
interest rate stress scenarios, as described in the report 'Global
Criteria for Cash Flow Analysis in CDOs'.  Based on this analysis,
the class A-1 notes' breakeven rates are generally consistent with
the 'BBB' rating category; the class A-2 notes' breakeven rates
are generally consistent with the 'BB' rating category; and the
class B notes' breakeven rates are generally consistent with the
'B' rating category.

Ratings for classes C through G are generally based on a
deterministic analysis, which considers the current percentage of
defaulted assets factoring in anticipated recoveries relative to
the credit enhancement of the respective class, as well as the
likelihood for OC tests to cure.  Based on this analysis, class C
is consistent with the 'CC' rating category, meaning default is
probable given current defaulted assets of 22.6% and Fitch's base
case loss expectation of 38.5%.  Ratings for classes D through G
are deemed to be consistent with the 'C' rating category, as Fitch
considers a default on these classes to be inevitable.  The
current percentage of defaulted assets, factoring in anticipated
recoveries, either exceeds or is very close to each of these
classes' respective credit enhancement.

The class A-1 through B notes were each assigned a Negative Rating
Outlook reflecting Fitch's expectation of further negative credit
migration of the underlying collateral.  These classes were also
assigned Loss Severity ratings ranging from 'LS4' to 'LS5'.  The
LS ratings indicate each tranche's potential loss severity given
default, as evidenced by the ratio of tranche size to the expected
loss for the collateral under the 'B' stress.  LS ratings should
always be considered in conjunction with probability of default
indicated by a class' long-term credit rating.  Fitch does not
assign Rating Outlooks or LS ratings to classes rated 'CCC' or
lower.

Classes C through G were assigned Recovery Ratings to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.  The Recovery Ratings are
calculated using Fitch's cash flow model, and incorporate Fitch's
current 'B' stress expectation for default and recovery rates
(43.6% and 11.7%, respectively), the 'B' stress US$ LIBOR up
stress, and a 24-month recovery lag to determine the present value
of all future proceeds to that class.  All modeled distributions
are discounted at 10% to arrive at a present value and compared to
the classes' tranche size to determine a Recovery Rating.  The
assignment of 'RR4' to class C reflects modeled recoveries of 35%
of its outstanding balance.  The expected recovery proceeds are
broken down:

  -- Present value of expected principal recoveries
     ($3.3 million);

  -- Present value of expected interest payments ($3.5 million);

  -- Total present value of recoveries ($6.8 million);

  -- Sum of undiscounted recoveries ($12.5 million).

Classes D through G are assigned a Recovery Rating of 'RR6' as the
present value of the recoveries in each case is less than 10% of
the principal balance of the security.

Fitch has downgraded, assigned Loss Severity and Recovery ratings,
and assigned Rating Outlooks as indicated to these classes:

  -- $90,508,896 class A-1 to 'BBB' from 'AAA'; assigned 'LS4';
     Outlook Negative;

  -- $79,398,000 class A-2 to 'BB' from 'AA'; assigned 'LS4';
     Outlook Negative;

  -- $29,167,000 class B to 'B' from 'BBB'; assigned 'LS5';
     Outlook Negative;

  -- $19,444,000 class C to 'CC' from 'B'; assigned 'RR4';

  -- $21,065,000 class D to 'C' from 'B'; assigned 'RR6';

  -- $3,241,000 class E to 'C' from 'B'; assigned 'RR6';

  -- $6,481,000 class F to 'C from 'CCC'; assigned 'RR6';

  -- $16,204,000 class G to 'C' from 'CCC'; assigned 'RR6'.

Additionally, classes A-1 through E are removed from Rating Watch
Negative.


CARBON CAPITAL: S&P Downgrades Ratings on Nine 2005-1 CRE CDOs
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on nine
classes from Carbon Capital II Real Estate CDO 2005-1 Ltd., a
commercial real estate collateralized debt obligation transaction.
Six of the lowered ratings and one additional rating remain on
CreditWatch negative.

The downgrades primarily reflect negative collateral performance.

According to the Oct. 30, 2009, trustee report, there were six
defaulted assets in the pool ($132.8 million, 42.3%).  The
negative CreditWatch placements on Carbon 2005-1 reflect exposure
to an underlying commercial mortgage-backed securities asset with
a rating on CreditWatch negative ($18 million, 5.7%).  The
CreditWatch placements also reflect exposure to loan collateral
that is subordinate to loans in CMBS transactions with ratings on
CreditWatch negative ($9.8 million, 3.1%).

The Oct. 30, 2009, trustee report listed six loans in Carbon 2005-
1 as defaulted and noted three par value test failures.  The
defaulted assets include:

* Hilton Pittsburgh (whole loan, $49.6 million, 15.8%);

* 200 LaFayette (whole loan, $29.8 million, 9.5%);

* East Village (whole loan, $22.75 million, 7.2%);

* San Francisco Multifamily Portfolio (preferred equity
  $15 million, 4.8%);

* Bermuda Dunes (mezzanine loan $9.6 million, 3.1%); and

* Lembi 8 (preferred equity $6 million, 1.9%).

Additionally, the Sept. 30, 2009, trustee report listed the 1330
Avenue of the Americas mezzanine loan and the Macklowe EOP
Manhattan Portfolio mezzanine loan as defaulted assets.  Both
assets had reported market values of zero, but were no longer in
the trust as of the Oct. 30, 2009, trustee report.

Excluding the defaulted assets, the transaction's current asset
pool includes these:

* Twelve mezzanine loans ($127.3 million, 40.6%);
* Two B notes ($21 million, 6.7%);
* One CMBS ($18 million, 5.7%); and
* One whole loan ($14.5 million, 4.6%).

S&P based its analysis of the transaction primarily on information
the collateral manager provided to us, as well as the Oct. 30,
2009, trustee remittance report.

S&P expects to update or resolve the CreditWatch negative
placements on Carbon 2005-1 in conjunction with S&P's resolution
of the CreditWatch placements on the underlying CMBS asset and as
S&P analyzes the credit characteristics of the subordinate loan
collateral in CMBS transactions on CreditWatch negative.

      Ratings Lowered And Remaining on Creditwatch Negative

           Carbon Capital II Real Estate CDO 2005-1 Ltd.

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

      Ratings Lowered And Removed From Creditwatch Negative

           Carbon Capital II Real Estate CDO 2005-1 Ltd.

                           Rating
                           ------
          Class     To                   From
          -----     --                   ----
          H         CCC-                BBB-/Watch Neg
          I         CCC-                BB+/Watch Neg
          J         CCC-                BB-/Watch Neg

             Rating Remaining on Creditwatch Negative

          Carbon Capital II Real Estate CDO 2005-1 Ltd.

                     Class     Rating
                     -----     ------
                     B         AA/Watch Neg


CITIGROUP MORTGAGE: S&P Downgrades Ratings on 11 2007-11 Certs.
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 11
classes of certificates from Citigroup Mortgage Loan Trust 2007-
11, a U.S. residential mortgage-backed securities resecuritized
real estate mortgage investment conduit transaction.  At the same
time, S&P affirmed its 'AAA' rating on class 1-A-4 from the same
transaction.

The downgrades reflect significant deterioration in the
performance of the loans backing the underlying certificates.  The
affirmation reflects the amount of credit support within the re-
REMIC.  Although the performance deterioration is severe, the
credit enhancement within CMLT 2007-11 is sufficient to maintain
the rating on class 1-A-4 because class 1-A-5 provides additional
credit enhancement to class 1-A-4.

CMLT 2007-11, which closed in November 2007, is collateralized by
five underlying classes that support two independent groups within
the re-REMIC.  The loans securing the five underlying classes,
which are included in three different trusts, consist
predominantly of fixed-rate Alternative-A mortgage loans.

Classes I-A-1, I-A-1B, I-A-2, I-A-3, I-A-4, and I-A-5 from CMLT
2007-11 are supported by classes A-7 and A-8 from CitiMortgage
Alternative Loan Trust Series 2006-A2 (both currently rated
'CCC').  The performance of the loans securing this trust has
declined precipitously in recent months.  This pool had
experienced losses of 1.52% of the original pool balance as of the
October 2009 distribution, and currently has approximately 20.80%
of the current balance in delinquent loans.  Based on the losses
to date, the current pool factor of 0.7266 (72.66%), 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 9.41%.

Classes II-A-1, II-A-2, II-A-3, II-A-4, II-A-5, and II-A-6 from
CMLT 2007-11 are supported by classes I-A-3 and II-A-12 from RALI
Series 2007-QS1 Trust (both currently rated 'CCC') and class A-3
from RALI Series 2007-QS5 Trust (currently rated 'CCC').

The performance of the loans securing the RALI Series 2007-QS1
Trust continues to erode beyond reasonable expectations.  The pool
of loans supporting the structure containing class I-A-3 had
experienced losses of 4.03% as of the October 2009 distribution,
and currently has approximately 30.61% in delinquent loans.  Based
on the losses to date, the current pool factor of 0.7402 (74.02%),
and the pipeline of delinquent loans, S&P's current projected loss
for this pool is 16.03%.  The pool of loans supporting the
structure containing class II-A-12 had experienced losses of 5.07%
as of the October 2009 distribution, and currently has
approximately 33.65% in delinquent loans.  Based on the losses to
date, the current pool factor of 0.6723 (67.23%), and the pipeline
of delinquent loans, S&P's current projected loss for this pool is
16.17%.

The performance of the loans securing RALI Series 2007-QS5 Trust
has declined in recent months.  This structure had experienced
losses of 5.35% as of the October 2009 distribution, and currently
has approximately 32.85% in delinquent loans.  Based on the losses
to date, the current pool factor of 0.7519 (75.19%), and the
pipeline of delinquent loans, S&P's current projected loss for
this pool is 22.74%.

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

               Citigroup Mortgage Loan Trust 2007-11

                                           Rating
                                           ------
         Class      CUSIP         To                   From
         -----      -----         --                   ----
         I-A-1      17313RAA4     CCC                  AAA
         I-A-1B     17313RAP1     CCC                  AAA
         I-A-2      17313RAB2     BBB+                 AAA
         I-A-3      17313RAC0     CCC                  AAA
         I-A-5      17313RAE6     CCC                  AAA
         II-A-1     17313RAF3     CC                   AAA
         II-A-2     17313RAG1     CC                   AAA
         II-A-3     17313RAH9     CCC                  AAA
         II-A-4     17313RAJ5     CC                   AAA
         II-A-5     17313RAK2     CCC                  AAA
         II-A-6     17313RAL0     CC                   AAA

                          Rating Affirmed

               Citigroup Mortgage Loan Trust 2007-11

                 Class      CUSIP         Rating
                 -----      -----         ------
                 I-A-4      17313RAD8     AAA


CITIGROUP MORTGAGE: S&P Gives Ratings on 12 2009-2 Securities
-------------------------------------------------------------
Standard & Poor's Ratings Services released its ratings on 12
classes of securities from Citigroup Mortgage Loan Trust 2009-1, a
U.S. residential mortgage-backed securities re-securitized real
estate mortgage investment conduit transaction.

Three of these classes, 1A2, 2A2, and 3A2, are senior classes, and
nine, 1A2A, 1A2B, 1A2C, 2A2A, 2A2B, 2A2C, 3A2A, 3A2B, and 3A2C,
are senior/exchangeable classes.

CMLTI 2009-1, which closed in January 2009, is collateralized by
three underlying classes that support three independent groups
within the re-REMIC.  The loans securing the three underlying
classes, which are included in three different trusts, consist
predominately of adjustable-rate prime jumbo mortgage loans.

Classes 1A2, 1A2A, 1A2B, and 1A2C from CMLTI 2009-1 are supported
by the 1-A1A class from Citigroup Mortgage Loan Trust 2007-AR4.
The performance of the loans securing this trust has declined
precipitously in recent months.  This pool had experienced losses
of 0.52% as of the October 2009 distribution date, and it
currently has approximately 13.28% in delinquent loans as a
percentage of the pool balance.  Based on the losses to date, the
pool factor of 0.6785 (67.85%), 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 5.18%, which exceeds the level of credit enhancement
available to cover losses.

Classes 2A2, 2A2A, 2A2B, and 2A2C from CMLTI 2009-1 are supported
by the 2A1 class from GSR Mortgage Loan Trust 2007-AR2 (currently
rated 'CCC').  The performance of the loans securing this trust
has declined precipitously in recent months.  This pool had
experienced losses of 1.02% as of the October 2009 distribution
date, and it currently has approximately 18.97% in delinquent
loans as a percentage of the pool balance.  Based on the losses to
date, the pool factor of 0.7621 (76.21%), 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.

Classes 3A2, 3A2A, 3A2B, and 3A2C from CMLTI 2009-1 are supported
by the 3-A-1 class from STARM Mortgage Loan Trust 2007-3
(currently rated 'CCC').  The performance of the loans securing
this trust has declined considerably in recent months.  This pool
had experienced losses of 1.35% as of the October 2009
distribution date, and it currently has approximately 15.23% in
delinquent loans as a percentage of the pool balance.  Based on
the losses to date, the pool factor of 0.7880 (78.80%), and the
pipeline of delinquent loans, S&P's current projected loss for
this pool is 8.57%, 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.

                          Ratings Issued

               Citigroup Mortgage Loan Trust 2009-1

                      Class           Rating
                      -----           ------
                      1A2             CCC
                      1A2A            BB-
                      1A2B            BB-
                      1A2C            CCC
                      2A2             CCC
                      2A2A            BBB-
                      2A2B            B
                      2A2C            CCC
                      3A2             CCC
                      3A2A            BBB
                      3A2B            BBB
                      3A2C            CCC


CLOVERIE PLC: Fitch Withdraws Rating on 2006-3 Notes to 'D/RR6'
---------------------------------------------------------------
Fitch Ratings has withdrawn the rating on the class of notes
issued by Cloverie Plc 2006-3.

This rating action is a result of an early termination of the
transaction's underlying credit default and interest rate swaps on
Oct. 15, 2009.  Accordingly, the rating has been withdrawn.  The
notes were previously downgraded to 'D/RR6' as a result of
multiple Credit Events with respect to obligations within the
reference portfolios of Cloverie 2006-3.

Cloverie 20006-3 was a partially funded, static synthetic
collateralized debt obligation that closed in January 2006.  The
transactions represented leveraged exposure to diversified
portfolios of asset-backed securities.  The note proceeds
collateralized credit default swaps with Citigroup Global Markets
Limited as the Swap Counterparty.  A modified 'Pay-As-You-Go'
template was utilized to define the terms of the credit default
swap.

Fitch has withdrawn this rating:

  -- $40,000,000 class D notes rated 'D/RR6'.


COMM 2006-CNL2: S&P Downgrades Ratings on 13 Securities
-------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 13
classes of commercial mortgage-backed securities from COMM 2006-
CNL2.  These ratings and S&P's ratings on five additional classes
from the same transaction remain on CreditWatch with negative
implications.

The rating actions follow S&P's continued analysis of the five
upscale luxury hotel properties that serve as collateral for the
sole mortgage loan in this transaction.  These hotel properties
have, in S&P's opinion, experienced significant operating
performance declines since issuance.  S&P believes that the
decline is primarily due to a reduction in business-group and
leisure travel coupled with increased operating expenses.  The
downgrades reflect a significant decline in revenue per available
room (RevPAR) and increased operating expenses from S&P's
expectations at issuance.  S&P's preliminary valuation has
declined 32% since issuance, resulting in a stressed loan-to-value
ratio of 101%.  The preliminary valuation, in part, utilized the
borrowers' year-to-date 2009 (through Aug. 31), and full-year 2008
operating statements provided by the master servicer, Midland Loan
Services Inc. (Midland).

All of the 18 outstanding ratings in this transaction remain on
CreditWatch with negative implications pending S&P's further
evaluation of the loan, which was transferred to the special
servicer, also Midland, on Oct. 21, 2009, due to imminent default
after the borrower submitted a loan modification proposal.
Midland is currently exploring various workout strategies with the
borrower and has ordered updated appraisals.  S&P expects to
resolve the CreditWatch placements and may revise its ratings upon
receipt of updated financial data and further dialogue with the
special servicer.

S&P based its analysis, in part, on a review of the borrower's
operating statements for the 12 months ended Dec. 31, 2008, and
its 2009 budgets, as well as available Smith Travel Research (STR)
reports.  S&P's analysis also considered the borrower's reported
20% decline in the portfolio's RevPAR for the 12 months ended
Aug. 31, 2009, compared with the levels S&P assessed at issuance.
According to STR, the luxury segment of the hotel industry posted
a significant 27% decline in RevPAR in the first nine months of
2009 compared with the same period in 2008, whereas the general
U.S. hotel industry reported an 18% decline in RevPAR for the same
period.

As of the Nov. 5, 2009, trustee remittance report, the mortgage
loan has a trust and whole-loan balance of $1.0 billion that is
secured by five upscale luxury resort hotels totaling 3,287 rooms
in Hawaii, California, Florida, and Arizona.  The interest-only
loan has a 5.5699% fixed interest rate and a final maturity of
Feb. 1, 2011.  In addition, the equity interests in the borrower
secure four floating-rate mezzanine loans totaling $525.0 million.

Details of the five collateral properties securing this loan are:

The Grand Wailea Resort Hotel and Spa is a 780-room, full-service
luxury resort hotel on 37 acres in Maui, Hawaii.  Amenities
include six restaurants, 80,600 sq. ft. of meeting space, and a
50,000-sq.-ft. spa.  The borrower's reported year-end 2008 net
cash flow (NCF) was 16% below the levels S&P assessed at issuance,
due primarily to an increase in operating expenses.

The La Quinta Resort & Club and PGA West is a 796-room, full-
service luxury resort and golf community on 2,180 acres, which
includes nine 18-hole golf courses, several restaurants, a retail
center, 47,850 sq. ft. of meeting space, and a 23,000-sq.-ft. spa
in La Quinta, Calif.  The year-end 2008 NCF for this asset has
fallen 86% since issuance, due primarily to a 21% drop in RevPAR
and increased operating expenses.

The Arizona Biltmore Resort & Spa is a 739-room, full-service
luxury conference resort destination on 30 acres in Phoenix, Ariz.
Amenities include a 92-foot water slide, 93,200 sq. ft. of
conference space, and a 22,000-sq.-ft. spa.  The borrower's
reported year-end 2008 NCF is comparable to the levels S&P
assessed at issuance.

The Doral Golf Resort & Spa is a 693-room, full-service luxury
hotel in Doral, Fla.  Amenities include 15,000 sq. ft. of retail
space, 67,350 sq. ft. of conference space, five 18-hole golf
courses, five restaurants, and 50,000 sq. ft. of fitness and spa
facilities.  The borrower's reported year-end 2008 NCF has dropped
39% since issuance, due primarily to an increase in operating
expenses.

The Claremont Resort & Spa is a 279-room, full-service luxury
resort, with amenities that include 27,000 sq. ft. of meeting
space, three restaurants, and a 20,000-sq.-ft. spa on 20 acres in
Berkeley Hills, Calif.  The borrower's reported year-end 2008 NCF
has declined 37% since issuance, due primarily to an increase in
operating expenses.

      Ratings Lowered And Remaining On Creditwatch Negative

                         COMM 2006-CNL2
             Commercial mortgage-backed certificates
                            Rating
                            ------
          Class     To                  From
          -----     --                  ----
          A-JFX     AA-/Watch Neg       AAA/Watch Neg
          A-JFL     AA-/Watch Neg       AAA/Watch Neg
          BFX       A-/Watch Neg        AA+/Watch Neg
          BFL       A-/Watch Neg        AA+/Watch Neg
          CFX       BBB+/Watch Neg      AA/Watch Neg
          CFL       BBB+/Watch Neg      AA/Watch Neg
          D         BBB/Watch Neg       AA-/Watch Neg
          E         BBB-/Watch Neg      A+/Watch Neg
          F         BB+/Watch Neg       A/Watch Neg
          G         BB/Watch Neg        A-/Watch Neg
          H         BB-/Watch Neg       BBB+/Watch Neg
          J         B+/Watch Neg        BBB/Watch Neg
          K         CCC-/Watch Neg      BBB-/Watch Neg

            Ratings Remaining On Creditwatch Negative

                         COMM 2006-CNL2
             Commercial mortgage-backed certificates

                     Class    Rating
                     -----    ------
                     A-1      AAA/Watch Neg
                     A-2FX    AAA/Watch Neg
                     A-2FL    AAA/Watch Neg
                     X-1      AAA/Watch Neg
                     X-2      AAA/Watch Neg


CORPORATE BACKED: Moody's Upgrades Ratings on Class A-1 Certs.
--------------------------------------------------------------
Moody's Investors Service announced that it has upgraded these
certificates issued by Corporate Backed Trust Certificates, Ford
Motor Company Note-Backed Series 2003-6 Trust:

  -- 1,000,000 Class A-1 Certificates due July 15, 2031; Upgraded
     to Caa1; Previously on September 18, 2009 Upgraded to Caa2.

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction.  The rating action is a result of the change of the
rating of 7.45% GlobLS due July 16, 2031 issued by Ford Motor
Company which were upgraded to Caa1 by Moody's on November 2,
2009.


CORPORATE BACKED: Moody's Upgrades Ratings on 2001-36 Certs.
------------------------------------------------------------
Moody's Investors Service announced that it has upgraded these
certificates issued by Corporate Backed Trust Certificates, Ford
Motor Co. Debenture-Backed Series 2001-36 Trust:

  -- 2,340,040 Corporate Backed Trust Certificates, Ford Motor Co.
     Debenture-Backed Series 2001-36, Class A-1; Upgraded to Caa1;
     Previously on September 18, 2009 Upgraded to Caa2.

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction.  The rating action is a result of the change of the
rating of 7.70% Debentures due May 15, 2097 issued by Ford Motor
Company which were upgraded to Caa1 by Moody's on November 2,
2009.


CORPORATE BACKED: S&P Raises Rating on 2001-36 Certs. to 'CCC'
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on Corporate
Backed Trust Certificates Ford Motor Co. Debenture-Backed Series
2001-36 Trust's $58.501 million class A1 certificates to 'CCC'
from 'CCC-'.

The rating on the certificates is dependent solely on the rating
on the underlying security, Ford Motor Co.'s 7.7% debentures due
May 15, 2097 ('CCC').

The rating action reflects S&P's Nov. 3, 2009, upgrade of the
underlying security to 'CCC' from 'CCC-'.


CORPORATE BACKED: S&P Raises Rating on $25 Mil. Certs. to 'CCC'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on Corporate
Backed Trust Certificates Ford Motor Co. Note-Backed Series 2003-6
Trust's $25 million 8% class A1 certificates to 'CCC' from 'CCC-'.

The rating on the certificates is dependent solely on the rating
on the underlying security, Ford Motor Co.'s 7.45% global landmark
securities due July 16, 2031 ('CCC').

The rating action reflects S&P's Nov. 3, 2009, upgrade of the
underlying security to 'CCC' from 'CCC-'.


CORTS TRUST: S&P Raises Rating on $219.584 Mil. Certs. to 'CCC'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on CorTS
Trust II For Ford Notes' $219.584 million pass-through
certificates series 2003-3 to 'CCC' from 'CCC-'.

The rating on the certificates is dependent solely on the rating
on the underlying security, Ford Motor Co.'s 7.45% global landmark
securities due July 16, 2031 ('CCC').

The rating action reflects S&P's Nov. 3, 2009, upgrade of the
underlying security to 'CCC' from 'CCC-'.


CORTS TRUST: Moody's Raises Ratings on Certificates to 'Caa1'
-------------------------------------------------------------
Moody's Investors Service announced that it has upgraded these
certificates issued by CorTS Trust for Ford Debentures:

  -- 12,000,000 7.40% Corporate-Backed Trust Securities
     Certificates; Upgraded to Caa1; Previously on September 18,
     2009 Upgraded to Caa2.

The transaction is a structured note whose rating is based on the
rating of the Underlying Debentures and the legal structure of the
transaction.  The rating action is a result of the change of the
rating of 7.40% Debentures due November 1, 2046, issued by Ford
Motor Company which were upgraded to Caa1 by Moody's on
November 2, 2009.


CORTS TRUST: Moody's Upgrades Ratings on Certificates to 'Caa1'
---------------------------------------------------------------
Moody's Investors Service announced that it has upgraded these
certificates issued by CorTS Trust II for Ford Notes:

  -- 8,783,363 8.00% Corporate-Backed Trust Securities
     Certificates; Upgraded to Caa1; Previously on September 18,
     2009 Upgraded to Caa2.

The transaction is a structured note whose rating is based on the
rating of the Underlying Notes and the legal structure of the
transaction.  The rating action is a result of the change of the
rating of 7.45% Global Landmark Securities due July 16, 2031,
issued by Ford Motor Company which were upgraded to Caa1 by
Moody's on November 2, 2009.


CORTS TRUST: S&P Raises Rating on $300 Mil. Certs. to 'CCC'
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on CorTS
Trust For Ford Debentures' $300 million certificates to 'CCC' from
'CCC-'.

The rating on the certificates is dependent solely on the rating
on the underlying security, Ford Motor Co.'s 7.4% debentures due
Nov. 1, 2046 ('CCC').

The rating action reflects S&P's Nov. 3, 2009, upgrade of the
underlying security to 'CCC' from 'CCC-'.


CREDIT SUISSE: S&P Downgrades Ratings on Five 2001-SPG1 Securities
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
classes from Credit Suisse First Boston Mortgage Securities
Corp.'s series 2001-SPG1 and removed them from CreditWatch with
negative implications.  In addition, S&P affirmed its ratings on
four other classes from the same transaction.

The downgrades reflect S&P's stressed valuation of the four
underlying properties that collateralize this transaction, which
S&P based on a review of the borrower's operating statements for
the first six months of 2009 and the 12 months ended Dec. 31,
2008, the borrower's budgets, and the Sept. 30, 2009, rent roll.
Based on discussions with the loan sponsor, Standard & Poor's
analysis also considered impending lease rollovers and the
sponsor's expectation for expense reductions due to its active
expense management program.

S&P affirmed its rating on the class A-X interest-only certificate
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 finalize its criteria review, S&P may revise its IO
criteria, which may affect outstanding ratings, including the
rating on the IO certificate that S&P affirmed.

The master and special servicer for the transaction is Capmark
Finance Inc., which provided financial and other loan performance
data that S&P used in its review.  Capmark Financial Group Inc.,
the master servicer's parent, filed for Chapter 11 bankruptcy
protection on Oct. 25, 2009.  Capmark remains on S&P's Select
Servicer List, as S&P discussed in "Capmark Servicer Rankings
Remain On CreditWatch Negative After Parent's Bankruptcy Filing,"
published Oct. 26, 2009.  If S&P remove Capmark from the Select
Servicer List at some point in the future and it is not replaced
in the transaction with an approved master servicer, it could
result in a downgrade, qualification, or withdrawal of the ratings
on this transaction.  It is also possible that fees and expenses
associated with the bankruptcy filing could affect the trust and
prompt future rating actions.

The collateral for the transaction is a single mortgage loan
secured by first mortgage liens on four regional malls in four
states.  The mortgage liens are cross-defaulted and cross-
collateralized.  Several of the properties are experiencing weak
occupancy, and overall debt service coverage is 1.33x based on
servicer-reported cash flows.

Details of the four malls securing the loan are:

The Ingram Park Mall in San Antonio, Texas, has an allocated loan
amount of $76.1 million.  The property's current in-line occupancy
is 91%.  There are five anchors, none of which serve as loan
collateral.  Standard & Poor's stressed loan-to-value for this
asset is 47%.  The latest available reported sales were $408 per
sq. ft. for in-line tenants, and the property's DSC is 2.02x based
on reported cash flow.

Knoxville Center in Knoxville, Tenn., has an allocated loan amount
of $57.8 million.  The property's current in-line occupancy is
64%.  There are four anchors, one of which (formerly Dillard's) is
vacant.  Another anchor, JCPenney, serves as loan collateral.
JCPenney has recently extended its lease and received a partial
rent abatement.  Standard & Poor's stressed LTV for this asset is
127%.  The latest available reported sales were $252 per sq. ft.
for in-line tenants, and the property's DSC is 0.93x based on
reported cash flow.

The Northlake Mall in Atlanta has an allocated loan amount of
$66.6 million.  The property's current in-line occupancy is 72%.
There are four anchors, and two, JCPenney and Kohl's, serve as
loan collateral.  JCPenney has recently extended its lease and
received a partial rent abatement.  Standard & Poor's stressed LTV
for this asset is 125%.  The latest available reported sales were
$200 per sq. ft. for in-line tenants, and the property's DSC is
0.96x based on reported cash flow.

Towne West Square in Wichita, Kan., has an allocated loan amount
of $49.8 million.  The property's current in-line occupancy is
71%.  There are four anchors, and one, Sears, serves as loan
collateral.  Standard & Poor's stressed LTV for this asset is 85%.
The latest available reported sales were $327 per sq. ft. for in-
line tenants, and the property's DSC is 1.21x based on reported
cash flow.

Standard & Poor's adjusted the net operating income for each of
the properties for management fees, leasing commissions, tenant
improvements, and capital expenditures to arrive at a stressed net
cash flow of $27.4 million.  Using a blended capitalization rate
of 8.6%, S&P estimate an overall LTV ratio of 78%.  The DSC is
1.18x, based on a refinance constant of 9.25%.

                       Transaction Structure

Credit Suisse First Boston Mortgage Securities Corp.'s commercial
mortgage pass-through certificates series 2001-SPG1 currently has
a $250.0 million trust principal balance and consists of nine
classes of securities representing direct obligations of the
mortgagors.  The mortgagors are bankruptcy-remote entities that
own the four malls that serve as collateral.  Each of the
mortgagors is an affiliate of the sponsor, Simon Property Group
('A-').  The transaction has a sequential-pay structure.  The loan
pays interest and principal fixed at 6.99% for 10 years based on a
30-year amortization term.  The loan matures on Aug. 11, 2011, and
has a rated final distribution date of Aug. 15, 2018.  There is a
hard lockbox in place that requires all tenants to pay rents and
other revenues to an account that the servicer/trustee controls.

       Ratings Lowered And Removed From Creditwatch Negative

       Credit Suisse First Boston Mortgage Securities Corp.
  Commercial mortgage pass-through certificates series 2001-SPG1

                              Rating
                              ------
           Class    To                    From
           -----    --                    ----
           C        A                     AA-/Watch Neg
           D        BBB+                  A+/Watch Neg
           E        BBB-                  BBB+/Watch Neg
           F        BB+                   BBB/Watch Neg
           G        BB                    BBB-/Watch Neg

       Rating Affirmed And Removed From Creditwatch Negative

       Credit Suisse First Boston Mortgage Securities Corp.
  Commercial mortgage pass-through certificates series 2001-SPG1

                              Rating
                              ------
           Class    To                    From
           -----    --                    ----
           B         AAA                  AAA/Watch Neg

                         Ratings Affirmed

        Credit Suisse First Boston Mortgage Securities Corp.
   Commercial mortgage pass-through certificates series 2001-SPG1

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


CREDIT SUISSE: S&P Downgrades Rating on 2005-TFL2 Certificates
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
L commercial mortgage pass-through certificates from Credit Suisse
First Boston Mortgage Securities Corp.'s series 2005-TFL2 and
removed it from CreditWatch with negative implications.
Concurrently, S&P affirmed its ratings on three classes and
removed two of them from CreditWatch negative.

The rating actions follow S&P's continued analysis of the
properties that serve as collateral for the remaining loan in the
pool, the Castleton Office Park Portfolio loan.  The downgrade
reflects declining occupancy and base rental revenue, which caused
an increase in S&P's stress loan-to-value ratio.  The loan's final
maturity date is July 9, 2010.  S&P also considered the related
refinance risk in S&P's analysis.

S&P based the affirmation of its 'A+' rating on class J on its
analysis of the remaining loan and the subordination levels, which
S&P believes are consistent with the rating.  S&P inadvertently
set the 'A+' rating on the class J certificates to 'NR' (not
rated) on Jan. 9, 2008, due to an administrative error, but S&P
reinstated the rating on Nov. 3, 2009.

S&P affirmed its rating on the class A-X-1 interest-only
certificate 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 finalize its criteria review, S&P may
revise its IO criteria, which may affect outstanding ratings,
including the rating on the IO certificate that S&P affirmed.

As of the Oct. 15, 2009, trustee remittance report, the remaining
loan in the trust, the Castleton Office Park Portfolio loan, had a
$49.8 million whole-loan balance, which is divided into a
$36.3 million in-trust senior participation interest and a
$13.5 million nontrust subordinate B participation interest.  In
addition, the equity interests in the borrower of the whole loan
secure $7.2 million of mezzanine debt.  Since issuance, the
borrower released three office properties totaling 128,500 sq. ft.
as collateral for the loan.  The remaining collateral securing the
Castleton Office Park Portfolio loan consists of 32 suburban
office properties totaling 938,200 sq. ft. in Castleton, Ind.

S&P based its analysis for the remaining collateral properties, in
part, on a review of the borrower's operating statements for the
trailing-12-months (TTM) ended Sept. 30, 2009, as well as the
borrower's 2009 budgets.  The properties' reported net operating
income for the TTM ended Sept. 30, 2009, has declined 11% from its
levels at year-end 2008.  The decline is due primarily to lower
base rental revenues and occupancy; occupancy was 71% as of
Oct. 1, 2009, down from 76% at year-end 2008.  S&P's analysis,
which factored in these declines, resulted in a stress LTV ratio
of 87% on the trust balance.  The master servicer, Wachovia Bank
N.A., reported debt service coverage of 3.29x on the trust balance
for the 12 months ended Dec. 31, 2008.  The loan has a final
maturity date of July 9, 2010.  According to Wachovia, the
borrower has not started searching for a refinance lender yet.

       Rating Lowered And Removed From Creditwatch Negative

        Credit Suisse First Boston Mortgage Securities Corp.
  Commercial mortgage pass-through certificates series 2005-TFL2

                              Rating
                              ------
                Class       To       From
                -----       --       ----
                L           B        BBB/Watch Neg

      Ratings Affirmed And Removed From Creditwatch Negative

       Credit Suisse First Boston Mortgage Securities Corp.
  Commercial mortgage pass-through certificates series 2005-TFL2

                              Rating
                              ------
                Class       To       From
                -----       --       ----
                K           BBB+     BBB+/Watch Neg
                A-X-1       AAA      AAA/Watch Neg

                          Rating Affirmed

       Credit Suisse First Boston Mortgage Securities Corp.
  Commercial mortgage pass-through certificates series 2005-TFL2

                        Class       Rating
                        -----       ------
                        J           A+


DEUTSCHE MORTGAGE: S&P Downgrades Ratings on 38 2006-PR1 Certs.
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 38
classes of residential mortgage-backed certificates issued by
Deutsche Mortgage Securities Inc. Mortgage Loan Trust Series 2006-
PR1.  S&P removed 23 of the lowered ratings from CreditWatch with
negative implications.  In addition, S&P affirmed its ratings on
four classes from the affected transaction.

Standard & Poor's has established loss projections for each
Alternative-A transaction it rated in 2006.  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 losses have changed for this
particular transaction:

                                  Orig. bal.        Lifetime
  Transaction                     (mil. $)          exp. loss (%)
  -----------                     ----------        -------------
Deutsche Mtg Loan Trust 2006-PR1      1,771            4.39

The downgrades reflect S&P's opinion that projected credit support
for the affected classes is insufficient to maintain the previous
ratings, given its 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 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 due to the fact that 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, the senior class 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 this particular
transaction.  The underlying pool of loans backing this
transaction consists of fixed-rate, Alternative-A mortgage loans
that are secured by first liens on one- to four-family residential
properties in Puerto Rico.

                           Rating Actions

       Deutsche Mortgage Securities Inc. Mortgage Loan Trust
                       Series      2006-PR1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A-1      25157GAA0     BBB                  AAA/Watch Neg
    A-X        25157GAB8     BBB                  AAA
    2-A-F      25157GAC6     BBB                  AAA/Watch Neg
    2-A-S      25157GAD4     BBB                  AAA
    2-PO       25157GAE2     BBB                  AAA/Watch Neg
    3-A-1      25157GAH5     BBB                  AAA/Watch Neg
    3-A-S      25157GAJ1     BBB                  AAA
    3-PO       25157GAN2     BBB                  AAA/Watch Neg
    4-A-F-2    25157GAQ5     BBB                  AAA/Watch Neg
    4-A-I-1    25157GAR3     BBB                  AAA/Watch Neg
    4-A-I-2    25157GAS1     BBB                  AAA/Watch Neg
    4-A-S-1    25157GAT9     BBB                  AAA
    4-A-S-2    25157GAW2     BBB                  AAA
    4-PO       25157GAZ5     BBB                  AAA/Watch Neg
    5-A-F-1    25157GBA9     BBB                  AAA/Watch Neg
    5-A-F-3    25157GBC5     BBB                  AAA/Watch Neg
    5-A-F-4    25157GBD3     BBB                  AAA/Watch Neg
    5-A-I-1    25157GBE1     BBB                  AAA/Watch Neg
    5-A-I-2    25157GBF8     BBB                  AAA/Watch Neg
    5-A-I-3    25157GBG6     BBB                  AAA/Watch Neg
    5-A-I-4    25157GBH4     BBB                  AAA/Watch Neg
    5-A-S-1    25157GBJ0     BBB                  AAA
    5-A-S-2    25157GBS0     BBB                  AAA
    5-A-S-3    25157GCA8     BBB                  AAA
    5-A-S-4    25157GCJ9     BBB                  AAA
    5-PO       25157GCS9     BBB                  AAA/Watch Neg
    BX         25157GDP4     CCC                  AA
    B-1A       25157GCU4     CCC                  AA/Watch Neg
    B-1B       25157GCV2     CCC                  AA/Watch Neg
    B-2        25157GCY6     CCC                  BBB/Watch Neg
    B-3        25157GDA7     CC                   BB/Watch Neg
    B-4        25157GDC3     CC                   B/Watch Neg
    B-5        25157GDE9     CC                   B-/Watch Neg
    B-6        25157GDG4     CC                   CCC
    B-7        25157GDJ8     CC                   CCC
    B-8        25157GDL3     CC                   CCC
    B-9        25157GDM1     CC                   CCC
    CW-A1      25157GCT7     BBB                  AAA

                          Ratings Affirmed

       Deutsche Mortgage Securities Inc. Mortgage Loan Trust
                       Series      2006-PR1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 3-A-F-1-C  25157GAF9     AAA
                 3-A-F-2    25157GAG7     AAA
                 4-A-F-1-C  25157GAP7     AAA
                 5-A-F-2    25157GBB7     AAA


DEUTSCHE ALT-A: S&P Downgrades Ratings on Three 2007-RS1 Certs.
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on all
three classes of certificates from Deutsche Alt-A Securities Inc.
Re-REMIC Trust Certificates Series 2007-RS1, a U.S. residential
mortgage-backed securities resecuritized real estate mortgage
investment conduit transaction.  At the same time, S&P removed two
of the lowered ratings from CreditWatch with negative
implications.  S&P lowered its ratings on classes A-1, A-2, and A-
3 to 'CCC' from 'AAA.'

The downgrades reflect significant deterioration in the
performance of the loans backing the underlying certificates.
This performance deterioration is so severe that the credit
enhancement for DBALT 2007-RS1 is insufficient to maintain the
previous ratings on the re-REMIC classes.  Additionally, classes
A-1 and A-2 are backed by a financial guaranty policy from Ambac
Assurance Corp. (CC/Developing/-- financial strength rating).
However, the standalone ratings on the A-1 and A-2 classes of
certificates are higher than the rating on Ambac.

DBALT 2007-RS1, which closed in August 2007, is collateralized by
nine underlying classes that support the re-REMIC.  The loans
securing the nine underlying classes, which were issued from five
different trusts, consist predominantly of fixed-rate Alternative-
A (Alt-A) mortgage loans.

Classes A-1, A-2, and A-3 from DBALT 2007-RS1 are supported by
classes A-22 (currently rated 'B-') and A-8 (currently rated
'CCC') from Alternative Loan Trust 2006-19CB; the A-1 class
(currently rated 'CCC') from Alternative Loan Trust 2006-25CB; the
A-15 class (currently rated 'CC') from Alternative Loan Trust
2006-31CB; the 1-A-1 and 1-A-10 classes (currently rated 'CCC')
from Alternative Loan Trust 2006-39CB; and the 1-A-5, 1-A-8, and
2-A-11 classes (currently rated 'CCC') from Alternative Loan Trust
2006-6CB.

The performance of the loans securing the A-22 and A-8
certificates from Alternative Loan Trust 2006-19CB has declined
precipitously in recent months.  This pool had experienced losses
amounting to 1.05% of the original pool balance as of the October
2009 distribution, and delinquent loans amount to approximately
22.59% of the current pool balance.  Based on the losses to date,
the current pool factor of 0.6434 (64.34%), 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 6.58%, which exceeds the level of credit
enhancement available to cover losses.

The performance of the loans securing the A-1 certificate from
Alternative Loan Trust 2006-25CB has declined considerably in
recent months.  This pool had experienced losses of 0.86% as of
the October 2009 distribution, and currently has approximately
24.25% in delinquent loans.  Based on the losses to date, the
current pool factor of 0.6411 (64.11%), and the pipeline of
delinquent loans, S&P's current projected loss for this pool is
8.20%, which exceeds the level of credit enhancement available to
cover losses.

The performance of the loans securing the A-15 certificate from
Alternative Loan Trust 2006-31CB has declined significantly in
recent months.

This pool had experienced losses of 1.67% as of the October 2009
distribution, and currently has approximately 25.45% in delinquent
loans.  Based on the losses to date, the current pool factor of
0.6480 (64.80%), and the pipeline of delinquent loans, S&P's
current projected loss for this pool is 8.51%, which exceeds the
level of credit enhancement available to cover losses.

The performance of the loans securing the 1-A-1 and 1-A-10
certificates from Alternative Loan Trust 2006-39CB has also
declined precipitously in recent months.  This pool had
experienced losses of 2.38% as of the October 2009 distribution,
and currently has approximately 33.25% in delinquent loans.  Based
on the losses to date, the current pool factor of 0.6983 (69.83%),
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.

The performance of the loans securing the 1-A-5, 1-A-8, and 2-A-11
certificates from Alternative Loan Trust 2006-6CB has declined
rapidly in recent months.  This pool had experienced losses of
1.41% as of the October 2009 distribution, and currently has
approximately 23.77% in delinquent loans.  Based on the losses to
date, the current pool factor of 0.6650 (66.50), and the pipeline
of delinquent loans, S&P's current projected loss for this pool is
8.63%, 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.

                           Rating Actions

    Deutsche Alt-A Securities Inc. Re-REMIC Trust Certificates
                          Series 2007-RS1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1        25152DAA2     CCC                  AAA/Watch Neg
    A-2        25152DAB0     CCC                  AAA/Watch Neg
    A-3        25152DAD6     CCC                  AAA


FALL CREEK: Fitch Downgrades Ratings on Three Classes of Notes
--------------------------------------------------------------
Fitch Ratings affirms seven and downgrades three classes of notes
issued by Fall Creek CLO LTD.

This review was conducted under the framework described in the
report 'Global Structured Finance Rating Criteria'.  Cash flow and
portfolio default modeling was conducted in accordance with
Fitch's 'Global Criteria for Cash Flow Analysis in Corporate CDOs'
and 'Global Rating Criteria for Corporate CDOs'.

The affirmation of the class A-2 notes is attributed to the
paydown of the notes from portfolio amortization and asset sales.
As a result, credit enhancement has improved which offsets the
weakening portfolio credit profile noted since the last review.
The downgrade of the class B notes is due to the lower credit
enhancement available to these notes as the result of losses from
asset sales and lower than expected recoveries on defaulted
assets.  Portfolio losses currently exceed the available credit
enhancement to the class C, D-1and D-2 notes.  These notes are
also deferring their interest payments.  As such, Fitch believes
payment default is inevitable for the class C, D-1 and D-2 notes.

Since Fitch's last review in December 2008, amortization and asset
sales have reduced the size of the Fall Creek portfolio by
approximately $87 million.  Approximately $7.9 million of losses
were realized from the sale of performing and defaulted assets,
thus reducing par coverage for the rated notes.  Additionally,
credit deterioration since the last rating review has increased
the overall credit risk of the portfolio.  Approximately 31% of
the portfolio is considered 'CCC+' or lower, compared to 16% at
the last rating review.  Assets that are currently on Rating Watch
Negative or Negative Rating Outlook by at least one rating agency
represent 1% and 22% of the total portfolio, respectively.
Finally, exposure to defaulted assets is currently 5.7% compared
to 4.4% at the last rating review.

The class A-2 note interest component is sizeable relative to the
weighted average spread of the underlying portfolio.  As a result,
there are insufficient interest proceeds to pay the interest due
to the class B notes and on the two most recent payment dates,
principal proceeds were used to make interest payments to the
class B notes prior to redeeming class A-2 principal.  Applying
principal proceeds to offset interest shortfalls reduces the
principal available to the rated notes and lowers their overall
asset coverage.

In its review, Fitch analyzed the structure's sensitivity to
ongoing softness in U.S. corporate recoveries.  To accomplish
this, Fitch reduces its average recovery rate assumptions for each
asset type by 30% in one sensitivity scenario and by 50% in a
second sensitivity scenario where explicit Recovery Ratings were
not available.  The class A-2, and B notes displayed considerable
sensitivity to lower recovery rates and, as such, the class A-2
notes have been assigned a Negative Outlook.  In addition, Fitch
noted the structure's high sensitivity to the amortization profile
of the underlying assets, which also contributed to the Negative
Outlook for the class A-2 notes.  Fitch does not assign Outlooks
to notes that are rated in distressed rating categories, rated
'CCC' or below.

The class A-2 notes were assigned a Loss Severity rating.  The LS
ratings indicate each 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 Fitch's
'Criteria for Structured Finance Loss Severity Ratings' report.
The LS rating should always be considered in conjunction with the
probability of default indicated by a class' long-term credit
rating.  Fitch does not assign LS ratings to tranches rated in the
'CCC' to 'C' categories.

Fall Creek is a collateralized loan obligation that closed on
Sept. 8, 2005, and was amended and restructured on Nov. 24, 2008.
The portfolio is comprised of leveraged loans and is monitored by
40|86 Advisors, Inc. The Indenture for the transaction was amended
and restated to remove the market value-based Threshold Value
Event trigger, effectively converting Fall Creek into a static
cash flow CLO structure from the original market value CLO
structure.

Fitch affirms, assigns Loss Severity ratings, and revises Outlooks
on these classes of Fall Creek CLO LTD. (all due Sept. 10, 2017)
as specified below:

  -- $250,831,246 class A-2 term notes at 'BB/LS2'; Outlook
     revised to Negative from Stable;

  -- $2,000,000 class D-1 notes at 'C';

  -- $3,160,000 class D-1A notes at 'C';

  -- $1,697,000 class D-1B notes at 'C';

  -- $2,092,000 class D-1C notes at 'C';

  -- $8,319,000 class D-1D notes at 'C';

  -- $5,167,000 class D-2 notes at 'C'.

Fitch downgrades these classes of Fall Creek CLO LTD. (all due
Sept. 10, 2017):

  -- $29,170,000 class B notes to 'CCC' from 'B';
  -- $47,000,000 class C notes to 'C' from 'CC';
  -- $9,732,000 class C-1 notes to 'C' from 'CC'.


FOLEY SQUARE: Moody's Reviews Ratings on Various 2007-1 Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has downgraded and
placed under review for possible downgrade the rating of these
notes issued by Foley Square CDO 2007-1 Ltd., a collateralized
debt obligation transaction referencing a static portfolio of
primarily non-investment grade corporate bonds:

  -- US$14,000,000 Class B Floating Rate Senior Notes Due 2014,
     Downgraded to Caa3 and Placed Under Review for Possible
     Downgrade; previously on April 29, 2009 Downgraded to B3.

In addition, Moody's also placed under review for possible
downgrade the rating of these Credit Default Swap:

  -- US$359,000,000 Class A Credit Default Swap (Current
     Outstanding Amount of $350,810,316), Baa3 Placed Under Review
     for Possible Downgrade; previously on March 27, 2009
     Downgraded to Baa3.

According to Moody's, the rating action taken on the Class B Notes
reflects additional credit deterioration in the reference
portfolio as well as the downgrade of Ambac after the last rating
actions taken in April.  On July 29, 2009, the insurance financial
strength rating of Ambac Assurance Corporation, which acts as
Guarantor under the Investment Agreement in the transaction, was
downgraded from Ba3 to Caa2.  In addition, since the last rating
action on the transaction in April 2009, the subordination of the
rated tranches has been further reduced due to credit events on
Abitibi-Consolidated Inc., Chemtura Corporation and R.H.  Donnelly
Corporation.  These credit events lead to a decrease of
approximately 3% of the subordination of the tranches.  Based on
the latest trustee report dated September 21, 2009, the Class D
overcollateralization ratio was reported at 108.71% versus a test
level of 109.7%, and the Class E overcollateralization ratio was
reported at 103.01% versus a test level of 105.9%.  In addition,
interest payments on the Class E Notes are presently being
deferred as a result of the failure of the Class D
Overcollateralization Ratio Test.  Moody's is conducting more
detailed rating analysis on the impact of such deteriorations and
will resolve the negative watch actions soon.


GREENWICH CAPITAL: S&P Downgrades Ratings on 15 2007-RR2 Certs.
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 15
classes from Greenwich Capital Commercial Mortgage Trust 2007-RR2.
These ratings and S&P's ratings on five additional classes from
the same transaction remain on CreditWatch with negative
implications.

The rating actions reflect S&P's analysis of the transaction
following its rating actions on the underlying commercial
mortgage-backed securities collateral for GCCMT 2007-RR2.  The
securities are from 16 transactions and total $280 million (53% of
the total asset balance).  The downgrades reflect the
transaction's exposure to underlying CMBS collateral that has
experienced negative rating actions, and the ratings on GCCMT
2007-RR2 remain on CreditWatch negative due to the transaction's
exposure to CMBS collateral with ratings on CreditWatch negative
($103.8 million, 19.6%).

According to the Oct. 22, 2009, trustee report, GCCMT 2007-RR2 is
collateralized by 63 CMBS classes ($528.7 million, 100%) from 29
distinct transactions issued between 2005 and 2007.  GCCMT 2007-
RR2 has significant exposure to these CMBS transactions that
Standard & Poor's has recently downgraded:

* J.P. Morgan Chase Commercial Mortgage Securities Trust 2006-LDP9
  (class F, G, and H; $38.9 million, 7.4%);

* J.P. Morgan Chase Commercial Mortgage Securities Trust 2007-
  CIBC18 (class D, E, G, and H; $30 million, 5.7%);

* ML-CFC Commercial Mortgage Trust 2007-5 (class F, G, and H;
  $30 million, 5.7%); and

* Wachovia Bank Commercial Mortgage Trust's series 2007-C30 (class
  H, J, and K; $30 million, 5.7%).

S&P will update or resolve the CreditWatch negative placements on
GCCMT 2007-RR2 in conjunction with S&P's CreditWatch resolutions
of the underlying CMBS assets.

      Ratings Lowered And Remaining On Creditwatch Negative

       Greenwich Capital Commercial Mortgage Trust 2007-RR2

                                 Rating
                                 ------
         Class            To               From
         -----            --               ----
         A1FX             A-/Watch Neg     AA/Watch Neg
         A1FL             A-/Watch Neg     AA/Watch Neg
         A2               BB+/Watch Neg    A-/Watch Neg
         A3               B+/Watch Neg     BBB-/Watch Neg
         B                B/Watch Neg      BB+/Watch Neg
         C                B-/Watch Neg     BB+/Watch Neg
         D                CCC+/Watch Neg   BB+/Watch Neg
         E                CCC/Watch Neg    BB/Watch Neg
         F                CCC-/Watch Neg   BB/Watch Neg
         G                CCC-/Watch Neg   B+/Watch Neg
         H                CCC-/Watch Neg   B/Watch Neg
         J                CCC-/Watch Neg   B-/Watch Neg
         K                CCC-/Watch Neg   CCC+/Watch Neg
         L                CCC-/Watch Neg   CCC/Watch Neg
         M                CCC-/Watch Neg   CCC/Watch Neg

             Ratings Remaining On Creditwatch Negative

       Greenwich Capital Commercial Mortgage Trust 2007-RR2

                 Class            Rating
                 -----            ------
                 N                CCC-/Watch Neg
                 O                CCC-/Watch Neg
                 P                CCC-/Watch Neg
                 Q                CCC-/Watch Neg
                 X                AAA/Watch Neg


GS MORTGAGE: S&P Downgrades Ratings on 10 2007-GKK1 Securities
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 10
classes of commercial mortgage-backed securities pass-through
certificates from GS Mortgage Securities Trust 2007-GKK1, a re-
REMIC transaction.  Concurrently, S&P removed one of these ratings
from CreditWatch negative, while the nine other affected ratings
remain on CreditWatch with negative implications.  Additionally,
S&P affirmed its rating on one other class from the same
transaction.

The downgrades reflect S&P's analysis of the transaction following
its downgrades to 16 CMBS certificates that serve as underlying
collateral for GSMST 2007-GKK1.  The downgraded certificates total
$116 million (18.3% of the pool balance) and are from seven
transactions.  Nine ratings from GSMST 2007-GKK1 remain on
CreditWatch negative due to the transaction's exposure to CMBS
collateral with ratings on CreditWatch negative ($93.5 million,
14.8%).

According to the Oct. 22, 2009, trustee report, 73 CMBS
certificates ($633.7 million, 100%) from 46 distinct transactions
issued between 1998 and 2007 collateralize GSMST 2007-GKK1.  GSMST
2007-GKK1 has significant exposure to these CMBS certificates that
Standard & Poor has downgraded:

  -- Morgan Stanley Capital I Trust 2007-HQ11 (classes E through
     K; $23.1 million, 3.7%);

  -- Wachovia Bank Commercial Mortgage Trust's series 2006-C27
     (classes G and H; $20 million, 3.2%); and

  -- Banc of America Commercial Mortgage Trust 2006-6 (classes F
     and G; $19.7 million, 3.1%).

S&P will update or resolve its CreditWatch negative placements on
GSMST 2007-GKK1's certificates in conjunction with S&P's
CreditWatch resolutions of the underlying CMBS assets.

      Ratings Lowered And Remaining On Creditwatch Negative

             GS Mortgage Securities Trust 2007-GKK1
Commercial mortgage-backed securities pass-through certificates

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

      Rating Lowered And Removed From Creditwatch Negative

             GS Mortgage Securities Trust 2007-GKK1
Commercial mortgage-backed securities pass-through certificates

                       Rating
                       ------
        Class            To               From
        -----            --               ----
        J                CCC-             CCC+/Watch Neg

                         Rating Affirmed

             GS Mortgage Securities Trust 2007-GKK1
Commercial mortgage-backed securities pass-through certificates

                     Class            Rating
                     -----            ------
                     K                CCC-


GSC PARTNERS: Moody's Downgrades Ratings on Various Classes
-----------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by GSC Partners CDO Fund II,
Limited:

  -- US$10,000,000 Class B Floating Rate Subordinated Notes due
     2013 (current balance of US$5,254,681), Downgraded to B3;
     previously, on January 16, 2009, Downgraded to Ba3.

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 B Overcollateralization Test.
In particular, the weighted average rating factor is currently
5034 versus a test level of 3600, as of the last trustee report,
dated as of September 30, 2009.  Based on the same report,
defaulted securities currently held in the portfolio total about
$42.6 million, accounting for roughly 23% of the collateral
balance, and securities from issuers rated Caa1 or lower by
Moody's make up approximately 44% of the underlying portfolio.
The Class B overcollateralization ratio was reported at 119.79%
versus a test level of 122.8%.

The rating actions also 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.

GSC Partners CDO Fund II, Limited, issued in March of 2003, 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.


INDEPENDENCE II: Moody's Downgrades Ratings on Class A Notes
------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of one class of Notes issued by Independence II CDO, Ltd.
The class of notes affected by the rating action is these:

  -- US$291,500,000 Class A First Priority Senior Secured Floating
     Rate Notes (current balance of $105,449,050), Downgraded to
     Ba2; previously on 3/26/2009 Downgraded to Baa3

Independence II CDO, Ltd. is a collateralized debt obligation
backed primarily by a portfolio of Commercial Mortgage-Backed
Securities and Residential Mortgage-Backed Securities.  CMBS and
RMBS are approximately 54% and 27%, respectively, of the
underlying portfolio of which the majority is from 2001-2003
vintages.

The rating downgrade actions reflect deterioration in the credit
quality of the underlying portfolio.  Credit deterioration of the
collateral pool is observed through a decline in the average
credit rating (as measured by an increase in the weighted average
rating factor), an increase in the dollar amount of defaulted
securities, and an increase in the proportion of securities rated
Caa1 and below.  Approximately 5% of the underlying assets have
been the subject of ratings downgrades since Moody's last review
of the transaction in March 2009.  The trustee reports that the
WARF of the portfolio is 1,914 as of September 30, 2009 and also
reports defaulted assets in the amount of $22.8 million.
Securities rated Caa1 or lower make up approximately 31% of the
underlying portfolio.  The Trustee also reports that the Class A/B
and Class C Overcollateralization Tests are currently failing.

The actions also take into consideration the occurrence on
February 2, 2006, as reported by the Trustee, of an Event of
Default described in Section 5.1 (i) of the Indenture dated
July 26, 2001.  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 Debt Securities and the Notes, including liquidation of
the collateral.  The actions take into consideration the risk that
liquidation of the Collateral may be selected as the post-Event of
Default remedy.  The liquidation of the CDO collateral may result
in a probability of repayment and a severity of loss that are
inconsistent with an investment-grade rating.

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.


JPMORGAN CHASE: S&P Downgrades Ratings on 16 2006-LDP7 Securities
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 16
classes of commercial mortgage-backed securities from JPMorgan
Chase Commercial Mortgage Securities Trust 2006-LDP7 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 S&P's 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 credit support erosion that S&P
anticipate will occur upon the eventual resolution of several
specially serviced assets.  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 1.41x and a loan-to-value ratio
of 112.0%.  S&P further stressed the loans' cash flows under S&P's
'AAA' scenario to yield a weighted average DSC of 0.85x and an LTV
of 154.8%.  The implied defaults and loss severity under the 'AAA'
scenario were 88.1% and 39.4%, respectively.  All of the DSC and
LTV calculations noted above exclude 13 ($75.1 million, 1.9%) of
the 23 specially serviced assets and one defeased loan (0.6%).
S&P separately estimated losses for the 13 specially serviced
assets, 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 are consistent
with the outstanding ratings.   S&P affirmed its rating on the
class X interest-only certificates based on S&P's current
criteria.  S&P published a request for comment proposing changes
to its IO criteria on June 1, 2009.  After S&P finalize its
criteria review, S&P may revise its IO criteria, which may affect
outstanding ratings, including the rating on the IO certificates
that S&P affirmed.

                      Credit Considerations

Twenty-three assets ($221.8 million, 5.7%) in the pool are with
the special servicer, LNR Partners Inc., including two of the top
10 assets.  A breakdown of the specially serviced assets by
payment status is: two loans are 60 days delinquent
($23.0 million, 0.6%), nine loans are more than 90 days delinquent
($34.0 million, 0.9%), three loans are in foreclosure
($32.5 million, 0.8%), one loan is in bankruptcy ($57.3 million,
1.5%), and two assets are reported as real estate owned
($12.5 million, 0.3%).  Twelve of the specially serviced loans
have appraisal reduction amounts in effect totaling $25.9 million.

                       Transaction Summary

As of the October 2009 remittance report, the collateral pool had
an aggregate trust balance of $3.87 billion, which is down
slightly from $3.94 billion at issuance.  The pool consists of 269
loans, which is unchanged since issuance.  The master servicer for
the transaction is Capmark Finance Inc., which provided financial
and other loan performance data that S&P used in its review.
Capmark Financial Group Inc., the master servicer's parent, filed
for Chapter 11 bankruptcy protection on Oct. 25, 2009.  Capmark
remains on S&P's Select Servicer List, as detailed in "Capmark
Servicer Rankings Remain On CreditWatch Negative After Parent's
Bankruptcy Filing," published Oct. 26, 2009.  Please review the
entire article for more information.  If S&P remove Capmark from
the Select Servicer List at some point in the future and it is not
replaced with an approved master servicer, it could result in a
downgrade, qualification, or withdrawal of the ratings in this
transaction.  It is also possible that fees and expenses
associated with the bankruptcy filing could affect the trust and
prompt future rating actions.

Capmark provided financial information for 99.2% of the pool;
95.9% of the financial information was full-year 2008 data or
interim 2009 data.  S&P calculated a weighted average DSC of 1.43x
for the pool based on the reported figures.  S&P's adjusted DSC
and LTV were 1.41x and 112.0%, respectively.  S&P's adjusted
figures exclude 13 of the 23 specially serviced assets.  S&P
estimated losses separately for these thirteen assets
($75.1 million, 1.9%).  Based on the servicer-reported DSC
figures, S&P calculated a weighted average DSC of 1.08x for these
13 assets.  The transaction has not experienced any losses to
date.  One loan ($21.2 million, 0.6%) has been defeased.  Seventy-
one loans ($861.0 million, 22.2%) are on the master servicer's
watchlist, including two of the top 10 loans, which are discussed
below.  Fifty-four loans ($474.2 million, 12.3%) have a reported
DSC of less than 1.10x, and 36 of these loans ($262.3 million,
6.8%) have a reported DSC of less than 1.0x.

                     Summary Of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$1.41 billion (36.5%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.46x for the top 10 loans.
Two of the top 10 loans ($353.1 million, 9.1%) appear on the
master servicer's watchlist.  S&P's adjusted DSC and LTV for the
top 10 loans are 1.40x and 115.5%, respectively.

The Westfield Centro Portfolio loan ($240.0 million, 6.2%) is the
largest loan in the pool and the largest loan on the watchlist.
The loan was current in its debt service payments as of the
October 2009 remittance report.  The loan appears on the
servicer's watchlist because of a decrease in reported DSC.  Based
on NCF, the reported DSC was 1.12x through June 2009, compared
with 1.33x at year-end 2008.  The loan is secured by a first
mortgage encumbering the fee and leasehold interests in five
cross-collateralized and cross-defaulted retail properties
containing 2.36 million sq. ft. located in five states.

The Hyatt - Huntington Beach loan ($113.1 million, 2.9%) is the
seventh-largest loan in the pool and the second-largest loan on
the watchlist.  The loan was current in its debt service payments
as of the October 2009 remittance report.  The loan is secured by
a first mortgage encumbering a 517-room full-service resort hotel
in Huntington Beach, Calif.  The loan appears on the servicer's
watchlist because of a low reported DSC.  Based on NCF, the
reported DSC was 1.21x through June 2009, compared with 1.94x at
year-end 2008.

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

   JPMorgan Chase Commercial Mortgage Securities Trust 2006-LDP7
          Commercial mortgage pass-through certificates

                 Rating
                 ------
      Class     To     From            Credit enhancement (%)
      -----     --     ----            ----------------------
      A-4       AA-    AAA/Watch Neg                    30.53
      A-SB      AA-    AAA/Watch Neg                    30.53
      A-1A      AA-    AAA/Watch Neg                    30.53
      A-M       A-     AAA/Watch Neg                    20.36
      A-J       BBB-   AAA/Watch Neg                    12.34
      B         BB+    AA/Watch Neg                     10.31
      C         BB     AA-/Watch Neg                     9.16
      D         BB-    A+/Watch Neg                      8.78
      E         B+     A/Watch Neg                       7.76
      F         B+     A-/Watch Neg                      6.74
      G         B+     BBB+/Watch Neg                    5.47
      H         B      BBB/Watch Neg                     4.45
      J         B      BBB-/Watch Neg                    3.31
      K         B-     BB+/Watch Neg                     2.93
      L         B-     BB/Watch Neg                      2.54
      M         CCC+   BB-/Watch Neg                     2.04

                         Ratings Affirmed

   JPMorgan Chase Commercial Mortgage Securities Trust 2006-LDP7
          Commercial mortgage pass-through certificates

            Class     Rating    Credit enhancement (%)
            -----     ------    ----------------------
            A-1       AAA                        30.53
            A-2       AAA                        30.53
            A-3A      AAA                        30.53
            A-3FL     AAA                        30.53
            A-3B      AAA                        30.53
            X         AAA                          N/A

                       N/A - Not applicable.


JPMORGAN CHASE: S&P Downgrades Ratings on 18 2006-LDP8 Securities
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 18
classes of commercial mortgage-backed securities from JPMorgan
Chase Commercial Mortgage Securities Trust 2006-LDP8 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 S&P's 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 credit considerations relating
to several of the specially serviced assets and one asset that S&P
determined to be 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 1.36x and a loan-
to-value ratio of 108.4%.  S&P further stressed the loans' cash
flows under S&P's 'AAA' scenario to yield a weighted average DSC
of 0.87x and an LTV of 143.2%.  The implied defaults and loss
severity under the 'AAA' scenario were 90.8% and 35.4%,
respectively.  All of the DSC and LTV calculations S&P noted above
exclude four ($55.3 million, 1.8%) of the eight specially serviced
assets and one credit-impaired loan ($7.5 million, 0.3%).  S&P
separately estimated losses for these assets, 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 are consistent
with the outstanding ratings.  S&P affirmed its rating on the
class X 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 finalize its
criteria review, S&P may revise its IO criteria, which may affect
outstanding ratings, including the rating on the IO certificates
that S&P affirmed.

                      Credit Considerations

Eight assets ($252.1 million, 8.3%) in the pool are with the
special servicer, J.E. Robert Co. Inc., including one of the top
10 assets.  A breakdown of the specially serviced assets by
payment status is: two loans are more than 90 days delinquent
($45.5 million, 1.5%), one loan is in foreclosure ($5.9 million,
0.2%), one loan is in bankruptcy ($173.0 million, 5.7%), and one
asset is real estate owned ($3.9 million, 0.1%).  Three of the
specially serviced loans have appraisal reduction amounts (ARAs)
in effect totaling $23.1 million.

The Tysons Galleria loan, which is the sixth-largest exposure in
the pool, is the largest loan in special servicing.  Pacific Life
is the special servicer for this loan.  The loan has a total trust
exposure of $174.0 million and a whole-loan balance of
$255.0 million.  The loan is secured by the leasehold interest in
309,112 sq. ft. of a 821,045-sq.-ft. two-story, enclosed, upscale
regional mall in McLean, Va.  The reported DSC for the property as
of year-end 2008 was 1.43x, and the occupancy was 96.0%.  The loan
was reported as current on the October 2009 remittance report and
was transferred to the special servicer on April 22, 2009, due to
General Growth Properties' bankruptcy filing.  S&P will continue
to monitor the developments relating to this loan and will take
rating actions on this transaction as necessary.

The second-largest loan with the special servicer is the
University Center loan ($25.5 million, 0.8%).  This loan was
transferred to the special servicer on Dec. 22, 2008, due to
payment default, and is in foreclosure.  This loan is secured by a
109,151-sq.-ft. retail property across from Florida International
University in Miami, Fla.

The special servicer appointed a receiver for the property.  S&P
expects a significant loss upon the eventual resolution of this
asset.

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

In addition to the specially serviced assets, S&P deemed the
Cheyenne Woods Apartments loan ($7.5 million, 0.3%) to be credit-
impaired.  This loan is reported as 60 days delinquent, and is
secured by a 160-unit multifamily property in North Las Vegas,
Nev.  Interim 2009 financials reflect a decline in DSC to 0.98x
from 1.19x at year end 2008.  This loan was transferred to the
special servicer on Oct. 9, 2009, after the Sept. 30, 2009, record
date on the most recent trustee remittance report.  S&P expects a
moderate loss upon the eventual resolution of this asset.

                       Transaction Summary

As of the October 2009 remittance report, the collateral pool had
an aggregate trust balance of $3.03 billion, which is down
slightly from $3.07 billion at issuance.  The pool consists of 165
loans, which is one less than at issuance.  The master servicers
for the transaction, Midland Loan Services Inc. (Midland) and
Wells Fargo Bank N.A., provided financial information for 98.5% of
the pool; 97.4% of the financial information was full-year 2008
data or interim 2009 data.  S&P calculated a weighted average DSC
of 1.44x for the pool based on the reported figures.  S&P's
adjusted DSC and LTV were 1.36x and 108.4%, respectively.  S&P's
adjusted figures exclude four of the eight specially serviced
loans, and one credit-impaired loan.  S&P estimated losses
separately for these five loans ($62.9 million, 12.1%).  Based on
the servicer-reported DSC figures, S&P calculated a weighted
average DSC of 0.88x for these five loans.  The transaction has
not experienced any principal losses to date.  One loan
($14.7 million, 0.5%) has paid off.  Thirty-two loans
($347 million, 11.4%) are on the master servicer's watchlist,
including one of the top 10 loans, which is discussed below.
Twenty-nine loans ($238.6 million, 7.9%) have a reported DSC below
1.10x, and 14 of these loans ($114.9 million, 3.8%) have a
reported DSC of less than 1.0x.

                    Summary Of The Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$1.87 billion (61.7%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.48x for the top 10 loans.
One of the top 10 loans ($110.2 million, 3.6%) appears on the
master servicer's watchlist.  S&P's adjusted DSC and LTV for the
top 10 loans are 1.34x and 110.1%, respectively.

The CNL/Welsh Portfolio loan ($110.2 million, 3.6%) is the eighth-
largest loan in the pool and the largest loan on the watchlist.
The loan was current in its debt service payments as of the
October 2009 remittance report.  The loan appears on the
servicer's watchlist because of a covenant compliance violation
related to the bankruptcy of one of the tenants.  The DSC based on
NCF was reported as 1.82x as of year-end 2008.  The loan is
secured by a first mortgage encumbering the fee interest in 13
single-tenant industrial-flex properties containing 2.38 million
sq. ft. in 10 states.

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

  JPMorgan Chase Commercial Mortgage Securities Trust 2006-LDP8
           Commercial mortgage pass-through certificates

                  Rating
                  ------
       Class     To     From          Credit enhancement (%)
       -----     --     ----          ----------------------
       A-4       AA-    AAA/Watch Neg                  30.34
       A-SB      AA-    AAA/Watch Neg                  30.34
       A-1A      AA-    AAA/Watch Neg                  30.34
       A-M       A-     AAA/Watch Neg                  20.23
       A-J       BBB-   AAA/Watch Neg                  11.63
       B         BB+    AA/Watch Neg                    9.86
       C         BB     AA-/Watch Neg                   9.10
       D         BB-    A/Watch Neg                     7.71
       E         B+     A-/Watch Neg                    6.57
       F         B+     BBB+/Watch Neg                  5.31
       G         B      BBB/Watch Neg                   4.30
       H         B      BBB-/Watch Neg                  3.03
       J         B-     BB+/Watch Neg                   2.65
       K         B-     BB/Watch Neg                    2.40
       L         CCC+   BB-/Watch Neg                   2.02
       M         CCC    B+/Watch Neg                    1.90
       N         CCC    B/Watch Neg                     1.52
       P         CCC-   CCC+/Watch Neg                  1.14

                         Ratings Affirmed

   JPMorgan Chase Commercial Mortgage Securities Trust 2006-LDP8
          Commercial mortgage pass-through certificates

            Class     Rating    Credit enhancement (%)
            -----     ------    ----------------------
            A-1       AAA                        30.34
            A-2       AAA                        30.34
            A-3A      AAA                        30.34
            A-3FL     AAA                        30.34
            A-3B      AAA                        30.34
            X         AAA                          N/A

                       N/A - Not applicable.


LBSBC NIM: S&P Downgrades Ratings on All Classes of Notes
---------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on all
outstanding classes of notes from LBSBC NIM Co.'s series 2006-1,
2006-2, 2006-3, 2007-1, and 2007-3.  All of these ratings, except
for those lowered to 'CC', remain on CreditWatch with negative
implications.

The net interest margin securities from the LBSBC NIM Co. trusts
hold two classes of asset-backed pass-through certificates--the
class X subordinate certificates and the class P certificates
previously issued by the underlying transactions, five Lehman
Bros.  Small Balance Commercial Mortgage Trusts.  The class X
certificates entitle certificateholders to receive excess cash
flow (if any) generated by the loans and pass-through certificates
each month after transaction expenses and required distributions
to each class of rated certificates in the underlying transactions
have been paid.  The class P certificates entitle certificate
holders to receive certain prepayment penalties associated with
the mortgage loans in the underlying transactions.

Because of the increased delinquencies in the collateral for the
underlying transactions, excess cash flow continues to be trapped,
as opposed to being passed on to the NIM trusts.  The NIM
transactions are currently reliant solely on prepayment penalties
and the reserve funds to make their interest payments.  Depending
on individual loan seasoning and performance, the availability of
future prepayment penalty funds could be significantly reduced.
Only LBSBC NIM Co.'s series 2007-3 has been receiving regular
prepayment penalties for the past six months.  All series have
been paying interest on the senior classes from their reserve
account and intermittent prepayment penalties.

The reserve accounts for these trusts have fallen below their
initial nine-month interest levels, and series 2007-1 lacked the
funds to make a full interest payment in the most recent payment
period.  Currently, the reserve account for series 2006-3 is not
sufficient to make a full interest payment on the next payment
date.  The remaining three trusts have enough funds in their
reserve accounts to pay between three and six months of interest
on the senior class if there continue to be no prepayment
penalties.

The current structure of these securitizations allow the most
senior class of notes, currently class N1, to experience an
interest default for three consecutive payment dates before
triggering an event of default.  The subordinate classes can
receive payment-in-kind interest payments, as long as there are
senior notes outstanding.

The ratings differential between the securitizations reflects a
combination of the funds in the reserve accounts, the amount of
monthly interest due, and the frequency of prepayment penalties.
The earlier securitizations, series 2006-1 and 2006-2, have
monthly interest payments of $1,911 and $29,764, respectively.
Both have received prepayment penalties as high as $79,795 and
$144,320, respectively, in the previous five months.  Future
prepayment penalties of comparable amounts have the ability to
extend the life of these securitizations, as both transactions
currently have at least five months of interest payments in their
reserve accounts.  A large prepayment penalty has the ability to
return the reserve accounts to their initial nine-month funding
requirement.

All of S&P's ratings, except those S&P lowered to 'CC', remain on
CreditWatch negative to reflect the possibility that the trusts
will continue to use their reserve accounts due to the potential
for lower-than-expected future cash flows.  Cash flow from the
class X certificates may not resume in the near future if the
underlying transactions' delinquencies remain at their current
levels.  Delinquencies among the underlying transactions would
have to decrease significantly and their reserve accounts,
currently at zero, would have to reach their target levels before
the excess spread from these underlying transactions begins to
pass through to the NIM trusts again.

If the performance of the underlying transactions continues to
squeeze the NIMs' cash flows and the NIMs' credit enhancement
deteriorates, S&P may take further negative rating actions as S&P
deem appropriate.

                          Rating Actions

                       LBSBC NIM Co. 2006-1
     $26 million net interest margin securities series 2006-1

                             Rating
                             ------
            Class       To              From
            -----       --              ----
            N1          B-/Watch Neg    BB+/Watch Neg
            N2          CCC-/Watch Neg  B+/Watch Neg
            N3          CCC-/Watch Neg  B-/Watch Neg

                       LBSBC NIM Co. 2006-2
     $28 million net interest margin securities series 2006-2

                             Rating
                             ------
            Class       To              From
            -----       --              ----
            N1          B-/Watch Neg    BB+/Watch Neg
            N2          CCC-/Watch Neg  B+/Watch Neg
            N3          CCC-/Watch Neg  B-/Watch Neg

                      LBSBC NIM Co. 2006-3
     $29 million net interest margin securities series 2006-3

                             Rating
                             ------
            Class       To              From
            -----       --              ----
            N1          CCC-/Watch Neg  BB-/Watch Neg
            N2          CC              B/Watch Neg
            N3          CC              CCC/Watch Neg

                      LBSBC NIM Co. 2007-1
  $25 million LBSBC net interest margin securities series 2007-1

                             Rating
                             ------
            Class       To              From
            -----       --              ----
            N1          CCC-/Watch Neg  BB-/Watch Neg
            N2          CC              B/Watch Neg
            N3          CC              CCC/Watch Neg

                      LBSBC NIM Co. 2007-3
     $39 million net interest margin securities series 2007-3

                             Rating
                             ------
            Class       To              From
            -----       --              ----
            N1          CCC/Watch Neg   BB-/Watch Neg
            N2          CC              B/Watch Neg
            N3          CC              CCC/Watch Neg


LOAN FUNDING: Fitch Cuts & Withdraws Rating on 2003-1 Notes
-----------------------------------------------------------
Fitch Ratings has downgraded and withdrawn its rating on one class
of notes issued by Loan Funding Corp 2003-1.  In addition, one
class has paid in full.  Details of the rating action follow at
the end of this press release.

LFC 2003-1 terminated on Oct. 15, 2009.  The rating action
reflects the final distribution of the liquidation proceeds to
noteholders.

As a result of the liquidation, the class A notes have been PIF,
as the class received all interest and principal that was owed to
it upon termination.  The class B notes have been downgraded to
'D' as it received no proceeds upon termination of the transaction
and therefore experienced a principal and interest default.

LFC 2003-1 was a synthetic total rate of return collateralized
loan obligation with a market value termination trigger.  The
transaction initially closed on July 10, 2003, and was managed by
Guggenheim Investment Management LLC.

This rating action is effective immediately:

  -- $25,000,000 class A notes PIF;

  -- $12,000,000 class B notes downgraded to 'D' from 'CCC';
     subsequently withdrawn.


MALIBU LOAN: Fitch Affirms Ratings on $110.8 Mil. Notes at 'CCC'
----------------------------------------------------------------
Fitch Ratings has affirmed the $110,800,000 class B notes issued
by Malibu Loan Fund, Ltd, at 'CCC'.

The affirmation reflects Fitch's analysis of both the market value
and the credit risk of the portfolio.  The market value risk was
analyzed by comparing the distance to trigger metric of 7% to the
advance rate ranges published in Fitch's Markey Value Structures
criteria and further supplemented in 'Fitch Update: Application of
Revised Market Value Structure Criteria to TRR CLOs', published in
May 2008.  Based on Fitch's classification of the assets, the
market value trigger is in line with Fitch's 'CCC' advance rates
for this structure.

The reference portfolio is comprised of a diverse pool of senior
secured loans.  Therefore, the credit risk of the portfolio was
analyzed using the Portfolio Credit Model, as described in Fitch's
Corporate CDO criteria (this and the other aforementioned criteria
are cited at the bottom of this press release).  Based on Fitch's
PCM analysis, the par subordination of the notes (approximately
10%) was in line with a 'CCC' rating loss rate.

Malibu Loan Fund, LLC, is a synthetic total rate of return
collateralized loan obligation with a market value termination
trigger.  The transaction closed on Sept. 30, 2005 and is managed
by Aegon USA Investment Management.  The notes began to experience
negative net asset value coverage in 2008, but subsequently
benefited from cash infusions which were designed to increase the
distance to the MV trigger.


MARATHON CLO: Moody's Reviews Ratings on Two Classes of Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has placed under
review for possible downgrade the ratings of these notes issued by
Marathon CLO I Ltd.:

  -- US$19,000,000 Class D Floating Rate Subordinate Deferrable
     Interest Notes Due 2019, B1 Placed Under Review for Possible
     Downgrade; previously on June 18, 2009 Confirmed B1;

  -- US$8,000,000 Class E Floating Rate Subordinate Deferrable
     Interest Notes Due 2019 (current balance $2,340,671), Caa3
     Placed Under Review for Possible Downgrade; previously on
     June 18, 2009 Confirmed Caa3.

According to Moody's, the rating actions result from credit
deterioration following recent sales by the issuer of
$217.5 million in par amount of collateral, which is approximately
two-thirds of the outstanding portfolio par immediately prior to
the sales.  Moody's notes that, according to the trustee report
dated October 16, 2009, the issuer executed the sales during the
period between September 18, 2009, and October 16, 2009.  The
sales were characterized primarily as "credit risk" sales, with a
small number of "discretionary" and "credit improved" sales.  The
reported sales were executed at a weighted average price of 90.7%.
The sales proceeds together with certain other principal and
interest collections were reported as being applied to the partial
redemption of the Class A-1 and Class A-2 notes in relation to the
cure of coverage test failures.  The Class A-1 and Class A-2 notes
were reduced by 85% significantly improving OC coverage for the
Class A, B, and C Notes.

The credit deterioration is evidenced by the weighted average
rating factor and the diversity of the pool following the sales.
The average credit quality of the $92.0 million remaining
collateral pool (as measured by the weighted average rating
factor) is notably lower than the average quality of the larger
collateral pool prior to the sales.  In particular, the weighted
average rating factor has increased and was 3941 as of the trustee
report dated October 16, 2009, versus 3400 as of the trustee
report dated September 18, 2009 (immediately prior to the above
sales).  The sales also resulted in a substantial decline in
diversity suggestive of increased concentration risks for the
pool.  The reported Diversity Score of 24 in the October report is
significantly lower than the level of 55 reported in September.
Finally the exposure to obligations rated CCC or Caa continues to
breach the limit of 5%, and is currently estimated to represent
about 30% of the remaining pool.  This includes approximately 6%
structured finance securities with depressed market values and
poor recovery prospects in the event of default.  Moody's expects
that the sales of assets and the resulting weaker portfolio has an
adverse impact on junior notes.  As a result, Moody's has placed
only the Class D and E notes on review for possible downgrade.

Marathon CLO I Ltd., issued in April 2005, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.


MERRILL LYNCH: S&P Downgrades Ratings on Three 1999-C1 Certs.
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on three
classes of commercial mortgage pass-through certificates from
Merrill Lynch Mortgage Investors Inc.'s series 1999-C1.  At the
same time, S&P affirmed its ratings on two other classes of
certificates from the same transaction.  Concurrently, S&P removed
all of the lowered and affirmed ratings from CreditWatch with
negative implications, where S&P initially placed them on June 15,
2009.

The downgrades reflect recurring interest shortfalls to the
classes since July 2009.  S&P believes the interest shortfalls
could occur for an extended period if the specially serviced
assets in the pool are not resolved, or if the master servicer,
KeyBank Real Estate Capital, declares advances to be
nonrecoverable on the Frazier King Building, a specially serviced
asset with significant advances outstanding (which S&P discuss in
detail below).  S&P may take further rating actions, including
possibly lowering the ratings to 'D', if the interest shortfalls
on the commercial mortgage-backed securities classes occur for an
extended period.

The affirmation of class C reflects subordination levels that are
consistent with the outstanding ratings.  The class recently
recovered accumulated interest shortfalls that had been
outstanding since July 2009.  S&P also affirmed its rating on the
interest-only class IO certificates based on S&P's current
criteria.  S&P published a request for comment proposing changes
to its IO criteria on June 1, 2009.  After S&P finalize its
criteria review, S&P may revise its IO criteria, which may affect
outstanding ratings, including the rating on the class IO
affirmed.

According to the October 2009 remittance report, classes D, E and
F have experienced interest shortfalls for the past four months
following the recovery of approximately $15.4 million of advances
by the master servicer from the trust.  The advance recoveries
were related to the Arlington Apartments asset, the third-largest
exposure with the special servicer and the fifth-largest exposure
in the pool.  As of the October 2009 remittance report, the
aggregate accumulated outstanding interest shortfalls to the
classes were $978,448.

Of the remaining 14 assets in the pool, 10 ($58.3 million, 63%)
are with the special servicer, ORIX Capital Markets LLC.  Details
on the three largest exposures with the special servicer are:

The largest exposure with the special servicer and the third-
largest in the pool is the Frazier-King Building, with a total
exposure of $22.3 million.  The total exposure includes
$7.6 million of servicer advances.  The asset was transferred to
ORIX on Jan. 30, 2003, due to imminent default and became real
estate owned (REO) on April 8, 2005.  The property is a 143,000-
sq.-ft. building in Irving, Texas, that was 69% occupied as of
Sept. 30, 2009.  Standard & Poor's expects a full loss upon the
resolution of this asset.  The First American Building loan is the
second-largest exposure with the special servicer, with an unpaid
principal amount of $14.4 million (13.6%).  The loan is secured by
a 230,700-sq.-ft. office property in Dallas, Texas.  The loan was
transferred to the special servicer in June 2006 due to imminent
default after the sole tenant indicated that it would exercise an
early lease termination.  The loan is current under the second
loan modification.  As of Sept. 30, 2009, the property was 43%
occupied, which includes 67,500 sq. ft. recently leased.  A lease
for an additional 40,000 sq. ft. is currently under negotiation.
Standard and Poor's expects a minimal loss upon the resolution of
the loan at this time.

The Arlington Apartments asset, discussed above, represents a
total exposure of $6.2 million (5.7%).  Although $15.3 million in
advances were recovered in July 2009, as noted above, an exposure
of $6.2 million remains in the trust pending resolution of the
asset.  Standard & Poor's expects a full loss upon the eventual
resolution.

As of the October 2009 remittance report, the collateral pool
consisted of one REO asset and 13 loans with an aggregate trust
balance of $92.5 million.  One loan ($7.1 million, 10.7%) is
defeased.  Of the 10 assets with the special servicer, one is REO
($14.7 million, 13.5%), one is in foreclosure ($2.6 million,
4.5%), and one is 90-plus-days delinquent ($1.91 million, 1.8%).
To date, the trust has experienced six losses totaling
$29.2 million, which includes the recovery of advances on the
Arlington Apartments asset discussed above.

The top 10 exposures have an aggregate outstanding balance of
$86.8 million (93.8%), and all are either in special servicing
(seven assets; $59.6 million, 64%) or on the master servicer's
watchlist (three loans; $27.2 million, 29%).

The three loans ($27.2 million, 29.4%) on the master servicer's
watchlist include the Blue Cross Blue Shield Building loan
($22.6 million, 24.4%), which is the largest loan in the pool.
The loan is secured by a 456,304-sq.-ft. medical office building
in Columbia, S.C.  The property is 100% occupied by Blue Cross
Blue Shield.  The loan was initially placed on the watchlist in
July 2009 because of an anticipated repayment date of Oct. 1,
2009.  The borrower indicated that it does not intend to pay off
the loan and will make an additional 2% interest payment until it
can negotiate a new long-term lease with Blue Cross Blue Shield.

       Ratings Lowered And Removed From Creditwatch Negative

                Merrill Lynch Mortgage Investors Inc.
    Commercial mortgage pass-through certificates series 1999-C1

                 Rating
                 ------
      Class    To       From            Credit enhancement (%)
      -----    --       ----            ----------------------
      D        CCC+     BBB-/Watch Neg                   64.11
      E        CCC      BB/Watch Neg                     41.70
      F        CCC-     B-/Watch Neg                     33.70

      Ratings Affirmed And Removed From Creditwatch Negative

               Merrill Lynch Mortgage Investors Inc.
   Commercial mortgage pass-through certificates series 1999-C1

                 Rating
                 ------
      Class    To       From            Credit enhancement (%)
      -----    --       ----            ----------------------
      C        BBB      BBB/Watch Neg                   73.71
      IO       AAA      AAA/Watch Neg                     N/A

                       N/A - Not applicable.


MILLENNIUM PARK: Moody's Reviews Ratings on Two Classes of Notes
----------------------------------------------------------------
Moody's Investors Service announced that it has placed the ratings
of these notes issued by Millennium Park CDO I, Ltd., under review
for possible downgrade:

  -- $1,740,000,000 Class A-1 Contingent Funding Notes, due March
     2014 (current balance of $1,729,211,575), A3 Placed Under
     Review for Possible Downgrade; previously on May 19, 2009
     Downgraded to A3;

  -- $95,000,000 Class A-2 Floating Rate Notes, due March 2014,
     Caa3 Placed Under Review for Possible Downgrade; previously
     on May 19, 2009 Downgraded to Caa3.

According to Moody's, the rating actions taken are a result of
further credit deterioration of the underlying portfolio since the
last actions taken on May 19, 2009.  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 proportion of securities from issuers rated Ba1 and below, and
continued failure of all the overcollateralization tests.  In
particular, the weighted average rating factor has increased since
the last rating action and is currently 1469 as of the last
trustee report, dated October 8, 2009, versus 1061 as of the April
trustee report.  Based on the same report, securities rated Ba1 or
lower currently make up approximately 41.61% of the underlying
portfolio compared to 37.05% in the April 9, 2009 trustee report.
The percentage of securities rated Ca or C has also increased from
1.27% in April to 5.47%.  The reference portfolio also includes
exposure to CIT Group, Inc., which filed for Chapter 11 bankruptcy
on November 1, 2009 and Ambac Financial Group, which has
experienced substantial credit migration in the past few months
and is now rated Ca.  Additionally, interest payments on the Class
C and Class D Notes continue to be deferred as a result of the
failure of the Class A/B overcollateralization test.

Moody's notes that on April 13, 2009, the Class A-2 Notes were
downgraded from Aaa to Aa3 as a result of the additional risk
posed to the noteholders due to the action taken by Moody's on the
senior unsecured rating of General Electric Capital Corporation.
The Class A-2, Class B, Class C, and Class D notes are
collateralized by floating rate global MTNs issued by GECC and on
March 23, 2009, Moody's downgraded the senior unsecured rating of
GECC from Aaa to Aa2.  Additionally, on May 19, 2009, the A-1
Notes were downgraded from Aaa to A3 and the A-2 Notes were
further downgraded from Aa3 to Caa3 as a result of the application
of revised and updated key modeling assumptions and the
deterioration in the credit quality of the transaction's reference
portfolio.

Millennium Park CDO I, Ltd., issued in March 2007, is a
collateralized bond obligation backed primarily by a synthetic
portfolio of corporate bonds.


MKP CBO: Fitch Downgrades Ratings on Three Classes of Notes
-----------------------------------------------------------
Fitch Ratings has downgraded three classes of notes issued by MKP
CBO III, LTD. as a result of continued credit deterioration in the
portfolio since Fitch's last rating action in August 2008.
Approximately 52.8% 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 47.5% of
the portfolio with a Fitch derived rating below investment grade
and 31.3% with a rating in the 'CCC' rating category or lower,
compared to 24.4% and 12.8%, respectively, at last review.
Defaulted securities, as defined in the transaction's governing
documents, now comprise 25.7% of the portfolio, compared to 10.7%
at last review.

MKP III entered an event of default on July 20, 2009, after the
class A/B overcollateralization ratio declined below 100%.  The
necessary majority of the controlling class voted to accelerate
the transaction as of Nov. 2, 2009.  Therefore, on the Nov. 9,
2009 distribution date, interest and principal proceeds began
diverting to redeem principal of the class A-2 notes rather than
to pay class B accrued interest.

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-2 notes is generally
consistent with the PCM rating loss rate for the 'AA' rating
category.  While the class A-2 notes are benefiting from excess
spread due to the transaction accelerating, the degree of
deterioration within the portfolio outweighs the positive effect
of amortization resulting in the downgrade.

The class A-2 notes are assigned a Negative Rating Outlook due to
the high 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-2 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.

Due to the significant collateral deterioration, all PCM rating
loss rates exceed the credit enhancement available to the class B
and class C notes.  For these classes, Fitch considered future
payment expectations to determine their appropriate ratings.

The class B notes are downgraded to 'D' because they have
defaulted on the timely interest component of their rating as of
the Nov. 9, 2009 distribution date due to the acceleration.  The
class B notes will not receive any further distributions until the
class A-2 notes are paid-in-full, at which time they will begin
receiving all available interest and principal proceeds.

The class C notes are downgraded to 'C' to indicate Fitch's belief
that default is inevitable at or prior to maturity.  The class C
notes did not receive any distributions on the Aug. 10, 2009,
payment date, due to the class A/B OC ratio failing its covenant,
and the Nov. 9, 2009 payment date, due to the acceleration, and
are not expected to receive any proceeds going forward.

MKP III is a structured finance collateralized debt obligation
that closed on April 7, 2004, and is monitored by MKP Capital
Management, LLC.  The portfolio is primarily composed of RMBS
(73.6%), commercial mortgage-backed securities (22.2%), and SF
CDOs (3.6%).

Fitch has downgraded and assigned Outlooks and LS ratings as
indicated:

  -- $45,161,527 class A-2 notes downgraded to 'AA' from 'AAA';
     assigned Negative Outlook; assigned 'LS3';

  -- $45,000,000 class B notes downgraded to 'D' from 'BB';

  -- $13,031,365 class C notes downgraded to 'C' from 'CCC'.


ML-CFC COMMERCIAL: S&P Downgrades Ratings on 39 Securities
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 39
classes of commercial mortgage-backed securities from ML-CFC
Commercial Mortgage Trust 2007-5, Wachovia Bank Commercial
Mortgage Trust's series 2007-C30, and Wachovia Bank Commercial
Mortgage Trust's series 2007-C31.  At the same time, S&P removed
36 of these ratings from CreditWatch with negative implications.
In addition, S&P affirmed its ratings on 35 classes from the same
transactions and removed one of them from CreditWatch negative.

The downgrades follow S&P's analysis of the transactions using its
U.S. conduit and fusion CMBS criteria, which was the driver of the
super senior 'AAA' downgrades.  S&P's reduced valuation of the
Stuyvesant Town and Peter Cooper Village loan was a significant
consideration in all the rating actions, particularly those
affecting the mezzanine and subordinate classes.  S&P valued the
collateral property under several different scenarios to derive a
stressed value that was 48% lower than S&P's value at issuance.
Considerations regarding specially serviced assets also
contributed to the lowered ratings on the mezzanine and
subordinate classes.

The affirmation of the ratings on the principal and interest
certificates reflects subordination levels that are consistent
with the current ratings.  S&P affirmed its ratings on the
interest-only certificates based on S&P's current criteria.  S&P
published a request for comment proposing changes to its IO
criteria on June 1, 2009.  After S&P finalize 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.

             Stuyvesant Town And Peter Cooper Village

The ST/PCV $3.0 billion participated IO loan is the largest
exposure in the WBCMT 2007-C30 ($1.5 billion, 19%) and ML-CFC
2007-5 ($800.0 million, 18%) transactions.  It is the fifth-
largest exposure in the WBCMT 2007-C31 transaction
($247.7 million, 4%).  Two additional participations totaling
$452.3 million serve as collateral in two transactions not rated
by Standard & Poor's: ML-CFC 2007-6 and CWCI 2007-C2.  The loan is
secured by a 110-building apartment complex consisting of 11,227
market-rent and rent-stabilized units on the east side of
Manhattan.  In addition to the $3.0 billion senior loan, there is
$1.4 billion of mezzanine debt secured by the borrower's equity
interest, which does not serve as collateral for the CMBS
transactions.

S&P determined the loan to be credit-impaired.  In S&P's view, the
loan is at an increased risk of transfer to the special servicer
and monetary default due to low debt service coverage (DSC) and
the likely inability of the sponsor to achieve the property's
expected valuation at the time of loan origination.  The master
servicer for this loan, Wachovia Bank N.A., reported a DSC of
0.65x and occupancy of 96% for the six-month period ended June 30,
2009.  The remaining balance of the debt service reserve was
$24.4 million as of the October 2009 remittance report, and the
reserve could be depleted by the end of the year.  Unless the
sponsors of the loan, Tishman Speyer and Blackrock Realty Advisors
Inc., choose to fund the $191.5 million ongoing annual debt
service payments out of pocket, they will likely need to seek a
capital infusion or loan restructuring.  In addition, under S&P's
analysis, the loan is not generating enough cash flow to fund debt
service on the mezzanine debt.

Credit considerations with respect to the loan prompted downgrades
of the three Standard & Poor's rated CMBS transactions over a year
ago.  S&P has recently revised its valuation of the loan, however,
given a recent ruling by the New York Court of Appeals.  On
Oct. 22, 2009, the New York Court of Appeals affirmed an order of
the New York Appellate Division and concluded that the current and
former owners of the property were not entitled to take advantage
of the luxury decontrol provisions of the New York Rent
Stabilization Law while simultaneously receiving tax incentive
benefits under the City of New York's J-51 tax incentive for
multiple-unit renovation program.  S&P believes the ruling could
significantly curtail the borrower's efforts to convert additional
units to market rents.  In fact, the borrower stopped converting
units earlier this year.  Prior to that time, the borrower
converted more than 1,000 units to market rents, bringing the
total number of market-rent units at the property to more than
4,000; more than 6,500 units remain rent-stabilized.  The
remaining units are occupied by employees, are models, or are
vacant.  Although it isn't clear at this time, S&P believes that
the ruling could also cause some market-rent units to be
reconverted to rent-stabilized units.

In any event, it is feasible that many of the 6,699 stabilized
units may not be converted to market-rent at this time.  To assess
the impact on value, S&P analyzed the property's cash flows using
the borrower's Dec. 31, 2008, and June 30, 2009, financial
statements, the September 2009 rent roll, and current market
occupancy and rental rate information.  Although S&P looked at a
range of scenarios, S&P's baseline analysis produced a stressed
valuation that has declined 48% since issuance.  The valuation
decline translates to a 38.9% loss on the whole loan.  The loss of
additional future rental revenues from converting the rent-
stabilized units to market-rent is the driver of the valuation
decline.  S&P used these assumptions in its valuation:

* S&P assumed a 5% vacancy rate for market-rent units, and a 0%
  vacancy rate for rent-stabilized units.

* S&P assumed rental concessions of one-month free rent on a 12-
  month lease for market-rent units.

S&P attempted to normalize operating expenses, which resulted in
an operating expense ratio in the low 50% range, somewhat lower
than the mid 50% range based on servicer-reported numbers for
year-end 2007 through June 30, 2009.  S&P's view is that while
some expenses, such as legal and professional fees, may remain
relatively high, other expenses, such as advertising and
marketing, may decline going forward.  Furthermore, some expenses,
such as payroll and benefits, were inflated in 2007 and 2008 due
to nonrecurring expenses such as severance costs.

S&P also estimated average capital expenditures of $250 per unit
for the stabilized units and $200 per unit for renovated units.
S&P used the estimated in-place net cash flow to value the
property.  The resulting value is 48% below the ST/PCV value at
issuance, which S&P derived using a 10-year discounted net cash
flow.

S&P will continue to monitor developments on the loan that could
affect S&P's valuation, and S&P will adjust its ratings as needed.
If a transfer occurs, S&P will also consider the impact of related
fees and expenses on the trust, which could prompt interest
shortfalls on the rated classes and further downgrades.

Details on the WBCMT 2007-C30 and ML-CFC 2007-5 transactions,
which had ratings on CreditWatch negative, are detailed below.
The WBCMT 2007-C31 transaction, which S&P reviewed in September
2009, is discussed briefly following the discussion of the WBCMT
2007-C30 and ML-CFC 2007-5 transactions below.

Transaction Summaries:

                 WBCMT 2007-C30 AND ML-CFC 2007-5

S&P's analysis of the WBCMT 2007-C30 and ML-CFC 2007-5
transactions included a review of the credit characteristics of
all of the loans in each pool.  For WBCMT 2007-C30, S&P used
servicer-provided financial information to calculate an adjusted
DSC of 1.22x and a loan-to-value ratio of 134.1%.  S&P further
stressed the loans' cash flows under S&P's 'AAA' scenario to yield
a weighted average DSC of 0.70x and an LTV of 187.5%.  The implied
defaults and loss severity under the 'AAA' scenario were 96.4% and
48.0%, respectively.

For ML-CFC 2007-5, S&P used servicer-provided financial
information to calculate an adjusted DSC of 1.38x and a LTV of
117.3%.  S&P further stressed the loans' cash flows under S&P's
'AAA' scenario to yield a weighted average DSC of 0.81x and a LTV
of 170.5%.  The implied defaults and loss severity under the 'AAA'
scenario were 91.2% and 44.1%, respectively.

All of the DSC and LTV calculations noted above exclude the
credit-impaired ST/PCV loan participations, as well as 10
($94.3 million, 1.2%) of the 16 specially serviced loans in WBCMT
2007-C30 and six ($48.1 million, 1.1%) of the nine specially
serviced loans in ML-CFC 2007-5.  S&P separately estimated losses
for these loans, which are included in its 'AAA' scenario implied
default and loss figures.

Fifty-nine loans in WBCMT 2007-C30 (46.7%) are on Wachovia's
watchlist, including six of the top 10 loans.  Thirty-nine loans
($3.2 billion, 41.0%) have a reported DSC of less than 1.10x, and
29 of these loans ($2.9 billion, 37.0%) have a reported DSC of
less than 1.0x.  Seventy loans in ML-CFC 2007-5 (34.7%) are on the
master servicers' watchlists, including three of the top 10 loans.
Fifty loans ($1.3 billion, 29.9%) have a reported DSC of less than
1.10x, and 37 of these loans ($1.1 billion, 26.0%) have a reported
DSC of less than 1.0x.

                 Specially Serviced Loan Overview

                          WBCMT 2007-C30

As of the October 2009 remittance report, 12 loans
($157.3 million, 2.0%) in the WBCMT 2007-C30 pool are with the
special servicer, CWCapital Asset Management LLC.  The payment
status of the loans are: one is in foreclosure ($7.4 million,
0.1%), seven are more than 90 days delinquent ($77.9 million,
1.0%), and one is 60 days delinquent ($5.6 million, 0.1%).  Eight
of the specially serviced loans have appraisal reduction amounts
in effect totaling $30.1 million.  All of the specially serviced
loans have balances that are less than 0.5% of the total pool
balance.

Four additional loans ($42.7 million, 0.5%) were transferred to
the special servicer after the October trustee remittance report
date due.

The loans with the special servicer range in size from 0.1% to
0.5% of the pool balance.  Standard & Poor's estimated losses for
10 ($94.3 million, 1.2%) of the 16 loans, and arrived at loss
severities ranging from 18.3% to 71.2%, resulting in an aggregate
loss of 0.5% of the pool balance.  S&P based its loss estimations
on data obtained from the special servicer, including MAI (Member
of the Appraisal Institute) appraisal values.

                           ML-CFC 2007-5

As of the October 2009 remittance report, eight loans
($87.5 million, 2.0%) in the ML-CFC 2007-5 pool are with the
special servicer, CWCapital Asset Management LLC.  The payment
status of the loans are: seven are more than 90 days delinquent
($71.9 million, 1.6%) and one is 30 days delinquent
($15.6 million, 0.4%).  Three of the specially serviced loans have
ARAs in effect totaling $19.3 million.  All of the specially
serviced loans have balances that are less than 0.6% of the total
pool balance.

Subsequent to the October remittance report date, two additional
loans, the Chantilly Residence Oxford loan ($20.3 million, 0.5%)
and the Sedona Retail loan ($9.2 million, 0.2%), were transferred
to the special servicer due to imminent default.  The reported DSC
for the Chantilly Residence Oxford loan for the six months ended
June 30, 2009, was 1.13x.  The reported DSC for the Sedona Retail
loan for year-end 2008 was 1.80x.  In addition, one of the
specially serviced loans, the Paramus Plaza loan ($23.7 million,
0.5%), was returned to the master servicer as a corrected mortgage
on Oct. 20, 2009.

The loans with the special servicer range in size from 0.1% to
0.5% of the pool balance.  Standard & Poor's estimated losses for
six ($48.1 million, 1.1%) of the nine loans, to arrive at loss
severities ranging from 20.8% to 58.7%, resulting in an aggregate
loss of 0.4% of the pool balance.

                     Summary of Top 10 Loans

                      WBCMT 2007-C30 TOP 10

The top 10 exposures in WBCMT 2007-C30 have an aggregate
outstanding balance of $4.11 billion (52.0%).  Using servicer-
reported numbers, S&P calculated a weighted average DSC of 0.93x
for the top 10 loans.  Six of the top 10 loans ($3.0 billion,
38.3%) appear on the master servicer's watchlist including the
ST/PCV loan ($1.5 billion, 19.0%).  S&P's adjusted DSC and LTV for
the top 10 loans, excluding the ST/PCV loan, are 1.03x and 157.1%,
respectively.  Two of the other top 10 loans on the watchlist are
discussed below.

The Five Times Square loan is the second-largest loan in the pool
and appears on the master servicer's watchlist due to low DSC.
The loan is current and has a trust balance of $536.0 million
(6.8%).  The loan is secured by a 1.1-million-sq.-ft. New York
City office property built in 2002.  The DSC for the six months
ended June 30, 2009, was 0.98x, and the year-end 2008 DSC was
0.96x.  At issuance, the DSC for this loan was 1.11x.

The 350 Park Avenue loan is the third-largest loan in the pool and
appears on the master servicer's watchlist due to low DSC.  The
loan is current and has a trust balance of $430.0 million (5.5%).
The loan is secured by a 538,424-sq.-ft. New York City office
property built in 1960.  The DSC for year-end 2008 was 0.68x, down
from 1.21x at issuance.

                       ML-CFC 2007-5 TOP 10

The top 10 exposures in ML-CFC 2007-5 have an aggregate
outstanding balance of $1.56 billion (35.8%).  Using servicer-
reported numbers, S&P calculated a weighted average DSC of 1.16x
for the top 10 loans.  Three of the top 10 loans ($991.1 million,
22.7%) appear on the master servicers' watchlists including the
ST/PCV loan ($800.0 million, 18.3%).  S&P's adjusted DSC and LTV
for the top 10 loans, excluding the ST/PCV loan, are 1.42x and
119.8%, respectively.  The other two top 10 loans on the watchlist
are discussed below.

The Hotel Gansevoort loan is the third-largest loan in the pool
and appears on the master servicers' watchlist due to low DSC.
The loan is current and has a trust balance of $124.1 million
(2.8%).  The loan is secured by a 187-room, full-service hotel in
New York City.  The DSC for the six months ending June 30, 2009,
was 0.84x, and the year-end 2008 DSC was 2.01x.  At issuance, the
DSC for this loan was 1.49x.

The HSA Memphis Industrial Portfolio loan is the sixth-largest
loan in the pool and appears on the master servicer's watchlist
due to low DSC.  The trust balance is $67.0 million (1.5%) and is
secured by 15 cross-collateralized and cross-defaulted office,
flex, and industrial warehouse buildings totaling 1,586,544 sq.
ft. in Memphis, Tenn.  The DSC for the six months ending June 30,
2009, was 1.03x, and the average occupancy was 80.9%, down from
1.21x and 89.4% at year-end 2008.

                          WBCMT 2007-C31

S&P last reviewed this transaction in September 2009.  The rating
actions on this transaction reflect S&P's revised ST/PCV valuation
following the recent court ruling.  The revised valuation prompted
S&P's loss estimate for ST/PCV to increase to 1.65% of the total
pool balance from 1.03% in September.

      Ratings Lowered And Removed From Creditwatch Negative

              Wachovia Bank Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2007-C30

                 Rating
                 ------
      Class     To     From           Credit enhancement (%)
      -----     --     ----           ----------------------
      A-5       BBB    AAA/Watch Neg                30.05
      A-1A      BBB    AAA/Watch Neg                30.05
      A-M       BB     AAA/Watch Neg                20.04
      A-MFL     BB     AAA/Watch Neg                20.04
      A-J       B      AAA/Watch Neg                11.52
      B         B-     AA+/Watch Neg                10.89
      C         B-     AA/Watch Neg                  9.89
      D         CCC+   AA-/Watch Neg                 9.02
      E         CCC    A+/Watch Neg                  8.27
      F         CCC-   A-/Watch Neg                  7.39
      G         CCC-   BBB+/Watch Neg                6.14
      H         CCC-   BBB/Watch Neg                 5.13
      J         CCC-   BBB-/Watch Neg                4.01
      K         CCC-   BB+/Watch Neg                 3.01
      L         CCC-   BB/Watch Neg                  2.50
      M         CCC-   B+/Watch Neg                  2.25
      N         CCC-   B/Watch Neg                   1.88

             ML-CFC Commercial Mortgage Trust 2007-5
          Commercial mortgage pass-through certificates

                 Rating
                 ------
      Class     To     From           Credit enhancement (%)
      -----     --     ----           ----------------------
      A-1A      A      AAA/Watch Neg                30.23
      A-4       A      AAA/Watch Neg                30.23
      A-4FL     A      AAA/Watch Neg                30.23
      AM        BBB-   AAA/Watch Neg                20.11
      AM-FL     BBB-   AAA/Watch Neg                20.11
      AJ        B+     AAA/Watch Neg                11.25
      AJ-FL     B+     AAA/Watch Neg                11.25
      B         B      AA/Watch Neg                  9.48
      C         B-     AA-/Watch Neg                 8.72
      D         CCC+   A-/Watch Neg                  6.95
      E         CCC    BBB+/Watch Neg                6.07
      F         CCC-   BBB/Watch Neg                 4.80
      G         CCC-   BBB-/Watch Neg                3.67
      H         CCC-   BB/Watch Neg                  2.53
      J         CCC-   B+/Watch Neg                  2.15
      K         CCC-   B/Watch Neg                   1.89
      L         CCC-   B-/Watch Neg                  1.64
      M         CCC-   CCC+/Watch Neg                1.39
      N         CCC-   CCC/Watch Neg                 1.26

                          Ratings Lowered

              Wachovia Bank Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2007-C31

                 Rating
                 ------
      Class     To     From           Credit enhancement (%)
      -----     --     ----           ----------------------
      L         CCC    CCC+                          2.76
      M         CCC    CCC+                          2.51
      N         CCC-   CCC                           2.14

      Rating Affirmed And Removed From Creditwatch Negative

             ML-CFC Commercial Mortgage Trust 2007-5
          Commercial mortgage pass-through certificates

                 Rating
                 ------
      Class     To     From           Credit enhancement (%)
      -----     --     ----           ----------------------
      P         CCC-   CCC-/Watch Neg                1.01

                         Ratings Affirmed

              Wachovia Bank Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2007-C30

            Class     Rating    Credit enhancement (%)
            -----     ------    ----------------------
            A-1       AAA                        30.05
            A-2       AAA                        30.05
            A-3       AAA                        30.05
            A-4       AAA                        30.05
            A-PB      AAA                        30.05
            X-P       AAA                          N/A
            X-C       AAA                          N/A
            X-W       AAA                          N/A

             ML-CFC Commercial Mortgage Trust 2007-5
          Commercial mortgage pass-through certificates

            Class     Rating    Credit enhancement (%)
            -----     ------    ----------------------
            A-1       AAA                        30.23
            A-2       AAA                        30.23
            A-2FL     AAA                        30.23
            A-3       AAA                        30.23
            A-SB      AAA                        30.23
            X         AAA                          N/A

              Wachovia Bank Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2007-C31

            Class     Rating    Credit enhancement (%)
            -----     ------    ----------------------
            A-1       AAA                        30.16
            A-2       AAA                        30.16
            A-3       AAA                        30.16
            A-PB      AAA                        30.16
            A-4       BBB+                       30.16
            A-5       BBB+                       30.16
            A-5FL     BBB+                       30.16
            A-1A      BBB+                       30.16
            A-M       BB+                        20.11
            A-J       B+                         12.19
            B         B+                         11.56
            C         B+                         10.31
            D         B                           9.05
            E         B                           8.55
            F         B                           7.67
            G         B-                          6.66
            H         B-                          5.28
            J         B-                          4.40
            K         CCC+                        3.27
            IO        AAA                          N/A

                      N/A -- Not applicable.


MORGAN STANLEY: Moody's Reverses Rating Actions on $200 Mil. Notes
------------------------------------------------------------------
Moody's Investors Service announced that it has reversed the
rating action announced on October 30, 2009, 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, Upgraded to Ba3, previously on October 30, 2009
     Downgraded to B2.

Moody's explained that the reversal of this rating action is due
to an error in the trustee report, which misidentified one of the
reference entities in the portfolio, Pacific Gas and Electric
Company (rated A3 for senior unsecured debt), as Residential
Capital, LLC (rated C for senior unsecured debt).  Moody's
consideration of this erroneous information led to the rating
downgrade announced on October 30th.  The trustee subsequently
made corrections to its report and posted the corrected trustee
report on its website on November 3, 2009.  As a result of this
correction, the 10 year weighted average rating factor of the
portfolio, not adjusted with forward looking measures, has reduced
from 575 to 474, equivalent to an average rating of the current
portfolio of Baa2/Baa3.  The portfolio continues to have the
highest industry concentrations in Banking (10%), Oil and Gas
(10%), Sovereign and Public Finance (10%) and Telecommunications
(9%).


MORGAN STANLEY: S&P Downgrades Ratings on 14 2005-IQ10 Securities
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 14
classes of commercial mortgage-backed securities from Morgan
Stanley Capital I Trust 2005-IQ10 and removed them from
CreditWatch with negative implications.  In addition, S&P affirmed
its ratings on 12 classes from the same transaction and removed
four of them from CreditWatch with negative implications.

The ratings actions 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 these actions.  The downgrades of the mezzanine and
subordinate classes also reflect credit support erosion S&P
anticipates will occur upon the eventual resolution of the
specially serviced loans, as well as S&P's considerations with
respect to one loan, which S&P has determined to be 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, excluding the loans that S&P
stressed due to credit considerations, Standard & Poor's
calculated an adjusted debt service coverage of 1.60x and a loan-
to-value ratio of 92.6%.  S&P further stressed the loans' cash
flows under S&P's 'AAA' scenario to yield a weighted average DSC
of 0.91x and an LTV of 105.8%.  The implied defaults and loss
severity under the 'AAA' scenario were 59.4% and 32.9%,
respectively.  The DSC and LTV calculations excluded three
specially serviced loans ($58.2 million, 3.9%) and one credit-
impaired loan ($3.3 million, 0.2%).  S&P separately estimated
losses for these loans, which are included in the 'AAA' scenario
implied default and loss figures.  S&P also excluded 74
cooperative apartment loans ($134.2 million, 9.3%), as they did
not default under the 'AAA' scenario due to extremely low
leverage.

The affirmations of the ratings on the principal and interest
certificates reflect subordination levels that are consistent with
the outstanding ratings.  S&P affirmed the ratings on the X1, X2,
and XY 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 IO criteria, which may affect
outstanding ratings, including the ratings on the IO certificates
S&P affirmed.

                      Credit Considerations

Three loans ($58.2 million, 3.9%) in the pool, including the 10th-
largest exposure in the pool, are with the special servicer, J.E.
Robert Co. Inc.  Two of these loans ($23.1 million, 1.6%) are more
than 90 days delinquent, and one ($35.1 million, 2.4%) is less
than 30 days delinquent.

The Cortana Mall loan ($35.1 million, 2.4%) is the 10th-largest
loan in the pool and is secured by 349,646 sq. ft. of a
1.4 million-sq.-ft. regional mall in Baton Rouge, La.  The loan
was transferred to JER on Aug. 21, 2009, due to imminent default.
As of Aug. 1, 2009, the property was 85.7% occupied with a
reported DSC of 1.02x as of Dec. 31, 2008.  However, the in-line
space, which constitutes the loan's collateral, was 47.0%
occupied.  Standard & Poor's anticipates a significant loss upon
the resolution of this loan.

The remaining two specially serviced loans account for 1.1% and
0.4% of the pool balance, respectively.

There is also one loan ($3.3 million, 0.2%) that S&P determined to
be credit-impaired.  The Rainier Manor Apartments loan is secured
by a 104-unit multifamily complex in Mt. Rainier, Md.  As of
Dec. 31, 2008, the property was 89% occupied with a 1.47x DSC.
However, structural problems requiring immediate repairs appear to
be affecting the property.  S&P believes that the extent of these
repairs exceeds the borrower's financial resources.  Consequently,
S&P has determined this loan to be at an increased risk of
default.

                        Transaction Summary

As of the October 2009 remittance report, the aggregate trust
balance was $1.48 billion, which represents 95.8% of the aggregate
trust balance at issuance.  There are 207 loans in the pool, down
from 211 at issuance.  The master servicer for the transaction is
Capmark Finance Inc., except with respect to the cooperative
apartment loans, for which the master servicer is NCB FSB.
Capmark Financial Group Inc., the master servicer's parent, filed
for Chapter 11 bankruptcy protection on Oct. 25, 2009.  Capmark
remains on S&P's Select Servicer List.  If S&P remove Capmark from
its Select Servicer List at some point in the future and the
servicer for the transaction is not replaced with an approved
master servicer, S&P may take rating actions on this transaction.
It is also possible that fees and expenses associated with the
bankruptcy filing could affect the trust and could also prompt us
to take future rating actions.

The master servicers provided financial information for 99.3% of
the pool, and 95.2% of the servicer-provided information was full-
year 2008 or interim 2009 data.  Excluding the cooperative
apartment loans, S&P calculated a weighted average DSC of 1.60x
for the pool based on the reported figures.  S&P's adjusted DSC
and LTV were 1.60x and 92.6%, respectively.  S&P's adjusted
figures exclude three specially serviced loans and one credit-
impaired loan.  S&P estimated losses separately for these loans.
Based on the servicer-reported DSC figures, S&P calculated a
weighted average DSC of 1.01x for three of the four loans.  Data
was not reported for one loan.  To date, the transaction has not
realized any losses.  Forty-eight loans ($266.6 million, 18.0%)
are on the master servicer's watchlist, including two of the top
10 loans.  Twenty-nine loans ($231.8 million, 15.7%) have a
reported DSC of less than 1.10x, and 20 of these loans
($104.8 million, 7.1%) have a reported DSC of less than 1.0x.

                     Summary of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$707.8 million (47.8%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.63x for the top 10 loans.
S&P's adjusted DSC and LTV for the top 10 loans were 1.61x and
95.6%, respectively.  These figures exclude the 10th-largest loan
in the pool ($35.1 million, 2.4%), which is with the special
servicer and described above.  The fourth- and eighth-largest
loans in the pool ($109.9 million, 7.4%) appear on the master
servicer's watchlist.

The 69th Street Philadelphia loan ($62.9 million, 4.3%) is the
fourth-largest loan in the pool and is secured by buildings that
constitute 665,531 sq. ft. of retail space in Upper Darby, Pa.
The loan appears on the watchlist due to low DSC, which resulted
from increased expenses and a decline in occupancy.  Occupancy was
75.5% as of Sept. 1, 2009, and DSC was 1.10x as of Dec. 31, 2008.

The Key West Hilton loan ($46.9 million, 3.2%) is the eighth-
largest loan in the pool and is secured by a 178-room full-service
resort in Key West, Fla.  The property is currently operating
under the Westin brand.  The loan appears on the watchlist due to
a decrease in DSC.  As of the 12 months ended June 30, 2009, the
property was 68.1% occupied with a 1.27x DSC.

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

             Morgan Stanley Capital I Trust 2005-IQ10
          Commercial mortgage pass-through certificates

                   Rating
                   ------
    Class  To              From          Credit enhancement (%)
    -----  --              ----          ----------------------
    A-J    A-              AAA/Watch Neg                  12.14
    B      BBB+            AA/Watch Neg                   10.05
    C      BBB             AA-/Watch Neg                   9.27
    D      BBB-            A/Watch Neg                     7.57
    E      BB+             A-/Watch Neg                    6.66
    F      BB              BBB+/Watch Neg                  5.35
    G      BB-             BBB/Watch Neg                   4.57
    H      B               BB+/Watch Neg                   3.39
    J      B-              BB/Watch Neg                    3.13
    K      CCC             B+/Watch Neg                    2.61
    L      CCC-            B/Watch Neg                     2.22
    M      CCC-            B-/Watch Neg                    1.83
    N      CCC-            CCC+/Watch Neg                  1.57
    O      CCC-            CCC/Watch Neg                   1.17

      Ratings Affirmed And Removed From Creditwatch Negative

             Morgan Stanley Capital I Trust 2005-IQ10
          Commercial mortgage pass-through certificates

                   Rating
                   ------
    Class  To              From          Credit enhancement (%)
    -----  --              ----          ----------------------
    A-1A   AAA             AAA/Watch Neg                  20.89
    A-AB   AAA             AAA/Watch Neg                  20.89
    A-4A   AAA             AAA/Watch Neg                  30.77
    A-4B   AAA             AAA/Watch Neg                  20.89

                         Ratings Affirmed

             Morgan Stanley Capital I Trust 2005-IQ10
          Commercial mortgage pass-through certificates

            Class     Rating     Credit enhancement (%)
            -----     ------     ----------------------
            A-1       AAA                         20.89
            A-2       AAA                         20.89
            A-3-1     AAA                         20.89
            A-3-1FL   AAA                         20.89
            A-3-2     AAA                         20.89
            X1        AAA                           N/A
            X2        AAA                           N/A
            XY        AAA                           N/A


MORGAN STANLEY: S&P Downgrades Ratings on 15 2006-IQ11 Securities
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 15
classes of commercial mortgage-backed securities from Morgan
Stanley Capital I Trust 2006-IQ11, two of which S&P set to 'D',
and removed them from CreditWatch with negative implications.  In
addition, S&P affirmed its ratings on seven classes from the same
transaction and removed two of these classes from CreditWatch with
negative implications.

The downgrades follow S&P's 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.  The downgrades of classes N and O to
'D' reflect the recurring interest shortfalls that resulted
primarily from appraisal subordinate entitlement reduction amounts
related to five assets that are currently with the special
servicer, LNR Partners Inc.  S&P expects the interest shortfalls
to continue for the foreseeable future.  Classes N and O have
experienced cumulative interest shortfalls of $84,241 and $28,076,
respectively.

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
(DSC) of 1.59x and a loan-to-value ratio of 96.8%.  S&P further
stressed the loans' cash flows under S&P's 'AAA' scenario to yield
a weighted average DSC of 1.02x and an LTV of 130.0%.  The implied
defaults and loss severity under the 'AAA' scenario were 61.9% and
36.2%, respectively.  All of the DSC and LTV calculations S&P
noted above exclude eight of the 10 specially serviced assets
($53.8 million, 3.4%) and 66 cooperative loans ($184.0 million,
11.8%).  S&P separately estimated losses for the eight specially
serviced assets, which S&P included in its 'AAA' scenario implied
default and loss figures.  S&P excluded the cooperative apartment
loans, as they did not default under the 'AAA' scenario due to
extremely low leverage.

The affirmations of the ratings on the principal and interest
certificates reflect subordination levels that are consistent with
the outstanding ratings.  S&P affirmed its ratings on the class X
and X-Y 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 S&P expect.

                      Credit Considerations

As of the October 2009 remittance report, 10 assets
($115.0 million, 7.3%) in the pool were with LNR, including one of
the top 10 loans, which S&P discuss in further detail below.  None
of the 66 cooperative apartment loans are with the special
servicer.  The specially serviced loans by payment status are: one
is real estate owned (REO) ($1.8 million, 0.1%); four are in
foreclosure ($39.1 million, 2.5%); four are more than 90 days
delinquent ($18.3 million, 1.2%); and one is 60 days delinquent
($2.4 million, 0.1%).  Five ($36.5 million, 2.3%) of the specially
serviced loans have appraisal reduction amounts in effect totaling
$19.1 million.

The LeNature's Headquarters loan is the fifth-largest loan in the
pool and the largest loan with the special servicer.  The loan has
a total exposure of $56.1 million (3.6%) and is secured by a
500,000-sq.-ft. warehouse distribution facility in Phoenix, Ariz.
The loan was transferred to the special servicer on Nov. 9, 2006,
because LeNature, the sole tenant, filed for bankruptcy and
subsequently vacated the space.  A data center operator has signed
a new triple-net master lease for 100% of the property.  LNR
continues to monitor the loan.

The remaining specially serviced loans have balances that
individually represent less than 1.0% of the total pool balance.

                       Transaction Summary

As of the October 2009 remittance report, the collateral pool
balance was $1.57 billion, down slightly from $1.62 billion at
issuance.  There are 233 loans in the pool, one less than at
issuance, due to a loan payoff ($2.8 million).  The master
servicers for the transaction, Wells Fargo Bank N.A. (Wells Fargo)
and National Consumer Cooperative Bank, provided financial
information for 95.9% of the pool; 88.7% of the financial
information was full-year 2008 data or interim-2009 data.  S&P
calculated a weighted average DSC of 1.62x for the pool based on
the reported figures excluding 66 cooperative loans.  S&P's
adjusted DSC and LTV were 1.59x and 96.8%, respectively.  S&P's
adjusted DSC and LTV figures also exclude the 66 cooperative loans
($184.0 million, 11.8%) and eight of the 10 specially serviced
assets ($53.8 million 3.4%).  S&P separately estimated losses for
the eight specially serviced assets, which are included in the
'AAA' scenario implied default and loss figures.  Wells Fargo
provided DSC figures for seven of the eight assets, and based on
these figures, S&P calculated a weighted average DSC of 1.22x.
The transaction has not experienced any principal losses to date.
Thirty-one loans ($126.4 million, 8.1%) are on the master
servicers' watchlists.  Twenty-eight loans ($111.3 million, 7.1%)
have a reported DSC below 1.10x, and 22 of these loans
($88.0 million, 5.6%) have a reported DSC of less than 1.0x.

                     Summary of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$560.5 million (35.8%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.84x for the top 10 loans.
S&P's adjusted DSC and LTV for the top 10 loans are 1.72x and
101.4%, respectively.  These calculated numbers exclude the fifth-
largest loan in the pool ($56.1 million total exposure, 3.6%),
which is with LNR and has no financials provided.  These
calculated numbers also exclude the ninth-largest loan in the pool
($23.0 million, 1.5%), which is a cooperative loan.

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

      Ratings Lowered And Removed From Creditwatch Negative

            Morgan Stanley Capital I Trust 2006-IQ11
         Commercial mortgage pass-through certificates

                Rating
                ------
    Class     To      From            Credit enhancement (%)
    -----     --      ----            ----------------------
    A-M       AA-     AAA/Watch Neg                    20.65
    A-J       BBB+    AAA/Watch Neg                    11.23
    B         BBB     AA/Watch Neg                      9.29
    C         BBB-    AA-/Watch Neg                     8.52
    D         BB+     A-/Watch Neg                      7.10
    E         BB      BBB+/Watch Neg                    6.07
    F         BB-     BBB/Watch Neg                     5.16
    G         B+      BB+/Watch Neg                     4.00
    H         B-      BB-/Watch Neg                     3.10
    J         CCC+    B/Watch Neg                       2.58
    K         CCC     B-/Watch Neg                      2.32
    L         CCC-    CCC+/Watch Neg                    2.06
    M         CCC-    CCC/Watch Neg                     1.68
    N         D       CCC-/Watch Neg                    1.29
    O         D       CCC-/Watch Neg                    1.16

     Ratings Affirmed And Removed From Creditwatch Negative

             Morgan Stanley Capital I Trust 2006-IQ11
          Commercial mortgage pass-through certificates

                Rating
                ------
    Class     To      From            Credit enhancement (%)
    -----     --      ----            ----------------------
    A-4       AAA     AAA/Watch Neg                    30.97
    A-1A      AAA     AAA/Watch Neg                    30.97

                        Ratings Affirmed

             Morgan Stanley Capital I Trust 2006-IQ11
          Commercial mortgage pass-through certificates

          Class      Rating      Credit enhancement (%)
          -----      ------      ----------------------
          A-1        AAA                          30.97
          A-2        AAA                          30.97
          A-3        AAA                          30.97
          X          AAA                            N/A
          X-Y        AAA                            N/A

                       N/A - Not applicable.


MORGAN STANLEY: S&P Downgrades Ratings on 14 2005-TOP17 Securities
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 14
classes of commercial mortgage-backed securities from Morgan
Stanley Capital I Trust 2005-TOP17 and removed them from
CreditWatch with negative implications.  In addition, S&P affirmed
its ratings on six classes from the same transaction and removed
one of the affirmed ratings from CreditWatch with negative
implications.

The downgrades reflect S&P's 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 mezzanine and
subordinate classes also reflect credit support erosion S&P
anticipate will occur upon the eventual resolution of the
transaction's two specially serviced assets.  S&P's analysis
included a review of the credit characteristics of all of the
assets in the pool.  Using servicer-provided financial
information, S&P calculated an adjusted debt service coverage
(DSC) of 2.15x and a loan-to-value ratio of 75.7%.  S&P further
stressed the loans' cash flows under its 'AAA' scenario to yield a
weighted average DSC of 1.41x and an LTV of 100.9%.  The implied
defaults and loss severity under the 'AAA' scenario were 38.1% and
25.3%, respectively.  All of the DSC and LTV calculations noted
above exclude the two ($7.8 million, 0.8%) specially serviced
assets, the four ($74.2 million, 7.9%) defeased loans, and one
($8.5 million, 0.9%) cooperative apartment loan.  S&P estimated
losses for the two specially serviced assets separately and
included them in the 'AAA' scenario implied default and loss
figures.

The affirmation of the ratings on the principal and interest
certificates reflects subordination levels that are consistent
with the outstanding ratings.  S&P affirmed its ratings on the
class X-1 and X-2 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 finalize its
criteria review, S&P may revise its current IO criteria, which may
affect outstanding ratings, including the ratings on the IO
certificates S&P affirmed.

                          Credit Concerns

As of the October 2009 remittance report, two loans ($7.8 million,
0.8%) in the pool are with the special servicer, Centerline
Servicing Inc. Both loans are 90-plus days delinquent.  The total
appraisal reduction amount for the two assets is $5.8 million.
The larger of the two loans with the special servicer is the
Butterfield Plaza Shopping Center loan, a retail property located
in Benson, Ariz., with a trust balance of $6.0 million (0.6%).
The loan was transferred to the special servicer on Feb. 4, 2009.
Standard & Poor's anticipates a significant loss upon the eventual
resolution of the asset.  The second specially serviced loan is
the Designer Doors Warehouse loan, which has a trust balance of
$1.8 million (0.2%).  The loan was transferred to the special
servicer on March 3, 2009, for payment default.  Standard & Poor's
anticipates a significant loss upon the eventual resolution
of the asset.

                        Transaction Summary

As of the October 2009 remittance report, the collateral pool
had an aggregate trust balance of $938.5 million, down from
$1.27 billion at issuance.  The pool includes 110 loans, unchanged
since issuance.  The master servicer for the transaction is Wells
Fargo Commercial Mortgage Servicing, which provided financial
information for 99.2% of the nondefeased loans in the pool.  98.8%
of the servicer-provided information was full-year 2008 data.  S&P
calculated a weighted average DSC of 2.32x for the pool based on
the reported figures.  S&P's adjusted DSC and LTV were 2.15x and
75.7%, respectively.  The master servicer reported a watchlist of
25 loans ($177.1 million, 18.9%), including three of the top 10
loans, which S&P discuss in detail below.  Four loans
($14.4 million, 1.5%) in the pool have a reported DSC below 1.10x,
and one loan ($2.0 million, 0.2%) has a reported DSC of less than
1.00x.  Six loans ($42.8 million, 4.6%) are scheduled to mature in
December 2009.

                     Summary of Top 10 Loans

The top 10 loan exposures secured by real estate have an aggregate
outstanding balance of $412.1 million (43.9%).  Using servicer-
reported numbers, S&P calculated a weighted average DSC of 2.60x
for the top 10 loans.  S&P's adjusted DSC and LTV for the top 10
loans are 2.26x and 80.7%, respectively.  Three ($76.7 million,
8.2%) of the top 10 loans appear on the master servicer's
watchlist.

The Travis Tower loan is the fifth-largest loan in the pool and
the largest loan on the master servicer's watchlist.  The loan has
a trust balance of $35.0 million (3.7%) and is secured by a
507,247-sq.-ft. 21-story office property in downtown Houston.  The
asset is current in its payments.  The loan appears on the
watchlist due to low occupancy at the collateral property, which
was reported at 38.0% as of June 2009.  Occupancy is low because
the former largest tenant, CenterPoint Energy, vacated the
property.  CenterPoint Energy represented 55.2% of the net
rentable area (NRA).  The master servicer's watchlist comments
indicate that there has been interest in the former CenterPoint
Energy space.  In addition, the loan has a $4.4 million tenant
improvement and leasing commission reserve in place, and the loan
exposure is $69 per sq. ft.

The Maritime Hotel loan is the seventh-largest loan in the pool
and the second-largest loan on the master servicer's watchlist.
The loan has a trust balance of $25.0 million (2.7%) and is
secured by a 125-room boutique hotel in New York.  The asset
appears on the watchlist due to low DSC.  The year-to-date March
2009 DSC was 1.19x, which reflects a decline from the year-to-date
March 2008 DSC of 5.45x.  The master servicer's watchlist comments
attribute the performance decline to the economic downturn's
effect on the tourism industry.

The Azalea Square loan is the ninth-largest loan in the pool and
the third-largest loan on the master servicer's watchlist.  The
loan has a trust balance of $16.5 million (1.8%) and is secured by
a 181,942-sq.-ft. retail property in Summerville, S.C.  The asset
appears on the watchlist because of its impending Dec. 1, 2009,
maturity date.  The reported DSC as of year-end 2008 was 2.53x, up
slightly from 2.46x at issuance.  Occupancy was reported at 86.0%
as of March 2009.

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

      Ratings Lowered And Removed From Creditwatch Negative

             Morgan Stanley Capital I Trust 2005-TOP17
           Commercial mortgage pass-through certificates

                 Rating
                 ------
        Class  To     From           Credit enhancement (%)
        -----  --     ----           ----------------------
        A-J    AA+    AAA/Watch Neg                    9.80
        B      A+     AA/Watch Neg                     7.58
        C      A      AA-/Watch Neg                    6.79
        D      A-     A/Watch Neg                      5.62
        E      BBB+   A-/Watch Neg                     4.57
        F      BBB    BBB+/Watch Neg                   3.92
        G      BB+    BBB/Watch Neg                    3.14
        H      BB-    BBB-/Watch Neg                   2.35
        J      B+     BB+/Watch Neg                    2.09
        K      B      BB/Watch Neg                     1.70
        L      CCC+   BB-/Watch Neg                    1.31
        M      CCC    B+/Watch Neg                     1.18
        N      CCC-   B/Watch Neg                      1.05
        O      CCC-   B-/Watch Neg                     0.78

      Rating Affirmed And Removed From Creditwatch Negative

             Morgan Stanley Capital I Trust 2005-TOP17
           Commercial mortgage pass-through certificates

                 Rating
                 ------
        Class  To     From           Credit enhancement (%)
        -----  --     ----           ----------------------
        A-5    AAA    AAA/Watch Neg                   17.77

                         Ratings Affirmed

             Morgan Stanley Capital I Trust 2005-TOP17
           Commercial mortgage pass-through certificates

        Class  Rating                Credit enhancement (%)
        -----  ------                ----------------------
        A-3    AAA                                    17.77
        A-4    AAA                                    17.77
        A-AB   AAA                                    17.77
        X-1    AAA                                      N/A
        X-2    AAA                                      N/A

                       N/A - Not applicable.


PACIFICA CDO: 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 Pacifica CDO II, Ltd., a
collateralized loan obligation issued in July 2003 that is backed
primarily by a portfolio of senior secured loans:

  -- US$9,000,000 Class C--1 Floating Rate Notes Due 2015 (current
     balance of $9,202,246), Downgraded to Caa3; previously on
     June 17, 2009 Downgraded to Caa2;

  -- US$3,000,000 Class C--2 Fixed Rate Notes Due 2015 (current
     balance of $3,105,507), Downgraded to Caa3; previously on
     June 17, 2009 Downgraded to Caa2.

According to Moody's, the rating actions taken are a result of
further credit deterioration of the underlying portfolio since the
last rating actions taken on June 17, 2009.  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 B, Class C and Class D
overcollateralization tests.  In particular, the weighted average
rating factor has increased since the last rating action and is
currently 3186 as of the last trustee report, dated November 2,
2009, versus 2912 as of the June 1, 2009 trustee report.  Based on
the same November report, defaulted securities currently held in
the portfolio total approximately $20 million, accounting for
roughly 8% of the collateral balance, as compared to $14 million
in June, which accounted for about 5% of the collateral balance.
Additionally, securities rated Caa1/CCC+ or lower make up
approximately 29.2% of the underlying portfolio in November
compared to 19.8% in the June trustee report.  Finally, since
June, interest payments on the Class C-1 and Class C-2 notes have
also begun to defer as a result of the failure of the Class B
Overcollateralization Test.  The Class B overcollateralization
ratio is reported at 100.8% based on the November trustee report
versus a test level of 104.8%, and is also below the
overcollateralization ratio of 105.6% reported in June.

On June 17, 2009, Moody's downgraded the Class C-1 and C-2 notes
from B1 to Caa2 as a result of the application of revised and
updated key modeling assumptions as well as the deterioration in
the credit quality of the transaction's underlying portfolio.


POTOMAC LIFE: Moody's Withdraws Ratings on Insurance Securities
---------------------------------------------------------------
Moody's Investors Service has withdrawn the ratings of Potomac
life insurance-linked securities insured by Ambac Assurance
Corporation as detailed below.  These ratings were withdrawn,
consistent with Moody's policy for rating insured notes when the
financial guarantor is downgraded to below investment grade and
there is no published underlying rating.  Moody's approach to
rating insured transactions is outlined in Moody's Special Comment
entitled "Assignment of Wrapped Ratings When Financial Guarantor
Falls Below Investment Grade" (May, 2008).

Notes Insured By Ambac Assurance Corporation (which is rated Caa2
for insurance financial strength, developing outlook):

First British American Reinsurance Company:

  -- $540 million of Potomac Trust Capital I (through XI) Class A
     Money Market Securities, Series 2004-I (through XI) at Baa1

The last rating action on the Ambac-insured notes of FBARC was on
April 13, 2009, when the rating of Ambac was downgraded to Ba3
from Baa1, and the Baa1 insured notes were placed under review
direction uncertain.

FBARC's underlying ratings were assigned by evaluating factors
believed to be relevant to the credit profile of the notes 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.

FBARC is a special purpose reinsurer domiciled in South Carolina
for the purpose of funding excess reserve requirements associated
with distinct blocks of business ceded by Banner Life Insurance
Company and William Penn Life Insurance Company of New York, which
are ultimately wholly-owned subsidiaries of Legal & General Group,
Plc. (A2 senior debt, negative outlook).  The reinsurance
agreement between Banner Life and William Penn and the special
purpose reinsurer covers defined blocks of level premium term life
policies subject to the statutory reserve requirements of
Regulation XXX.

Moody's insurance financial strength ratings are opinions of the
ability of insurance companies to punctually pay senior
policyholder claims and obligations.


PPLUS TRUST: Moody's Upgrades Ratings on FMC-1 Certs. to 'Caa1'
---------------------------------------------------------------
Moody's Investors Service announced that it has upgraded these
certificates issued by PPLUS Trust Series FMC-1:

  -- 1,600,000 PPLUS 8.25% Trust Certificates; Upgraded to Caa1;
     Previously on September 18, 2009 Upgraded to Caa2.

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction.  The rating action is a result of the change of the
rating of 7.45% Notes due 2031 issued by Ford Motor Company which
were upgraded to Caa1 by Moody's on November 2, 2009.


PPLUS TRUST: S&P Raises Rating on $40 Mil. Certs. to 'CCC'
----------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on PPLUS
Trust Series FMC-1's $40 million 8.25% pass-through certificates
to 'CCC' from 'CCC-'.

The rating on the certificates is dependent solely on the rating
on the underlying security, Ford Motor Co.'s 7.45% global landmark
securities due July 16, 2031 ('CCC').

The rating action reflects S&P's Nov. 3, 2009, upgrade of the
underlying security to 'CCC' from 'CCC-'.


PREFERREDPLUS TRUST: Moody's Upgrades Ratings on Certs. to 'Caa1'
-----------------------------------------------------------------
Moody's Investors Service announced that it has upgraded these
certificates issued by PREFERREDPLUS Trust Series FRD-1:

  -- 2,000,000 PREFERREDPLUS 7.40% Trust Certificates; Upgraded to
     Caa1; Previously on September 18, 2009 Upgraded to Caa2.

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction.  The rating action is a result of the change of the
rating of 7.40% Debentures due November 1, 2046, issued by Ford
Motor Company which were upgraded to Caa1 by Moody's on
November 2, 2009.


PUBLIC STEERS: S&P Raises Ratings on 1998 F-Z4 Certs. to 'CCC's
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on Public
STEERS Series 1998 F-Z4 Trust's $231.903 million class A and B
certificates to 'CCC' from 'CCC-'.

The ratings on the certificates are dependent solely on the rating
on the underlying security, Ford Motor Co.'s 7.7% debentures due
May 15, 2097 ('CCC').

The rating actions reflect S&P's Nov. 3, 2009, upgrade of the
underlying security to 'CCC' from 'CCC-'.


PREFERREDPLUS TRUST: S&P Raises Rating on $50 Mil. Certs. to 'CCC'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on
PreferredPLUS Trust Series FRD-1's $50 million certificates to
'CCC' from 'CCC-'.

The rating on the certificates is dependent solely on the rating
on the underlying security, Ford Motor Co.'s 7.4% debentures due
Nov. 1, 2046 ('CCC').

The rating action reflects S&P's Nov. 3, 2009, upgrade of the
underlying security to 'CCC' from 'CCC-'.


PUBLIC STEERS: Moody's Lifts Ratings on 1998 F-Z4 Certs. to 'Caa1'
------------------------------------------------------------------
Moody's Investors Service announced that it has upgraded these
certificates issued by Public Steers Series 1998 F-Z4 Trust:

  -- US$106,903,000 Initial Principal Amount Class A Trust
     Certificates; Upgraded to Caa1; previously on September 18,
     2009 Upgraded to Caa2;

  -- US$125,000,000 Principal Amount at Maturity Class B Trust
     Certificates; Upgraded to Caa1; previously on September 18,
     2009 Upgraded to Caa2;

The transaction is a structured note whose ratings are based on
the rating of the Underlying Securities and the legal structure of
the transaction.  The rating action is a result of the change of
the rating of 7.70% Debentures due May 15, 2097, issued by Ford
Motor Company which were upgraded to Caa1 by Moody's on
November 2, 2009.


ROCKALL CLO: 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 Rockall CLO B.V.:

  -- EUR408,250,000 VF-1 Senior Secured Variable Funding Notes due
     2013 (current balance of EUR134,477,353), Downgraded to Aa2;
     previously on October 16, 2008 Aaa Placed Under Review for
     Possible Downgrade;

  -- EUR6,250,000 Class B-1 Second Senior Secured Floating Rate
     Notes due 2013, Downgraded to Ba1; previously on October 16,
     2008 Aa2 Placed Under Review for Possible Downgrade;

  -- EUR12,250,000 Class C-1 Third Senior Secured Floating Rate
     Notes due 2013, Downgraded to Ba2; previously on October 16,
     2008 A2 Placed Under Review for Possible Downgrade;

  -- EUR12,250,000 Class D-1 Forth Senior Secured Floating Rate
     Notes due 2013, Downgraded to Ba3; previously on October 16,
     2008 Baa2 Placed Under Review for Possible Downgrade.

According to Moody's, Rockall CLO B.V. which was issued on
June 28, 2006, is a market value collateralized loan obligation
transaction backed primarily by a portfolio of senior secured
loans.  Moody's explained that the rating action reflected the
revised modeling assumptions and monitoring approach for market
value collateralized loan obligation transactions described in
Moody's report noted below.  The revised, more conservative
volatility and liquidity assumptions that were presented in
Moody's report imply that lower advance rates are now required in
order to achieve the same target rating levels for any given
market value collateralized loan obligation transaction.  Advance
rates that were set at issuance for such transactions prior to the
extreme conditions the market has witnessed since 2007 as was the
case for Rockall CLO are therefore no longer adequate to maintain
existing rating levels.

The rating action also took into consideration a Supplemental
Trust Deed dated as of November 3, 2009 that amended the Master
Trust Deed to revise the Moody's advance rates used in the
transaction's governing documents.  The revised advance rate for
the VF-1 notes is now consistent with an Aa2 target rating; the
revised advance rate for the class B notes is now consistent with
a Ba1 rating, the revised advance rate for the class C notes is
now consistent with a Ba2 rating and the revised advance rate for
the class D notes is now consistent with a Ba3 rating.


ROSEMONT CLO: Fitch Affirms Ratings on Three Classes of Notes
-------------------------------------------------------------
Fitch Ratings has affirmed three and downgraded two classes of
notes issued by Rosemont CLO Ltd./Corp.  A detailed list of rating
actions follows at the end of this press release.

This review was conducted under the framework described in the
report 'Global Structured Finance Rating Criteria'.  Cash flow and
portfolio default modeling were conducted in accordance with
Fitch's 'Global Criteria for Cash Flow Analysis in Corporate CDOs'
and 'Global Rating Criteria for Corporate CDOs'.

The affirmations are the result of the credit enhancement
available to the classes A, B-1, and B-2 notes relative to the
observed and expected performance of the underlying loan
portfolio.  The senior notes have benefited from significant
collateral amortization, as the class A notes have received over
70% of their initial principal balance since the closing date.
The relative priority of the class B-1 and B-2 notes has improved
due to the significant amortization of the class A notes above
them, helping to mitigate the deteriorating performance of the
underlying collateral.

Structural features of the transaction, such as the application of
excess spread to redeem the notes in order of priority should an
overcollateralization test fail, also serve to protect the higher-
priority classes.  Rosemont CLO is currently in compliance with
all coverage tests, although the class D OC test was only passing
at a level of 101.6% versus a trigger of 101.5% as of the Oct. 6,
2009 trustee report.  The calculations of the OC tests do not
incorporate ratings-based principal haircuts, such as an excess
'CCC' adjustment.  In Fitch's opinion, the class D notes would
likely be considered undercollateralized if ratings-based haircuts
were applied.

The downgrades to the classes C and D notes are due to the
collateral deterioration experienced since Fitch's last rating
review in February 2009.  Defaulted assets, excluding those that
the portfolio manager expects to resume cash flows after
restructuring in the near term, currently account for 13.5% of the
portfolio.  This represents a marked increase from 6.3% at Fitch's
last rating review.  Additionally, Fitch considers 27.1% of the
performing portfolio to be rated 'CCC+' or below, up from 18.8% at
the last review.  It is probable that the deteriorated portfolio
performance will lead to some principal impairment for the class D
notes.  Although a degree of credit enhancement remains for the
class C notes, the rapid deterioration of the portfolio and below-
average recovery rates have negatively affected the credit profile
of these notes.

In its review, Fitch analyzed the structure's sensitivity to
ongoing softness in U.S. corporate recoveries.  To accomplish
this, Fitch reduced its average recovery rate assumptions for each
asset type by 30% in one sensitivity scenario and by 50% in a
second sensitivity scenario where explicit Recovery Ratings were
not available.  The class A notes displayed solid performance in
both of these scenarios and have therefore been assigned a Stable
Outlook.  The classes B-1, B-2, and C notes displayed greater
degrees of sensitivity to lower recovery rates.  In addition,
approximately 35% of the underlying portfolio ratings currently
have a Negative Outlook, which may result in additional future
rating volatility.  For these reasons, the classes B-1, B-2, and C
notes have been assigned Negative Outlooks.

The classes A, B-1, B-2, and C notes were each assigned a Loss
Severity rating.  The LS ratings indicate each 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 Fitch's 'Criteria for Structured Finance Loss
Severity Ratings' report.  The LS rating should always be
considered in conjunction with the probability of default
indicated by a class' long-term credit rating.  Fitch does not
assign LS ratings to tranches rated in the 'CCC' to 'C'
categories.

Rosemont CLO is a cash flow collateralized loan obligation that
closed on Jan.  8, 2002 and is managed by Deerfield Capital
Management LLC.  The transaction's reinvestment period ended in
January 2007.  The portfolio is composed of 97.4% senior secured
loans and 2.6% junior secured loans.

Fitch Ratings has taken these rating actions on these notes.
Rating actions include affirmations, downgrades, assignment of
Loss Severity ratings and Rating Outlooks.

  -- $69,013,726 class A notes affirmed at 'AAA/LS3'; Outlook
     Stable;

  -- $18,000,000 class B-1 notes affirmed at 'A/LS3'; Outlook to
     Negative from Stable;

  -- $7,000,000 class B-2 notes affirmed at 'A/LS3'; Outlook to
     Negative from Stable;

  -- $13,200,000 class C notes downgraded to 'B/LS4' from 'BBB+';
     Outlook Negative;

  -- $12,000,000 class D notes downgraded to 'CC' from 'CCC'.


SATURN VENTURES: Fitch Downgrades Ratings on Two Classes of Notes
-----------------------------------------------------------------
Fitch Ratings has downgraded two and affirmed two classes of notes
issued by Saturn Ventures I, Ltd./Inc. as a result of the
continued deterioration in the portfolio.

Since Fitch's last rating action in March 2009, approximately
26.6% of the portfolio has been downgraded a weighted average of
4.7 notches.  Currently, the balance of assets deemed as
defaulted, as per the transaction's governing documents, is equal
to $8.1 million.

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.  Although the credit quality of the
portfolio has deteriorated, the risk to the class A-1 notes has
been mitigated by the sale of defaulted assets.  Prior to the
November 2009 distribution date, the manager sold $26.6 million in
par notional of defaulted securities, recovering $7 million of
principal.  The proceeds were used to pay down the class A-1
notes.  As a result, the credit enhancement available to the class
A-1 notes is consistent with the PCM rating loss rate for the
'AAA' rating.

Similarly, the current credit enhancement level for the class A-2
notes is consistent with the PCM rating loss rates for the 'BB'
rating category.

The class A-1 and class A-2 notes are assigned a Negative Rating
Outlook due to the high concentration of commercial mortgage-
backed securities and residential mortgage-backed securities bonds
in the portfolio, which are expected to continue to face ratings
volatility in the next one to two years.

The classes A-1 and A-2 notes are assigned Loss Severity ratings
of 'LS3'.  The LS ratings indicate each 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-3 notes are downgraded to 'C' from 'CCC' to indicate
Fitch's belief that default is inevitable at or prior to maturity.
In addition to credit deterioration of the portfolio, the
transaction continues to divert portion of the principal proceeds
to pay accrued interest to timely classes, thus reducing the
amount of principal proceeds available to pay down the notes.  The
class B notes are not expected to receive any distributions going
forward.

Saturn I is a static structured finance collateralized debt
obligation that closed on Oct. 29, 2003.  The portfolio is
monitored by Church Tavern Advisors, LLC.  The portfolio is
comprised primarily of CMBS (58.7%), RMBS (17%), real estate
investment trusts (12.1%), and SF CDOs (4.6%) from the 2002 and
2003 vintages.

Fitch has affirmed, downgraded, assigned LS ratings, and revised
Outlooks as indicated:

  -- $60,913,478 class A-1 notes affirmed at 'AAA'; Outlook
     revised to Negative from Stable; assigned 'LS3';

  -- $44,611,659 class A-2 notes downgraded to 'BB' from 'BBB';
     Outlook revised to Negative from Stable; assigned 'LS3';

  -- $23,198,063 class A-3 notes downgraded to 'C' from 'CCC';

  -- $18,817,688 class B notes affirmed at 'C'.


SATURNS TRUST: Moody's Upgrades Ratings on 2003-5 Units to 'Caa1'
-----------------------------------------------------------------
Moody's Investors Service announced that it has upgraded these
units issued by SATURNS Trust No. 2003-5:

  -- 3,001,107 SATURNS Trust No. 2003-5 Units; Upgraded to Caa1;
     Previously on September 18, 2009 Upgraded to Caa2.

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction.  The rating action is a result of the change of the
rating of Ford Motor Company 7.45% debentures due July 16, 2031,
which were upgraded to Caa1 by Moody's on November 2, 2009.


SATURNS TRUST: S&P Raises Rating on $75 Mil. Units to 'CCC'
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on SATURNS
Trust No. 2003-5's $75 million 8.125% units to 'CCC' from 'CCC-'.

The rating on the units is dependent solely on the rating on the
underlying security, Ford Motor Co.'s 7.45% global landmark
securities due July 16, 2031 ('CCC').

The rating action reflects S&P's Nov. 3, 2009, upgrade of the
underlying security to 'CCC' from 'CCC-'.


SEAWALL SPC: S&P Withdraws Ratings on 24 Classes of Notes
---------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 24
classes issued by 24 Seawall SPC transactions.  Four of the
ratings were previously on CreditWatch with negative implications.
All 24 transactions are U.S. synthetic collateralized debt
obligations.

The rating withdrawals follow the repurchase of the notes by the
arranger.

                          Rating Actions

                            Seawall SPC
         $31,062,982 million class AJ floating-rate notes
                        series BACM 2007-2

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BB+

                           Seawall SPC
  $31,062,983 series WBCMT 2007-C33 class AJ floating-rate notes

                                     Rating
                                     ------
       Class                    To             From
       -----                    --             ----
       Notes                    NR             AAA/Watch Neg

                           Seawall SPC
$31.063 Million series MLMT 2007-C1 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BB

                           Seawall SPC
  $31,062,983 series WBCMT 2007-C32 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BB-

                           Seawall SPC
   $31,062,983 series MSC2007-IQ14 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BB-

                           Seawall SPC
  $31,062,983 series WBCMT 2007-C31 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             B+

                           Seawall SPC
    $31,062,983 series MSC2007-T27 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BBB

                           Seawall SPC
  $31,062,982 series LBUBS 2007-C2 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BB-

                           Seawall SPC
       $31 million floating-rate notes series LBCMT 2007-C3

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             B

                           Seawall SPC
   $31,062,983 series MSC2007-IQ15 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             B+

                           Seawall SPC
   $31,062,982 series CSMC 2007-C4 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             B+

                           Seawall SPC
$31,062,982 series JPMCC 2007-LD12 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BB-

                           Seawall SPC
   $31,062,982 series CSMC 2007-C3 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             B+

                           Seawall SPC
   $31,062,982 series COMM 2007-C9 class AJ floating-rate notes

                                     Rating
                                     ------
       Class                    To             From
       -----                    --             ----
       Notes                    NR             AAA/Watch Neg

                           Seawall SPC
   $31,062,982 series CWCI 2007-C3 class AJ floating-rate notes

                                     Rating
                                     ------
       Class                    To             From
       -----                    --             ----
       Notes                    NR             AAA/Watch Neg

                           Seawall SPC
$31,062,982 series BSCMS 2007-PW17 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BB

                           Seawall SPC
    $31,062,982 series BACM 2007-3 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             B+

                           Seawall SPC
  $31,062,982 series JPMCC 2007-LD11 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             B+

                           Seawall SPC
  $31,062,982 series JPMCC 2007-CB20 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BB+

                           Seawall SPC
   $31,062,982 series CGCMT 2007-C6 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BBB-

                           Seawall SPC
  $31,062,982 series JPMCC 2007-CB19 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BB

                           Seawall SPC
$31.063 million series MLCFC 2007-8 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             BBB-

                           Seawall SPC
   $31,062,982 series MLCFC 2007-7 class AJ floating-rate notes

                                         Rating
                                         ------
           Class                    To             From
           -----                    --             ----
           Notes                    NR             B+

                           Seawall SPC
   $31,062,982 series LBUBS 2007-C6 class AJ floating-rate notes

                                     Rating
                                     ------
       Class                    To             From
       -----                    --             ----
       Notes                    NR             AAA/Watch Neg


STARWOOD HOTELS: Fitch Assigns 'BB+' Rating on Senior Notes
-----------------------------------------------------------
Fitch Ratings has assigned a 'BB+' rating to Starwood Hotels &
Resorts Worldwide Inc.'s senior notes due 2019.  The company is
proposing to issue $250 million of the ten-year notes.  The Rating
Outlook remains Negative.

The notes will rank equally with Starwood's other unsecured and
unsubordinated debt.  The proceeds from the offering will be used
to fund concurrent tender offers for $200 million of 7.875% notes
due 2012 and $100 million of 6.25% notes due 2013.  If the full
tenders are not accepted, remaining funds will be used for general
corporate purposes.  As a result, the issuance may be mostly
leverage neutral depending on the success of the tender offer.

Fitch believes Starwood's liquidity is adequate relative to its
upcoming needs and that the company is likely to be opportunistic
with respect to refinancing and accessing the capital markets over
the next few quarters.  As of Sept. 30, 2009, Starwood had
$113 million of available cash and $1.575 billion of availability
on its $1.875 billion revolving credit facility, which expires in
February 2011.  Fitch calculates that the company generated
roughly $243 million of free cash flow prior to dividend payments
over the last 12 months ending Sept. 30, 2009.

In addition, the company continues to enhance liquidity and
improve its credit and leverage profile through the sale of non-
core assets.  In first quarter 2009 (1Q'09), Starwood signed an
agreement to sell its Bliss Spas for roughly $100 million and
closed the sale of the retail space at the St. Regis New York for
$117 million.  That followed the sale of two wholly-owned hotels
in 3Q'09 that resulted in cash proceeds of $96 million.  Enhanced
liquidity and debt reduction could be supported over the next few
months by the receipt of $200 million of proceeds related to an
IRS settlement, and a timeshare receivable note sale.  Both
Marriott and Wyndham have successfully sold timeshare receivables
recently, and securitization terms are improving, indicating the
market is likely to be receptive to a Starwood securitization.

The proposed issuance and tender offers aim to push out some of
the companies nearest bond maturities, although the issuance is
not contingent on the success of the tender offers.  The 2012
notes have $802 million outstanding and the 2013 notes have
$604 million outstanding as of Sept. 30, 2009.  Prior to the bond
maturities, Starwood has a $300 million term loan due in September
2011, and its revolving credit facility expires in February 2011,
and had only $159 million drawn as of Sept. 30, 2009.  Given
Starwood's solid free cash flow model despite the weak operating
environment, the small amount of bank debt outstanding, and
current access to capital in the financial markets, Fitch believes
refinancing risk is minimal with respect to the 2011 bank debt
maturities.

The 2019 notes are being issued under a supplemental indenture to
the Sept. 13, 2007 base indenture that covers the 6.25% notes due
2013 and the 6.75% notes due 2018, which were issued in September
2007 and May 2008, respectively, when Starwood held an investment-
grade rating.  In May 2009, the company also issued 7.875% notes
due 2014 under a supplemental indenture to the base indenture,
after Starwood's rating was downgraded by Fitch to below
investment grade.

As a result of being governed by the investment-grade base
indenture, there are limited financial covenants protecting 2019
unsecured noteholders.  The 2019 notes are not guaranteed by any
subsidiaries and will be structurally subordinated to any
subsidiary debt.  Only $159 million of subsidiary debt was
outstanding as of Sept. 30, 2009, but the indenture does not limit
the ability of Starwood's subsidiaries to issue or incur debt or
preferred stock.  However, similar to those previously issued
notes, the 2019 notes contain a change of control put at 101, as
defined in the indenture.

Starwood's Rating Outlook remains Negative.  Fitch revised the
Outlook to Negative on Dec. 5, 2008, as it became clear the demand
deterioration related to the recession was likely to be more
severe than Fitch's stress case assumptions.  Fitch downgraded
Starwood's Issuer Default Rating to 'BB+' from 'BBB-' on Feb. 4,
2009, due to Fitch's view that the deterioration in lodging demand
trends had accelerated.  If the improvement in lodging demand
trends that became evident in recent months continues into early
2010 while the broader economic recovery gains traction and
capital markets remain accommodating, the Rating Outlook could
return to Stable at the current IDR of 'BB+'.

However, the Negative Outlook partially reflects weak credit
protection measures relative to the 'BB+' IDR and current business
risks.  Fitch believes Starwood will continue to focus on debt
reduction and balance sheet repair for at least the next few
quarters and until there is greater confidence and visibility in
lodging demand and the broader economic outlook.  Unadjusted
debt/EBITDA leverage was 4.3 times (x) as of Sept. 30, 2009 and
could deteriorate further in upcoming quarters, although Fitch
believes it will remain comfortably below the credit facility
covenant, increased earlier this year to 5.5x from 4.5x.

The ratings continue to reflect Starwood's solid brands; quality
assets, which include a sizeable, unencumbered owned asset
portfolio that could be used as collateral if needed; and
substantial product and geographic diversification.  In addition,
the ratings are supported by Starwood's solid free cash flow
profile despite the significant industry and economic headwinds.

This could lead to a downgrade of Starwood's IDR:

  -- Economic trends that point to a deeper and more prolonged
     recession than Fitch's current expectation, which calls for
     2010 global GDP growth of 2.0% with U.S.  GDP growth of 1.8%.
     Fitch believes the pace of expansion is likely to accelerate
     modestly in 2011 to 2.7% globally and 2.5% for the U.S.;

  -- Unadjusted comparable leverage that is expected to be
     sustained solidly above 4.5x, with an expectation that
     reduction below 4.0x in 2010 appears unlikely;

  -- As visibility with respect to 2010 becomes clearer, an
     expectation that 2010 RevPAR could decline in the mid-single-
     digit range or more;

  -- The company is unable to complete a timeshare receivable note
     sale in 2009, limiting debt reduction, and there is an
     expectation of an inability to monetize receivables.

This could result in a revision in the Outlook to Stable:

  -- The broader economy tracks to Fitch's expectations of a
     return to slightly positive growth in 2010;

  -- Unadjusted comparable leverage is sustained below 4.5x, with
     an expectation that reduction below 4.0x in 2010 appears
     likely;

  -- Expected 2010 RevPAR declines are in the flat- to low-single-
     digit range;

  -- Travel demand shows further signs of improvement and the
     return of RevPAR growth becomes more visible and near term
     rather than Fitch's current expectation of late 2010 RevPAR
     growth;

  -- The free cash flow profile of the timeshare business appears
     solidly improved;

  -- The company completes a timeshare receivable note sale in
     2009, and realizes other secondary sources of capital (IRS
     proceeds, asset sales, etc.) supporting debt reduction, and
     there is an expectation of a continued ability to monetize
     receivables.

Fitch currently rates Starwood:

  -- IDR 'BB+';
  -- Senior unsecured revolving credit facility 'BB+';
  -- Senior unsecured term loan 'BB+';
  -- Senior unsecured notes 'BB+'.


STRUCTURED ASSET: Moody's Adjusts Ratings on Tranche AXP1
---------------------------------------------------------
Moody's Investors Service has adjusted the rating of the tranche
AXP1 from the resecuritization transaction Structured Asset
Securities Corporation 2006-12.  This rating has been adjusted to
Caa2 from Caa3 to reflect adjustments to the ratings of two
tranches issued by IndyMac INDX Mortgage Loan Trust 2006-AR14 that
are pledged to the resecuritization deal.  As explained in Moody's
October 9, 2009 press release, Moody's adjusted the ratings of
these underlying tranches to reflect a principal allocation
feature not previously accounted for.

The ratings on the certificates in the resecuritization are 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 certificates 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 certificate in the
resecuritization is the same as the probability of default for the
lowest rated underlying certificate.  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
certificate).  Therefore, the ratings on junior certificates in
the resecuritization are lower than the portfolio rating on the
combined underlying bonds.

Because the ratings on the certificates in the resecuritization
are linked to the ratings on the underlying certificates and their
mortgage pool performance, any rating action on the underlying
certificates may trigger a further review of the ratings on the
certificates in the resecuritization.  The ratings on the
certificates 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 certificates.

Complete rating actions are:

Issuer: Structured Asset Securities Corporation 2006-12

  -- Cl. AXP1, Upgraded to Caa2; previously on May 15, 2009
     Downgraded to Caa3


TBW MORTGAGE-BACKED: S&P Corrects Ratings on 128 Securities
-----------------------------------------------------------
Standard & Poor's Ratings Services corrected its ratings on 128
classes from eight residential mortgage-backed securities
transactions issued by TBW Mortgage-Backed Trusts in 2006 and 2007
by lowering them to 'D'.  In addition, S&P affirmed its ratings on
six classes from three of the affected transactions.

The downgrades reflect S&P's assessment of missed interest
payments to certificateholders of these classes on the Aug. 25,
2009, Sept. 25, 2009, and Oct. 25, 2009, distribution dates.  S&P
lowered approximately 77.6% of the ratings from the 'CCC' or 'CC'
rating categories, and S&P lowered approximately 10.4% from a
speculative-grade category other than 'CCC' or 'CC'.  The rating
actions did not occur earlier due to an analytical error.

The affirmations reflect a financial guarantee policy and the
payment in full of interest to certificateholders by the
applicable bond insurer (MBIA Insurance Corp. for series 2006-6
and 2007-1 and Assured Guaranty Corp. for series 2007-2) on the
past three month's distribution dates.  The ratings on these
insured classes reflect the higher of (i) the applicable insurer's
rating and (ii) the rating based on the classes' credit support
without regard to the bond insurance.

The underlying pool of loans backing these transactions consists
of fixed- and adjustable-rate U.S. subprime and Alternative-A
mortgage loans secured by first and second liens on one- to four-
family residential properties.

                         Rating Actions

                TBW Mortgage-Backed Trust 2006-6

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       A-1        87222PAA1     D                    AAA
       A-2A       87222PAB9     D                    CCC
       A-2B       87222PAC7     D                    CCC
       A-3        87222PAD5     D                    CCC
       A-5B       87222PAU7     D                    CCC
       A-6A       87222PAV5     D                    CCC
       A-6B       87222PAW3     D                    CCC
       M-1        87222PAG8     D                    CC
       M-2        87222PAH6     D                    CC
       M-3        87222PAJ2     D                    CC
       M-4        87222PAK9     D                    CC
       M-5        87222PAL7     D                    CC
       M-6        87222PAM5     D                    CC
       M-7        87222PAN3     D                    CC

                TBW Mortgage-Backed Trust 2007-1

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       A-1        87222EAA6     D                    AAA
       A-2        87222EAB4     D                    CCC
       A-3        87222EAC2     D                    CCC
       A-4        87222EAD0     D                    CC
       A-5        87222EAE8     D                    CCC
       A-6        87222EAF5     D                    CC
       A-7B       87222EAW8     D                    CC
       A-8        87222EAH1     D                    CC
       M-1        87222EAJ7     D                    CC
       M-2        87222EAK4     D                    CC
       M-3        87222EAL2     D                    CC
       M-4        87222EAM0     D                    CC
       M-5        87222EAN8     D                    CC
       M-6        87222EAP3     D                    CC
       M-7        87222EAQ1     D                    CC
       M-8        87222EAR9     D                    CC
       M-9        87222EAS7     D                    CC

                 TBW Mortgage-Backed Trust 2007-2

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       A-1-A      872227AA1     D                    B-
       A-1-B      872227AB9     D                    B-
       A-2-A      872227AC7     D                    B-
       A-2-B      872227AD5     D                    B-
       A-3-A      872227AE3     D                    B-
       A-3-B      872227AF0     D                    B-
       A-6-A      872227AK9     D                    B-
       A-6-B      872227AL7     D                    B-
       M-1        872227AM5     D                    CC
       M-2        872227AN3     D                    CC
       M-3        872227AP8     D                    CC
       M-4        872227AQ6     D                    CC

             TBW Mortgage-Backed Trust Series 2006-1

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       1-A-1      225470S87     D                    CCC
       1-A-2      225470S95     D                    CCC
       1-A-3      225470T29     D                    A
       1-A-4      225470T37     D                    AA
       1-A-5      225470T45     D                    CCC
       1-A-6      225470T52     D                    CCC
       2-A-1      225470T60     D                    CCC
       3-A-1      225470T78     D                    B
       3-A-2      225470T86     D                    CCC
       4-A-1      225470T94     D                    CCC
       5-A-1      225470U27     D                    CCC
       5-A-2      225470U35     D                    CCC
       6-A-1      225470U43     D                    CCC
       7-A-1      225470U50     D                    CCC
       A-X        225470U68     D                    AA
       D-X        225470U76     D                    B
       A-P        225470U84     D                    CCC
       D-P        225470U92     D                    CCC
       C-B-1      225470V26     D                    CC
       C-B-2      225470V34     D                    CC

             TBW Mortgage-Backed Trust Series 2006-2

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       1-A-1      878048AA5     D                    CCC
       1-A-2      878048AB3     D                    CCC
       1-A-3      878048AC1     D                    CCC
       1-A-4      878048AD9     D                    CCC
       1-A-5      878048AE7     D                    CCC
       2-A-1      878048AF4     D                    CCC
       3-A-1      878048AG2     D                    CCC
       4-A-1      878048AH0     D                    CCC
       5-A-1      878048AJ6     D                    CCC
       6-A-1      878048AK3     D                    CCC
       7-A-1      878048AL1     D                    CCC
       7-A-2      878048BA4     D                    CCC
       8-A-1      878048AM9     D                    CCC
       A-X        878048AN7     D                    CCC
       C-X        878048AP2     D                    CCC
       D-X        878048AQ0     D                    CCC
       A-P        878048AR8     D                    CCC
       C-P        878048AS6     D                    CCC
       C-B-1      878048AT4     D                    CC
       C-B-2      878048AU1     D                    CC
       C-B-3      878048AV9     D                    CC

             TBW Mortgage-Backed Trust Series 2006-3

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       1-A        87804AAA0     D                    CCC
       2-A1       87804AAB8     D                    CCC
       2-A2       87804AAC6     D                    CCC
       3-A        87804AAD4     D                    CCC
       4-A1       87804AAE2     D                    CCC
       4-A2       87804AAF9     D                    CCC
       4-A3       87804AAS1     D                    CCC
       5-A1       87804AAG7     D                    CCC
       5-A2       87804AAH5     D                    CCC
       5-A3       87804AAT9     D                    CCC
       AP         87804AAJ1     D                    CCC
       AX         87804AAK8     D                    CCC
       M          87804AAV4     D                    CC
       B1         87804AAL6     D                    CC
       B2         87804AAM4     D                    CC
       B3         87804AAN2     D                    CC
       B4         87804AAW2     D                    CC
       B5         87804AAX0     D                    CC

             TBW Mortgage-backed Trust Series 2006-4

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       A-1-A      872224AA8     D                    AAA
       A-1-B      872224AB6     D                    AAA
       A-2        872224AC4     D                    AAA
       A-3        872224AD2     D                    CCC
       A-4        872224AE0     D                    CCC
       A-5        872224AF7     D                    CCC
       A-6        872224AG5     D                    CCC
       A-7        872224AH3     D                    CCC
       M-1        872224AJ9     D                    CC
       M-2        872224AK6     D                    CC
       M-3        872224AL4     D                    CC

             TBW Mortgage-Backed Trust Series 2006-5

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       A-1        872225AA5     D                    AAA
       A-2-A      872225AB3     D                    AAA
       A-2-B      872225AC1     D                    AAA
       A-3        872225AD9     D                    A
       A-4        872225AE7     D                    A
       A-5-A      872225AF4     D                    CCC
       A-5-B      872225AG2     D                    CCC
       A-6        872225AH0     D                    A
       M-1        872225AJ6     D                    CC
       M-2        872225AK3     D                    CC
       M-3        872225AL1     D                    CC
       M-4        872225AM9     D                    CC
       M-5        872225AN7     D                    CC
       M-6        872225AP2     D                    CC
       M-7        872225AQ0     D                    CC

                         Ratings Affirmed

                TBW Mortgage-Backed Trust 2006-6

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-4        87222PAE3     BB+
                 A-5A       87222PAF0     BB+

                TBW Mortgage-Backed Trust 2007-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-7A       87222EAG3     BB+

                TBW Mortgage-Backed Trust 2007-2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-4-A      872227AG8     AAA
                 A-4-B      872227AH6     AAA
                 A-5        872227AJ2     AAA


TIAA STRUCTURED: Moody's Downgrades Rating on Class A-1 Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of one class of Notes issued by TIAA Structured Finance CDO
II, Limited.  The class of notes affected by the rating action is
these:

  -- US$225,000,000 Class A-1 Floating Rate Term Notes, Due 2038
     (current balance of $54,620,266), Downgraded to B1;
     previously on 3/26/2009 Downgraded to Baa2

TIAA Structured Finance CDO II, Limited is a collateralized debt
obligation backed primarily by a portfolio of Residential
Mortgage-Backed Securities.  RMBS are approximately 58% of the
underlying portfolio of which the majority is from 2002-2004
vintages.

The rating downgrade actions reflect deterioration in the credit
quality of the underlying portfolio.  Credit deterioration of the
collateral pool is observed through a decline in the average
credit rating (as measured by an increase in the weighted average
rating factor), an increase in the dollar amount of defaulted
securities, and an increase in the proportion of securities rated
Caa1 and below.  More than 20% of the underlying assets have been
the subject of ratings downgrades since Moody's last review of the
transaction in March 2009.  The trustee reports that the WARF of
the portfolio is 777 as of September 28, 2009 and also reports
defaulted assets in the amount of $19 million.  Securities rated
Caa1 or lower make up approximately 26.4% of the underlying
portfolio.  The trustee also reports that the Class A/B and Class
C Overcollateralization Tests are currently failing.

The actions also take into consideration the risk of the
transaction experiencing an Event of Default.  As provided in
Article V of the Indenture dated May 1, 2003, 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 liquidation.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment 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.


TRICADIA CDO: Moody's Downgrades Ratings on Three Classes of Notes
------------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of three classes of Notes issued by Tricadia CDO 2004-2,
Ltd. The notes affected by the rating action are:

  -- US$148.5M Class A Senior Secured Floating Rate Notes Due 2019
     Notes, Downgraded to Ca; previously on May 1, 2009 Downgraded
     to Ba3 and Remained On Review for Possible Downgrade;

  -- US$24M Class B Second Priority Deferrable Floating Rate Notes
     Due 2019 Notes, Downgraded to C; previously on May 1, 2009
     Downgraded to Ca;

  -- US$13M Class C Third Priority Deferrable Floating Rate Notes
     Due 2019 Notes, Downgraded to C; previously on May 1, 2009
     Downgraded to Ca.

Tricadia CDO 2004-2, Ltd., is a collateralized debt obligation
backed primarily by a portfolio of collateralized debt
obligations.

The Trustee reported on March 23, 2009, an Event of Default caused
by the Class A Overcollateralization Percentage to be less than
100% as described in Section 5.1 (h) of the Indenture dated
November 2, 2004.  The rating action takes into consideration the
direction to accelerate Note maturity and to sell and liquidate
the collateral following the Event of Default.  The Trustee
reported on October 28, 2009, that the majority of the Controlling
Class, pursuant to Section 5.2(a) of the Indenture, has declared
the principal of all of the Notes to be immediately due and
payable.  Furthermore, according to the Trustee, a majority of the
Controlling Class has directed the sale and liquidation of the
Collateral pursuant to Section 5.5(a)(ii) of the Indenture.  A
sale and liquidation of the Collateral may result in losses with
respect to the rated Notes that are inconsistent with the ratings
assigned prior to this rating action.


TRUST CERTIFICATES: Moody's Lifts Ratings on 2002-1 Certs. to Caa1
------------------------------------------------------------------
Moody's Investors Service announced that it has upgraded these
certificates issued by Trust Certificates Series 2002-1 Trust:

  -- 1,280,000 7.70% Class A-1 Certificates due 2097, Upgraded to
     Caa1; previously on September 18, 2009, Upgraded to Caa2

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction.  The rating action is a result of the change of the
rating of 7.70% Debentures due 2097 issued by Ford Motor Company
which were upgraded to Caa1 by Moody's on November 2, 2009.


TRUST CERTIFICATES: S&P Raises Rating on $32 Mil. Certs. to 'CCC'
-----------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on Trust
Certificates Series 2002-1 Trust's $32 million class A-1
certificates to 'CCC' from 'CCC-'.

The rating on the certificates is dependent solely on the rating
on the underlying security, Ford Motor Co.'s 7.7% debentures due
May 15, 2097 ('CCC').

The rating action reflects S&P's Nov. 3, 2009, upgrade of the
underlying security to 'CCC' from 'CCC-'.


WACHOVIA BANK: S&P Downgrades Ratings on 16 2006-C29 Securities
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 16
classes of commercial mortgage-backed securities from Wachovia
Bank Commercial Mortgage Trust's series 2006-C29 and removed them
from CreditWatch with negative implications.  In addition, S&P
affirmed its ratings on seven classes from the same transaction
and removed two of them from CreditWatch with negative
implications.

The rating actions follow S&P's analysis of the transaction using
its U.S. conduit and fusion CMBS criteria, which was the primary
driver of these actions.  The downgrades of the subordinate
classes also reflect credit support erosion S&P anticipate will
occur upon the eventual resolution of loans that are with the
special servicer, as well as concerns S&P has with one loan S&P
considers to be 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, excluding loans
that S&P stressed due to credit considerations, S&P calculated an
adjusted debt service coverage of 1.51x and a loan-to-value ratio
of 109.3%.  S&P further stressed the loans' cash flows under its
'AAA' scenario to yield a weighted average DSC of 0.94x and an LTV
of 136.6%.  The implied defaults and loss severity under the 'AAA'
scenario were 88.7% and 32.3%, respectively.  The DSC and LTV
calculations exclude seven specially serviced loans
($113.2 million, 3.4%) and one credit-impaired loan ($3.8 million,
0.1%).  S&P separately estimated losses for these loans, which are
included in the 'AAA' scenario implied default and loss figures.
To date, no loans have been defeased.

The affirmations of the ratings on the principal and interest
certificates reflect subordination levels that are consistent with
the outstanding ratings.  S&P affirmed its rating 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 IO criteria, which may affect outstanding
ratings, including the ratings on the IO certificates S&P
affirmed.

                      Credit Considerations

Nine loans ($167.9 million, 5.0%) in the pool are with the special
servicer, Helios AMC LLC (Helios).  Six of the loans
($95.9 million, 2.9%) are more than 90 days delinquent, two
($54.7 million, 1.6%) are 60 days delinquent, and one
($17.3 million, 0.5%) is 30 days delinquent.  The weighted average
DSC for these loans is 0.89x.  The nine specially serviced loans
each account for less than 1.5% of the pool balance.  Of these
loans, one ($49.0 million, 1.5%) is currently the subject of
modification discussions and one ($5.7 million, 0.2%) has a
bankrupt master tenant.  S&P separately estimated losses for the
remaining seven loans ($113.2 million, 3.4%).

                       Transaction Summary

As of the October 2009 remittance report, the aggregate trust
balance was $3.4 billion, which represents 99.7% of the aggregate
trust balance at issuance.  There are 142 loans in the pool, which
is unchanged issuance.  The master servicer for the transaction is
Wachovia Bank N.A.  The master servicer provided financial
information for 99.0% of the pool, and 95.5% of the servicer-
provided information was full-year 2008 or interim 2009 data.  S&P
calculated a weighted average DSC of 1.50x for the pool based on
the reported figures.  S&P's adjusted DSC and LTV were 1.51x and
109.3%, respectively.  S&P's adjusted figures exclude seven
specially serviced loans and one credit-impaired loan.  S&P
estimated losses separately for these loans.  To date, the
transaction has not realized any losses.  Twenty-three loans
($542.1 million, 16.1%) are on the master servicer's watchlist,
including two of the top 10 loans.  Fifteen loans ($330.3 million,
9.8%) have a reported DSC of less than 1.10x, and 13 of these
loans ($308.7 million, 9.2%) have a reported DSC of less than
1.0x.

                     Summary of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$1.56 billion (46.2%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.68x for the top 10 loans.
The third- and eighth-largest loans in the pool ($305.0 million,
9.1%) appear on the master servicer's watchlist.  S&P's adjusted
DSC and LTV for the top 10 loans were 1.66x and 103.7%,
respectively.

The Galleria at Tyler loan ($205.0 million, 6.1%) is the third-
largest loan in the pool and is secured by 564,247 sq. ft. of a
1.2 million-sq.-ft. regional mall in Riverside, Calif.  This
property is owned by a joint venture between General Growth
Properties (GGP) and the Teacher's Retirement System of the State
of Illinois.  The loan appears on the watchlist due to GGP's
bankruptcy filing.  S&P will continue to monitor developments
relating to this loan and will take rating actions on this
transaction as necessary.  Occupancy was 94.7% as of June 30,
2009, and DSC was 1.94x as of Dec. 31, 2008.

The 21-25 West 34th Street loan ($100.0 million, 3.0%) is the
eighth-largest loan in the pool and is secured by a first mortgage
encumbering a proposed retail building on this site in Manhattan.
The proposed building is 100% triple-net leased to Apple Computer
Inc. for a 15-year term that expires in January 2022.  The loan
appears on the watchlist due to reported DSC of 0.77x as of
Dec. 31, 2008.  A debt service reserve is in place until February
2010, at which time S&P expects the DSC to be above 1.0x.

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

              Wachovia Bank Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2006-C29

                   Rating
                   ------
    Class  To               From         Credit enhancement (%)
    -----  --               ----         ----------------------
    A-M    A-              AAA/Watch Neg                  20.04
    A-J    BB+             AAA/Watch Neg                  11.02
    B      BB              AA+/Watch Neg                  10.27
    C      BB-             AA/Watch Neg                    9.27
    D      B+              AA-/Watch Neg                   8.39
    E      B+              A/Watch Neg                     7.02
    F      B+              A-/Watch Neg                    5.89
    G      B               BBB+/Watch Neg                  4.76
    H      B-              BBB/Watch Neg                   3.76
    J      CCC+            BBB-/Watch Neg                  2.63
    K      CCC             BB+/Watch Neg                   2.25
    L      CCC             BB/Watch Neg                    2.00
    M      CCC-            BB-/Watch Neg                   1.75
    N      CCC-            B+/Watch Neg                    1.63
    O      CCC-            B/Watch Neg                     1.38
    P      CCC-            B-/Watch Neg                    1.13

     Ratings Affirmed And Removed From Creditwatch Negative

              Wachovia Bank Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2006-C29

                   Rating
                   ------
    Class  To               From         Credit enhancement (%)
    -----  --               ----         ----------------------
    A-4    AAA             AAA/Watch Neg                  30.07
    A-1A   AAA             AAA/Watch Neg                  30.07

                         Ratings Affirmed

              Wachovia Bank Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2006-C29

             Class  Rating      Credit enhancement (%)
             -----  ------      ----------------------
             A-1    AAA                         30.07
             A-2    AAA                         30.07
             A-3    AAA                         30.07
             A-PB   AAA                         30.07
             IO     AAA                         N/A


WACHOVIA BANK: S&P Downgrades Ratings on 22 2006-WHALE7 Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 22
classes of commercial mortgage pass-through certificates from
Wachovia Bank Commercial Mortgage Trust's series 2006-WHALE7.
Concurrently, S&P removed all 22 ratings from CreditWatch with
negative implications.

The reasons for the downgrades included:

* S&P's revaluations of the lodging properties in the pool, which
  were generally between 6% and 54% below the levels S&P assessed
  at issuance.

* S&P's analysis incorporated its expectations of future revenue
  per available room declines.

Depressed rental rates and/or higher vacancy rates for the office
collateral properties since issuance, which, based on S&P's
analysis, resulted in property valuations that were generally
between 16% and 35% below issuance levels.

The distribution of interest amounts to the class X-1B interest-
only (IO) certificate is made pro rata to the class A-1
certificate, which S&P downgraded.  S&P published a request for
comment proposing changes to its IO criteria on June 1, 2009.
After S&P finalize its criteria review, S&P may revise its IO
criteria, which may affect outstanding ratings, including the
rating on the IO certificate that S&P lowered.

Hotel properties secure four loans in the pool totaling
$1.80 billion (77% of the pooled trust balance).  These properties
are predominantly located in Honolulu and Maui, Hawaii (36% of the
pooled trust balance), southern Florida (28%), San Francisco (4%),
and Austin, Texas (2%).  The trust also includes the real estate
owned Westin Aruba Resort & Spa property (Westin Aruba; 4% of the
pooled trust balance).

S&P based its hotel analysis on a review of the borrowers'
available operating statements for 2009 and for the 12 months
ended Dec. 31, 2008, and their 2009 budgets, as well as available
STAR reports (hotel benchmarking and performance reports).  The
reduction in business and leisure travel has significantly
affected the performance of lodging collateral.  S&P's analysis
factored in S&P's assumption that overall average 2009 RevPAR in
the industry would decline between 14% and 16% and also considered
conditions in the local lodging markets.

According to Smith Travel, the Oahu Island, Hawaii, lodging market
(the largest submarket concentration in this pool) posted a 17%
decline in RevPAR in the first nine months of 2009 compared with
2008, whereas the general U.S. hotel industry reported an 18%
decline in RevPAR.

The two largest loans in the pool secured by hotel properties are
the Kyo-ya Hotel Pool and Boca Resorts Hotel Pool loans, which
together make up 68% of the pooled trust balance.  Details of
these two loans and the REO Westin Aruba are:

The Kyo-ya Hotel Pool loan, the largest loan in the pool, is
secured by six full-service resort hotel properties totaling 5,163
rooms in Honolulu and Lahaina, Hawaii, and in San FrancisCo. The
current whole loan balance is $1.10 billion, which is bifurcated
into a $1.05 billion senior participation interest and a
$45.9 million subordinate nontrust junior participation interest.
The senior participation interest consists of a $932.4 million
senior pooled component that makes up 40% of the pooled trust
balance and a $123.0 million subordinate nonpooled component that
supports the 'KH' raked certificates.  In addition, the equity
interests in the borrower of the whole loan secure four mezzanine
loans totaling $459.4 million.  The master servicer, Wachovia Bank
N.A., reported a combined debt service coverage of 2.59x for the
12 months ended Dec. 31, 2008.  The combined occupancy for the
hotel properties was 74% as of June 2009, down from 81% at
issuance.  S&P's adjusted valuation has fallen 42% since issuance.
The loan matures on July 9, 2010, and has one 12-month extension
option remaining.  The Boca Resorts Hotel Pool loan, the second-
largest loan in the pool, is secured by five full-service hotels
totaling 2,326 rooms, three marinas, 402 boat slips, and three
golf courses in Boca Raton, Fort Lauderdale, and Naples, Fla.  The
loan has a whole-loan balance of $899.9 million that is split into
a $651.9 million senior pooled component (28% of the pooled trust
balance), a $148.0 million subordinate nonpooled component raked
to the 'BH' certificates, and a $100.0 million nontrust junior
participation interest.  In addition, the equity interests in the
borrower of the whole loan secure four mezzanine loans totaling
$175.0 million.  Wachovia reported a DSC of 2.16x for the 12
months ended June 30, 2009.  The combined occupancy was 53% as of
June 2009, down from 67% at issuance.  S&P's adjusted valuation
has declined 54% since issuance.  The loan matures on Aug. 9,
2010, and has one one-year extension option remaining.

The Westin Aruba, an REO 478-room full-service resort hotel in
Palm Beach, Aruba, has a trust exposure of $109.8 million,
including property protection and debt service advancing totaling
$9.8 million to date.  The property's cash flow also supports the
$3.3 million class WA raked certificate.  To date, the special
servicing fees and appraisal subordinate entitlement reduction
amounts have been absorbed by cash flows from the unrated residual
class in the trust.  The Westin Aruba was transferred to the
special servicer, also Wachovia, on Nov. 19, 2008, due to a
nonmonetary default.  The property became REO on May 20, 2009.
The current property cash flow is insufficient to cover operating
expenses, and reported occupancy was 55% as of June 30, 2009.
Wachovia calculated a $1.6 million appraisal reduction amount,
based on the March 2009 appraisal, which valued the hotel on an
'as is' basis at a level that was comparable to the total exposure
on the property.  Wachovia stated that it plans to begin marketing
the property for sale after completing repairs and resolving
outstanding legal issues.

Office properties secure five loans totaling $408.1 million (17%
of the pooled trust balance).  These properties are located in
Manhattan (9% of the pooled trust balance), southern California
(7%), and Frankfort, Kentucky (1%).  Most of the office properties
have experienced lower rental rates and/or higher vacancies since
issuance.  Details of these five loans are:

The 1515 Broadway loan, the third-largest loan in the pool, has a
whole-loan balance of $425.0 million that is split into two pari
passu pieces, $212.5 million of which makes up 9% of the pooled
trust balance.  The other piece is in the Lehman Bros.  Floating
Rate Commercial Mortgage Trust 2006-LLF C5's commercial mortgage
pass-through certificates transaction.  In addition, the equity
interests in the borrower of the whole loan secure a
$200.0 million mezzanine loan.  This loan is secured by a
1.7 million-sq.-ft. class A office building in midtown Manhattan.
Wachovia reported a 2.86x DSC for the year ended Dec. 31, 2008,
and 98% occupancy as of August 2009.  S&P's adjusted valuation has
declined 16% since issuance.  The loan matures on Nov. 9, 2009,
and has one 12-month extension option remaining.  Wachovia stated
that the loan is in the process of being extended one year.

The Broadreach Pool loan, the sixth-largest loan in the pool, is
secured by eight suburban office properties in southern California
totaling 900,650 sq. ft. This loan has a whole-loan balance of
$148.2 million that consists of a senior participation interest of
$75.8 million and four subordinate nontrust junior participation
interests totaling $72.4 million.  The senior participation
interest is split into a $71.6 million senior pooled component (3%
of the pooled trust balance) and a $4.2 million subordinate
nonpooled component that supports the 'BP' raked certificates
(which Standard & Poor's does not rate).  Wachovia reported a
combined DSC of 2.11x for the 12 months ended Dec. 31, 2008, and
70% occupancy as of August 2009.  S&P's adjusted valuation is down
32% since issuance.  The loan matures on Aug. 9, 2010, and has one
one-year extension option remaining.

The 6300 Wilshire Boulevard loan, the seventh-largest loan in the
pool, is secured by a 388,300-sq.-ft., 21-story, class A office
building in Los Angeles, Calif.  This loan has a whole-loan
balance of $75.0 million that consists of a $55.0 million senior
pooled component (2% of the pooled trust balance), a $5.0 million
subordinate nonpooled component raked to the 'WB' certificate, and
a $15.0 million subordinate nontrust junior participation
interest.  In addition, the equity interests in the borrower of
the whole loan secure two mezzanine loans totaling $29.5 million.

Wachovia reported a DSC of 3.48x for the 12 months ended Dec. 31,
2008.  Reported occupancy was 82% as of August 2009, down from 94%
at issuance.  S&P's adjusted valuation has declined 25% since
issuance.  The loan matures on Aug. 9, 2010, and has one one-year
extension option remaining.   The 4000 MacArthur loan, the eighth-
largest loan in the pool, is secured by two 10-story class A
office buildings in Newport Beach, Calif., totaling 373,450 sq.
ft.  This loan has a whole-loan balance of $100.0 million that
consists of a $50.0 million senior pooled component (2% of the
pooled trust balance), a $10.0 million subordinate nonpooled
component raked to the 'MB' certificates (which Standard & Poor's
does not rate), and a $40.0 million subordinate nontrust junior
participation interest.  Wachovia reported a DSC of 2.92x for the
12 months ended Dec. 31, 2008, and 95% occupancy as of June 2009.
A single tenant currently occupies 95% of the net rentable area
(NRA), half of which expires in June 2010 and the other half in
March 2015.  Wachovia has indicated that the tenant does not plan
to renew the lease expiring in 2010.  S&P's adjusted valuation,
which considers tenant turnover and downtime, has declined 32%
since issuance.  The loan matures on April 9, 2010, and has one
one-year extension option remaining.

The Leestown Square loan, the smallest loan in the pool, has a
trust balance of $19.1 million (1% of the pooled trust balance)
and a whole-loan balance of $30.6 million.  This loan is secured
by three government-occupied class B buildings in Frankfort, Ky.,
totaling 441,650 sq. ft.  Wachovia reported a DSC of 0.44x for the
12 months ended Dec. 31, 2008.  Reported occupancy was 72% as of
April 2009, down from 100% at issuance.  The loan was transferred
to the special servicer on Dec. 12, 2008, due to a maturity
default on Dec. 11, 2008.  The special servicer has indicated that
it plans to initiate foreclosure proceedings if a sale with the
State of Kentucky does not materialize.  A March 2009 appraisal
valued the property at a level that exceeds the senior trust
balance.  S&P's adjusted valuation has fallen 35% since issuance.

Five of the loans in the pool have raked certificates rated by
Standard & Poor's, four of which S&P discussed above.  Details of
the remaining loan are:

The Colonial Mall Myrtle Beach loan, the 10th-largest loan in the
pool, is secured by a 524,200-sq.-ft. regional mall in Myrtle
Beach, S.C.  This loan has a whole-loan balance of $50.2 million
that consists of a $35.0 million senior pooled component (1% of
the pooled trust balance), a $1.2 million subordinate nonpooled
component raked to the class 'CM' certificate, and a $14.0 million
subordinate nontrust junior participation interest.  Wachovia
reported a DSC of 2.10x for the 12 months ended Dec. 31, 2008, and
87% occupancy as of June 2009.  S&P's adjusted valuation has
declined 34% since issuance, primarily due to lower rental
revenue.  The loan matures on Dec. 11, 2009, and has one one-year
extension option remaining.  The borrower has not yet indicated
whether it plans to exercise the extension option.

According to the Oct. 19, 2009, trustee remittance report, pool
statistics are:

* There are 10 loans and one REO asset in the pool, including
  senior participation interests in eight floating-rate mortgage
  loans, one floating-rate whole-mortgage loan, and one floating-
  rate mortgage loan that is split into pari passu notes.

* There are mortgages on 13 full-service and 104 limited-service
  hotels; three golf courses; three marinas; 402 boat slips; one
  class B office, three class A office, and eight suburban office
  properties; and one regional mall.

* All of the loans are indexed to one-month LIBOR.

      Ratings Lowered And Removed From Creditwatch Negative

             Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2006-WHALE7

               Rating
               ------
   Class    To        From               Credit enhancement (%)
   -----    --        ----               ----------------------
   A-1      AA+       AAA/Watch Neg                      51.27
   A-2      A+        AAA/Watch Neg                      26.80
   B        A         AA+/Watch Neg                      22.59
   C        BBB+      AA/Watch Neg                       18.54
   D        BBB-      AA/Watch Neg                       15.27
   E        BB        AA-/Watch Neg                      12.06
   F        B+        A+/Watch Neg                        9.05
   G        B         A/Watch Neg                         5.99
   H        B-        A-/Watch Neg                        3.22
   J        CCC+      BBB+/Watch Neg                      2.29
   K        CCC       BBB/Watch Neg                       1.21
   L        CCC-      BB+/Watch Neg                        N/A
   KH-1     CCC-      BBB-/Watch Neg                       N/A
   KH-2     CCC-      BB+/Watch Neg                        N/A
   BH-1     CCC-      BBB+/Watch Neg                       N/A
   BH-2     CCC-      BBB/Watch Neg                        N/A
   BH-3     CCC-      BBB-/Watch Neg                       N/A
   BH-4     CCC-      BB+/Watch Neg                        N/A
   WA       CCC-      BB+/Watch Neg                        N/A
   WB       CCC-      BB+/Watch Neg                        N/A
   CM       CCC-      BB-/Watch Neg                        N/A
   X-1B     AA+       AAA/Watch Neg                        N/A

                      N/A - not applicable.


WICKER PARK: Moody's Reviews Ratings on Four Classes of Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has placed the ratings
of these notes issued by Wicker Park CDO I, Ltd., under review for
possible downgrade:

  -- US$880,000,000 Class A-1 Contingent Funding Notes, due
     September 2014 (current balance of $877,002,746), A1 Placed
     Under Review for Possible Downgrade; previously on May 18,
     2009 Downgraded to A1;

  -- US$38,500,000 Class A-2 Floating Rate Notes, due September
     2014, Ba1 Placed Under Review for Possible Downgrade;
     previously on May 18, 2009 Downgraded to Ba1;

  -- US$15,000,000 Class B Floating Rate Notes, due September
     2014, B1 Placed Under Review for Possible Downgrade;
     previously on May 18, 2009 Downgraded to B1;

  -- US$21,500,000 Class C Floating Rate Deferrable Interest
     Notes, due September 2014 (current balance of $21,801,885),
     Caa3 Placed Under Review for Possible Downgrade; previously
     on May 18, 2009 Downgraded to Caa3.

According to Moody's, the rating actions taken are a result of
further credit deterioration of the underlying portfolio since the
last rating actions taken on May 18, 2009.  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 proportion of securities from issuers rated Ba1
and below, and continued failure of all the overcollateralization
tests.  In particular, the weighted average rating factor has
increased since the last rating action and is currently 1181 as of
the last trustee report, dated October 8, 2009, versus 875 as of
the April trustee report.  Based on the same report, securities
rated Ba1 or lower make up approximately 35.14% of the underlying
portfolio compared to 33.48% in the April 9, 2009 trustee report.
The percentage of securities rated Ca or C has also increased from
.51% to 2.78% since April.  The reference portfolio also includes
exposure to CIT Group Inc., which filed for Chapter 11 bankruptcy
on November 1, 2009, and iStar Financial Inc., which has
experienced substantial credit migration in the past few months
and is now rated Ca.  Additionally, interest payments on the Class
C, Class D-1 and Class D-2 Notes continue to be deferred as a
result of the failure of the Class A/B overcollateralization test.

Moody's notes that on April 13, 2009, the Class A-2 were
downgraded from Aaa to Aa3, the Class B Notes were downgraded from
Aa2 to A1 as a result of the additional risk posed to the
noteholders due to the action taken by Moody's on the senior
unsecured rating of General Electric Capital Corporation.  The
Class A-2, Class B, Class C, and Class D notes are collateralized
by floating rate global MTNs issued by GECC and on March 23, 2009,
Moody's downgraded the senior unsecured rating of GECC from Aaa to
Aa2.  Additionally, on May 18, 2009, all the rated notes were
further downgraded as a result of the application of revised and
updated key modeling assumptions and the deterioration in the
credit quality of the transaction's reference portfolio.


WIREFREE PARTNERS: Moody's Keeps 'BB' Ratings on Lease-Back Notes
-----------------------------------------------------------------
Fitch Ratings has affirmed the rating of Wirefree Partners III,
LLC PCS Spectrum lease-backed notes series 2005-1 at 'BB' and
assigned a Negative Rating Outlook.

The notes are backed primarily by leases of Personal
Communications Services spectrum licenses.  The lessees of the
licenses are SprintCom, Inc., and WirelessCo, L.P., two wholly
owned subsidiaries of Sprint Nextel Corporation.

Fitch has applied the Global Structured Finance Rating Criteria
for the review of this transaction.  The rating of PCS Spectrum
lease-backed series 2005-1 notes is tied to the senior unsecured
credit rating of Sprint Nextel.  The rating action is based on
Fitch's downgrade of the unsecured credit rating of Sprint Nextel
and its subsidiaries to 'BB' from 'BB+'.

Wirefree Partners, LLC (not rated by Fitch) is a wireless
broadband service provider formed for the purpose of managing, on
behalf of the issuer, its participation in the Federal
Communication Commission's Auction 58 and its acquired spectrum
leases.  Wirefree Partners, LLC was founded on Nov. 15, 2004, by
the former executives and founders of Sprint PCS affiliate,
AirGate PCS, Inc., and is a private company based in Atlanta.


* Fitch Takes Various Rating Actions on Five Re-Performing RMBS
---------------------------------------------------------------
Fitch Ratings has taken various rating actions on five Re-
Performing HUD U.S. residential mortgage-backed securities
transactions in the course of its ongoing RMBS reviews.  Fitch's
rating actions include: affirmations; downgrades; Rating Outlook,
Loss Severity, and Recovery Rating assignments; and RR revisions
as indicated below:

BCF LLC, Series 1997-R1

  -- Class A-4 affirmed at 'AAA/LS3'; Outlook Negative;

  -- Class WAC affirmed at 'AAA'; Outlook Negative;

  -- Class B-1 downgraded to 'BB/LS3' from 'AA'; Outlook Negative;

  -- Class B-2 downgraded to 'C/RR3' from 'BB'; removed from
     Rating Watch Negative;

  -- Class B-3 downgraded to 'D/RR6' from 'C/DR6'.

BCF LLC, Series 1997-R3

  -- Class A WAC affirmed at 'AAA'; Outlook Negative;
  -- Class B-1 downgraded to 'BB/LS3' from 'AA'; Outlook Negative;
  -- Class B-2 downgraded to 'D/RR4' from 'C/DR6';
  -- Class B-3 downgraded to 'D/RR6' from 'C/DR6'.

Bear Stearns Mortgage Securities, Series 1996-6

  -- Class PO affirmed at 'AAA/LS5';
  -- Class X1 affirmed at 'AAA';
  -- Class B1 affirmed at 'AAA/LS3';
  -- Class B2 affirmed at 'AAA/LS3';
  -- Class B3 downgraded to 'BBB/LS3' from 'A+'; Outlook Negative.

Salomon Brothers Mortgage Securities VII, Series 1997-HUD1

  -- Class A-4 affirmed at 'AAA/LS3';
  -- Class A WAC affirmed at 'AAA';
  -- Class IO affirmed at 'AAA';
  -- Class B-1 affirmed at 'AAA/LS4'; Outlook Negative;
  -- Class B-2 downgraded to 'BB/LS4' from 'A+'; Outlook Negative;
  -- Class B-3 downgraded to 'D/RR5' from 'BBB';
  -- Class B-4 downgraded to 'D/RR6' from 'C/DR4'.

Salomon Brothers Mortgage Securities VII, Series 1997-HUD2

  -- Class A-4 affirmed at 'AAA/LS3';
  -- Class A WAC affirmed at 'AAA';
  -- Class IO affirmed at 'AAA';
  -- Class B-1 affirmed at 'AA+/LS3';
  -- Class B-2 downgraded to 'B/LS3' from 'A'; Outlook Negative;
  -- Class B-3 downgraded to 'D/RR5' from 'B+';
  -- Class B-4 downgraded to 'D/RR6' from 'C/DR6'.

The underlying collateral for these transactions consists
primarily of mortgage loans purchased from the United States
Department of Housing and Development.  Each mortgage loan is a
fixed-rate or adjustable-rate loan secured by a first lien on a
one- to four-family residential property.  All of the mortgage
loans in the Trust have previously defaulted and all HUD insurance
on the loans has terminated.

When determining each collateral pool's projected base-case loss,
Fitch incorporated actual deal and sector level performance
trends.  The severities used in this review ranged from 55%-74%
depending on the actual severity history and vintage average.  The
weighted average frequency of foreclosure for the transactions
ranged from 20.67% to 34%.

The average updated expected collateral loss as a percentage of
the original pool balance is 12.46% with losses ranging from 7.1%
- 17.3%.  As a percentage of the remaining pool balances, the
average expected loss is 18.64% with losses ranging from 11.4% -
25.1%.  The remaining pool balances of the reviewed transactions
extending from 1996-1997 have paid down to approximately 6.9% of
the original pool balances on average.

After determining each pool's projected base-case and stressed
scenario loss assumptions, Fitch took rating actions based on the
relationship between each bond's credit enhancement and the
expected loss.


* S&P Downgrades Ratings on 145 Tranches From 25 CLO Transactions
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 145
tranches from 25 U.S. collateralized loan obligation transactions
and removed them from CreditWatch with negative implications.  The
affected tranches had a total issuance amount of $10.469 billion.
S&P also affirmed its ratings on 16 tranches from 10 of these
transactions and removed 15 of the ratings from CreditWatch
negative.

The downgrades reflect two primary factors:

* The application of S&P's new corporate collateralized debt
  obligation criteria; and

* For some of the transactions, deterioration in the credit
  quality of the collateral supporting the CLO tranches due to
  increased exposure to obligors that have either defaulted or
  experienced downgrades into the 'CCC' range.

The downgrades of 23 classes from 11 transactions resulted from
S&P's application of the largest-obligor default test, which is
one of the supplemental stress tests S&P introduced as part of
S&P's criteria update.

S&P will continue to review the remaining transactions placed on
CreditWatch following its corporate CDO criteria update and
resolve the CreditWatch status of the affected tranches.

                          Rating Actions

                                             Rating
                                             ------
  Transaction                    Class     To     From
  -----------                    -----     --     ----
  ACAS CLO 2007-1 Ltd.           A-1       AA+    AAA/Watch Neg
  ACAS CLO 2007-1 Ltd.           A-1-J     AA+    AAA/Watch Neg
  ACAS CLO 2007-1 Ltd.           A-2       AA-    AA/Watch Neg
  ACAS CLO 2007-1 Ltd.           B         A-     A/Watch Neg
  ACAS CLO 2007-1 Ltd.           C         BBB-   BBB/Watch Neg
  AMMC CLO IV Ltd.               A-1       AA+    AAA/Watch Neg
  AMMC CLO IV Ltd.               A-3       AA+    AAA/Watch Neg
  AMMC CLO IV Ltd.               B         A      AA/Watch Neg
  AMMC CLO IV Ltd.               C         BBB    A/Watch Neg
  AMMC CLO IV Ltd.               D         CCC-   BBB/Watch Neg
  Apidos CDO IV                  A-1       AA+    AAA/Watch Neg
  Apidos CDO IV                  A-2       AA+    AAA/Watch Neg
  Apidos CDO IV                  B         A+     AA/Watch Neg
  Apidos CDO IV                  C         BBB+   A/Watch Neg
  Apidos CDO IV                  D         BB+    BBB/Watch Neg
  Apidos CDO IV                  E         B+     BB/Watch Neg
  Apidos Quattro CDO             A         AA+    AAA/Watch Neg
  Apidos Quattro CDO             B         AA-    AA/Watch Neg
  Apidos Quattro CDO             C         BBB+   A/Watch Neg
  Apidos Quattro CDO             D         BBB-   BBB/Watch Neg
  Apidos Quattro CDO             E         B+     BB/Watch Neg
  Ares Enhanced Loan Investment  A-1       AA+    AAA/Watch Neg
   Strategy IR Ltd.
  Ares Enhanced Loan Investment  B-1       A-     A/Watch Neg
   Strategy IR Ltd.
  Ares Enhanced Loan Investment  B-2       A-     A/Watch Neg
   Strategy IR Ltd.
  Babson CLO Ltd. 2005-III       A         AA     AAA/Watch Neg
  Babson CLO Ltd. 2005-III       B         A+     AA/Watch Neg
  Babson CLO Ltd. 2005-III       C         BBB+   A/Watch Neg
  Babson CLO Ltd. 2005-III       D         BB+    BBB/Watch Neg
  Babson CLO Ltd. 2005-III       E         B+     BB/Watch Neg
  Babson CLO Ltd. 2007-I         A-1       AA+    AAA/Watch Neg
  Babson CLO Ltd. 2007-I         A-2b      AA+    AAA/Watch Neg
  Babson CLO Ltd. 2007-I         A-3       AA-    AA/Watch Neg
  Babson CLO Ltd. 2007-I         B-1       A-     A/Watch Neg
  Babson CLO Ltd. 2007-I         B-2       A-     A/Watch Neg
  BlueMountain CLO II Ltd.       A         AA     AAA/Watch Neg
  BlueMountain CLO II Ltd.       A-2       AA     AAA/Watch Neg
  BlueMountain CLO II Ltd.       B         A+     AA/Watch Neg
  BlueMountain CLO II Ltd.       C         BBB    A/Watch Neg
  BlueMountain CLO II Ltd.       D         BB+    BBB-/Watch Neg
  BlueMountain CLO II Ltd.       E         B+     BB-/Watch Neg
  Cent CDO 14 Ltd.               A-1       AA-    AAA/Watch Neg
  Cent CDO 14 Ltd.               A-2a      AA+    AAA/Watch Neg
  Cent CDO 14 Ltd.               A-2b      AA-    AAA/Watch Neg
  Cent CDO 14 Ltd.               B         A      AA/Watch Neg
  Cent CDO 14 Ltd.               C         BBB    A/Watch Neg
  Cent CDO 14 Ltd.               D         BB+    BBB/Watch Neg
  Cent CDO 14 Ltd.               E         B+     BB/Watch Neg
  Cornerstone CLO Ltd.           A-1--J    AA     AAA/Watch Neg
  Cornerstone CLO Ltd.           A-1-S     AA+    AAA/Watch Neg
  Cornerstone CLO Ltd.           A-2       A+     AA/Watch Neg
  Cornerstone CLO Ltd.           B         BBB+   A/Watch Neg
  Cornerstone CLO Ltd.           C         CCC+   BBB/Watch Neg
  Cornerstone CLO Ltd.           D         CCC-   BB/Watch Neg
  Dryden XI-Leveraged Loan CDO   A-1       AA+    AAA/Watch Neg
   2006
  Dryden XI-Leveraged Loan CDO   A-2A      AA+    AAA/Watch Neg
   2006
  Dryden XI-Leveraged Loan CDO   A-2B      AA+    AAA/Watch Neg
   2006
  Dryden XI-Leveraged Loan CDO   A-3       AA-    AA/Watch Neg
   2006
  Dryden XI-Leveraged Loan CDO   B         BBB+   A/Watch Neg
   2006
  Dryden XI-Leveraged Loan CDO   C-1       CCC+   BBB/Watch Neg
   2006
  Dryden XI-Leveraged Loan CDO   C-2       CCC+   BBB/Watch Neg
   2006
  Dryden XI-Leveraged Loan CDO   D         CCC-   BB/Watch Neg
   2006
  Dryden XVIII Leveraged Loan    B         CCC-   BB/Watch Neg
   2007 Ltd.
  Gannett Peak CLO I Ltd.        A-1       AA-    AAA/Watch Neg
  Gannett Peak CLO I Ltd.        A-1b      AA-    AAA/Watch Neg
  Gannett Peak CLO I Ltd.        A-2       BBB+   AA/Watch Neg
  Gannett Peak CLO I Ltd.        B-1       BB+    A/Watch Neg
  Gannett Peak CLO I Ltd.        B-2       BB+    A/Watch Neg
  Gannett Peak CLO I Ltd.        C         CCC+   BBB/Watch Neg
  Gannett Peak CLO I Ltd.        D-1       CCC-   BB/Watch Neg
  Gannett Peak CLO I Ltd.        D-2       CCC-   BB/Watch Neg
  Gulf Stream-Compass CLO 2007   A-1B      AA+    AAA/Watch Neg
   Ltd.
  Gulf Stream-Compass CLO 2007   B         A+     AA/Watch Neg
   Ltd.
  Gulf Stream-Compass CLO 2007   C         BBB+   A/Watch Neg
   Ltd.
  Gulf Stream-Compass CLO 2007   D         BB+    BBB/Watch Neg
   Ltd.
  Gulf Stream-Compass CLO 2007   E         CCC-   BB/Watch Neg
   Ltd.
  Gulf Stream-Sextant CLO        A-1-B     AA+    AAA/Watch Neg
   2006-1 Ltd.
  Gulf Stream-Sextant CLO        A-2       AA+    AAA/Watch Neg
   2006-1 Ltd.
  Gulf Stream-Sextant CLO        B         A+     AA/Watch Neg
   2006-1 Ltd.
  Gulf Stream-Sextant CLO        C         BBB+   A/Watch Neg
   2006-1 Ltd.
  Gulf Stream-Sextant CLO        D         BB+    BBB/Watch Neg
   2006-1 Ltd.
  Integral Funding Ltd.          A-2       AA-    AAA/Watch Neg
  Integral Funding Ltd.          A-3       A      AA/Watch Neg
  Integral Funding Ltd.          B         BBB-   A/Watch Neg
  Integral Funding Ltd.          C         B+     BBB-/Watch Neg
  Integral Funding Ltd.          D         CCC-   B/Watch Neg
  Madison Park Funding II Ltd.   A-1       A+     AAA/Watch Neg
  Madison Park Funding II Ltd.   A-2a      AA+    AAA/Watch Neg
  Madison Park Funding II Ltd.   A-2b      A+     AAA/Watch Neg
  Madison Park Funding II Ltd.   A-3       A-     AA/Watch Neg
  Madison Park Funding II Ltd.   B-1       BB+    A/Watch Neg
  Madison Park Funding II Ltd.   B-2       BB+    A/Watch Neg
  Madison Park Funding II Ltd.   C-1       B+     BBB/Watch Neg
  Madison Park Funding II Ltd.   C-2       B+     BBB/Watch Neg
  Madison Park Funding II Ltd.   D         CCC+   BB/Watch Neg
  Madison Park Funding III Ltd.  A-1       AA     AAA/Watch Neg
  Madison Park Funding III Ltd.  A-2a      AA+    AAA/Watch Neg
  Madison Park Funding III Ltd.  A-2b      AA     AAA/Watch Neg
  Madison Park Funding III Ltd.  A-3       A+     AA/Watch Neg
  Madison Park Funding III Ltd.  B         BBB+   A/Watch Neg
  Madison Park Funding III Ltd.  C         BB+    BBB/Watch Neg
  Madison Park Funding III Ltd.  D         B+     BB/Watch Neg
  Madison Park Funding III Ltd.  Q         B+     BBB-/Watch Neg
  Marathon CLO II Ltd.           A-1A      A+     AAA/Watch Neg
  Marathon CLO II Ltd.           A-1B      A+     AAA/Watch Neg
  Marathon CLO II Ltd.           A-2       A-     AA/Watch Neg
  Marathon CLO II Ltd.           B         BB+    BBB+/Watch Neg
  Marathon CLO II Ltd.           C         CCC-   BB/Watch Neg
  Marathon CLO II Ltd.           D         CCC-   CCC+/Watch Neg
  Momentum Capital Fund Ltd.     A-2       AA+    AAA/Watch Neg
  Momentum Capital Fund Ltd.     B         A+     AA/Watch Neg
  Momentum Capital Fund Ltd.     C         BB+    A/Watch Neg
  Momentum Capital Fund Ltd.     D         CCC+   BBB/Watch Neg
  Momentum Capital Fund Ltd.     E         CCC-   BB/Watch Neg
  Pacifica CDO VI Ltd.           A-1a      AA     AAA/Watch Neg
  Pacifica CDO VI Ltd.           A-1b      AA+    AAA/Watch Neg
  Pacifica CDO VI Ltd.           A-1c      AA     AAA/Watch Neg
  Pacifica CDO VI Ltd.           A-2       A+     AA/Watch Neg
  Pacifica CDO VI Ltd.           B         BBB    A/Watch Neg
  Pacifica CDO VI Ltd.           C-1       CCC-   BBB-/Watch Neg
  Pacifica CDO VI Ltd.           C-2       CCC-   BBB-/Watch Neg
  Pacifica CDO VI Ltd.           D         CCC-   BB/Watch Neg
  Red River CLO Ltd.             A         A+     AAA/Watch Neg
  Red River CLO Ltd.             B         BBB+   AA/Watch Neg
  Red River CLO Ltd.             C         BB+    A-/Watch Neg
  Red River CLO Ltd.             D         CCC-   BB-/Watch Neg
  Red River CLO Ltd.             E         CCC-   CCC/Watch Neg
  Saratoga CLO I Ltd.            A-2       A+     AAA/Watch Neg
  Saratoga CLO I Ltd.            B         BBB-   A/Watch Neg
  Saratoga CLO I Ltd.            C         B+     BBB-/Watch Neg
  Saratoga CLO I Ltd.            D         CCC+   BB-/Watch Neg
  Stanfield Vantage CLO Ltd.     A1        AA-    AAA/Watch Neg
  Stanfield Vantage CLO Ltd.     A3        AA-    AAA/Watch Neg
  Stanfield Vantage CLO Ltd.     B         BBB+   AA/Watch Neg
  Stanfield Vantage CLO Ltd.     C         BB+    A/Watch Neg
  Stanfield Vantage CLO Ltd.     D         CCC-   BBB/Watch Neg
  Stone Tower CLO V Ltd.         A-1       AA-    AAA/Watch Neg
  Stone Tower CLO V Ltd.         A-2a I    AA+    AAA/Watch Neg
  Stone Tower CLO V Ltd.         A-2a NV   AA+    AAA/Watch Neg
  Stone Tower CLO V Ltd.         A-2a V    AA+    AAA/Watch Neg
  Stone Tower CLO V Ltd.         A-2b      AA-    AAA/Watch Neg
  Stone Tower CLO V Ltd.         A-3       A+     AA/Watch Neg
  Stone Tower CLO V Ltd.         B         BBB+   A/Watch Neg
  Stone Tower CLO V Ltd.         C-1       B+     BBB/Watch Neg
  Stone Tower CLO V Ltd.         C-2       B+     BBB/Watch Neg
  Stone Tower CLO V Ltd.         D         CCC-   BB/Watch Neg

       Ratings Affirmed And Removed From Creditwatch Negative

                                             Rating
                                             ------
  Transaction                    Class     To     From
  -----------                    -----     --     ----
  ACAS CLO 2007-1 Ltd.           A-1-S     AAA    AAA/Watch Neg
  ACAS CLO 2007-1 Ltd.           D         BB     BB/Watch Neg
  AMMC CLO IV Ltd.               A-2       AAA    AAA/Watch Neg
  Ares Enhanced Loan Investment  A-2       AA     AA/Watch Neg
   Strategy IR Ltd.
  Ares Enhanced Loan Investment  C         BBB    BBB/Watch Neg
   Strategy IR Ltd.
  Babson CLO Ltd. 2007-I         A-2a      AAA    AAA/Watch Neg
  Babson CLO Ltd. 2007-I         C         BBB    BBB/Watch Neg
  Babson CLO Ltd. 2007-I         D-1       BB     BB/Watch Neg
  Babson CLO Ltd. 2007-I         D-2       BB     BB/Watch Neg
  Gulf Stream-Compass CLO        A-1A      AAA    AAA/Watch Neg
   2007 Ltd.
  Gulf Stream-Sextant CLO        A-1-A     AAA    AAA/Watch Neg
   2006-1 Ltd.
  Gulf Stream-Sextant CLO        A-1-R     AAA    AAA/Watch Neg
   2006-1 Ltd.
  Integral Funding Ltd.          A-1       AAA    AAA/Watch Neg
  Momentum Capital Fund Ltd.     A-1       AAA    AAA/Watch Neg
  Saratoga CLO I Ltd.            A-1       AAA    AAA/Watch Neg

                          Rating Affirmed

         Transaction                    Class     Rating
         -----------                    -----     ------
         Stanfield Vantage CLO Ltd.     A2        AAA



                           *********

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
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The Sunday TCR delivers securitization rating news from the week
then-ending.

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                           *********

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
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