TCR_Public/091129.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 29, 2009, Vol. 13, No. 330

                            Headlines



ABACUS 2005-CB1: Fitch Downgrades Ratings on Eight Classes
ABACUS 2007-18: Fitch Downgrades Ratings on Five Classes of Notes
ALTERNATIVE LOAN: S&P Downgrades Rating on Class A 2005-59R Certs.
AMBAC ASSURANCE: S&P Withdraws Ratings on Two Medium-Term Notes
AMERICAN CORPORATE: Moody's Withdraws 'C' Rating on Receipts

ANSONIA CDO: Moody's Reviews Ratings on Nine Classes of Notes
ARBOR REALTY: Fitch Downgrades Ratings on All Classes of Notes
ARBOR REALTY: Fitch Downgrades Ratings on All 2004-1 Notes
AUDUBON PARK: Moody's Affirms 'Ba2' Ratings on Refunding Bonds
AUSTIN CONVENTION: Moody's Reviews 'Ba2' Ratings on Two Bonds

BANC OF AMERICA: Fitch Downgrades Ratings on 21 2005-4 Certs.
BANC OF AMERICA: Moody's Affirms Ratings on Nine 2005-3 Certs.
BANC OF AMERICA: Moody's Affirms Ratings on Eight 2006-6 Certs.
BEAR STEARNS: Fitch Takes Rating Actions on 2005-PWR7 Certs.
BEAR STEARNS: Moody's Reviews Ratings on 24 2007-BBA8 Certificates

BEAR STEARNS: S&P Downgrades Ratings on 151 2006-R1 Certificates
BEAR STEARNS: S&P Downgrades Ratings on 15 2007-Top26 Securities
BRYANT PARK: Moody's Confirms Ratings on Three Classes of Notes
BUCHANAN SPC: S&P Withdraws 'D' Ratings on Various Classes
CAPITAL AUTO: S&P Raises Ratings on Six Classes of Notes

CAPMARK VII: Moody's Reviews Ratings on 11 Classes of Notes
CHASE MORTGAGE: S&P Downgrades Ratings on 16 2007-A1 Securities
CITY OF ALHAMBRA: Fitch Assigns 'BB' Rating on $43.3 Mil. Bonds
CITY OF EVANSVILE: Moody's Cuts Housing Revenue Bond Rating to Ba1
COBALTS TRUST: S&P Puts 'BB' Rating on CreditWatch Negative

COLUMBIA COUNTY: S&P Junks Rating on $13.575 Mil. 1999 Bonds
COMM 2007-C9: S&P Downgrades Ratings on 24 Classes of CMBS
CORPORATE-BACKED: Moody's Withdraws 'C' Rating on Class A-1
CORPORATE BACKED: S&P Puts 'BB-' Rating on CreditWatch Negative
CREDIT SUISSE: Fitch Puts Ratings on 2003-CK2 Notes on Neg. Watch

CREDIT SUISSE: Fitch Takes Rating Actions on 2005-C1 Certs.
CREDIT SUISSE: Moody's Affirms Ratings on Five 2007-C4 Certs.
CREDIT SUISSE: Moody's Reviews Ratings on 15 2007-C3 Certificates
CREDIT SUISSE: S&P Downgrades Ratings on 14 2007-TFL1 Certs.
CREDIT SUISSE: S&P Downgrades Ratings on 15 2006-C2 Securities

CREST G-STAR: S&P Downgrades Ratings on Three Classes of Notes
CWCAPITAL COBALT: Moody's Reviews Ratings on Eight Classes
CWCAPITAL COBALT: S&P Downgrades Ratings on 10 Classes to 'D'
GE COMMERCIAL: S&P Downgrades Ratings on 11 2005-C2 Securities
GREENWICH STRUCTURED: S&P Downgrades Rating on Class N-3 Notes

G-STAR 2005-5: Fitch Downgrades Ratings on Six Classes of Notes
GE COMMERCIAL: Fitch Takes Rating Actions on 2005-C3 Certs.
GS MORTGAGE: Moody's Reviews Ratings on Nine Series 2004-C1 Certs.
GS MORTGAGE: Moody's Affirms Ratings on 13 2005-GG4 Certificates
GS MORTGAGE: Moody's Affirms Ratings on Five 2007-GG10 Certs.

GSMSC RESECURITIZATION: S&P Downgrades Rating on Class A Certs.
HIGHLAND CREDIT: Moody's Upgrades Ratings on Two Classes of Notes
HOLYOKE HOSPITAL: Fitch Affirms 'BB' Rating on Series B Bonds
INDUSTRIAL DEVELOPMENT: Fitch Affirms 'D' Rating on $35 Mil. Bonds
JP MORGAN: Fitch Corrects Loss Severity Rating on Class X

JP MORGAN: Fitch Takes Various Rating Actions on 2005 LDP1 Certs.
JP MORGAN: Moody's Reviews Ratings on 25 2007-LPD10 Certificates
JP MORGAN: Moody's Takes Rating Actions on 2004-CIBC10 Certs.
JP MORGAN: Fitch Takes Rating Actions on 2005-CIBC12 Certificates
JPMORGAN CHASE: S&P Downgrades Ratings on Two 2001-A Certificates

KIMBERLITE CDO: S&P Downgrades Ratings on Hybrid CDO CMBS Deal
LB-UBS COMMERCIAL: S&P Downgrades Ratings on 20 2007-C6 Securities
MAGI FUNDING: Moody's Takes Rating Actions on Various Classes
MARATHON CLO: Moody's Takes Rating Actions on Various Classes
MARICOPA COUNTY: Fitch Assigns 'BB+' Rating on $36 Mil. Bonds

MAX CMBS: S&P Downgrades Ratings on 22 Classes of Notes
MORGAN STANLEY: S&P Downgrades Ratings on 16 2007-IQ13 Securities
MORGAN STANLEY: S&P Puts 'BB+' Rating on CreditWatch Positive
MORGAN STANLEY: S&P Withdraws 'CCC-' Rating on Class IA Notes
MORGAN STANLEY: S&P Withdraws 'CCC-' Rating on Class IIA Notes

NELSON RE: Moody's Takes Rating Actions on Catastrophe Bonds
NEPTUNO CLO: Moody's Takes Rating Actions on Various Notes
NORMAN REGIONAL: S&P Cuts Ratings to 'BB+'; Gives Stable Outlook
PORTER SQUARE: Fitch Downgrades Ratings on Three Classes of Notes
PORTER SQUARE: Fitch Downgrades Ratings on Two Classes of Notes

PPLUS TRUST: S&P Downgrades Ratings on $25 Mil. Certs. to 'BB-'
PPLUS TRUST: S&P Puts 'BB' Cert. Rating on CreditWatch Negative
PRICHARD HOUSING: Moody's Affirms 'Ba3' Rating on 1998 Bonds
PRIME 2004-CL1A: S&P Downgrades Ratings on Two Classes of Notes
PUTNAM CBO: Fitch Downgrades Ratings on Notes to 'D/RR6'

RACERS 2000-16-P-STRONG: Moody's Withdraws 'C' Rating on Certs.
RACERS 2001-17-P: Moody's Withdraws 'C' Rating on Certificates
RACE POINT: Fitch Downgrades Ratings on Four Classes of Notes
RFC CDO: Fitch Downgrades Ratings on 10 Classes of 2006-1 Notes
SANKATY HIGH: S&P Downgrades Ratings on Eight Classes of Notes

SATURNS TRUST: S&P Puts 'BB' Ratings on CreditWatch Negative
SEAWALL SPC: S&P Downgrades Ratings on 2008 CMBS CDO-3 Notes
SOUTH COUNTY: Moody's Confirms 'Ba1' Rating on Series 2006A Bonds
STRUCTURED ASSET: S&P Downgrades Rating on $25 Mil. Units to 'BB-'
STRUCTURED REPACKAGED: S&P Puts 'BB' Rating on Negative Watch

TEXAS STATE: S&P Changes Outlook on 'C' Bond Rating to Negative
TIGRIS CDO: Fitch Downgrades Ratings on Seven Classes of Notes
TULSA HOUSING: Moody's Raises Ratings on Revenue Bonds From 'Ba1'
VERTICAL ABS: Fitch Downgrades Ratings on Three Classes of Notes
WACHOVIA BANK: Moody's Affirms Ratings on Eight 2006-C28 Certs.

WASHINGTON MUTUAL: Moody's Upgrades Ratings on 10 Securities

* Moody's Downgrades Ratings on 14 Tranches From 10 US SF CDOs
* Moody's Reviews Ratings on 16 Tranches From Seven Trust CDOs
* Moody's Withdraws Ratings on 159 Classes of Notes by 20 SF CDOs
* S&P Cuts Ratings on 26 Classes From Three RMBS Deals to 'D'
* S&P Downgrades Ratings on 21 Classes From Five RMBS Transactions

* S&P Downgrades Ratings on 72 Tranches From 11 CLO Transactions
* S&P Downgrades Ratings on 129 Tranches From 22 CLO Transactions
* S&P Downgrades Ratings on 703 Classes of Certificates to 'D'
* S&P Downgrades Ratings on Eight Classes From Two Synthetic CDOs



                            *********

ABACUS 2005-CB1: Fitch Downgrades Ratings on Eight Classes
----------------------------------------------------------
Fitch Ratings has downgraded eight classes of notes issued by
Abacus 2005-CB1, Ltd, as a result of significant credit
deterioration within the portfolio since last review in July 2008.

As per the latest trustee report dated September 2009, aggregate
losses in the reference portfolio have reached approximately
$133.8 million.  These losses have completely eroded the balance
of class B, C, D, E-1, E-2, and F notes and resulted in a loss of
$18.5 million on class A-2 notes.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Structured Finance Portfolio Credit Model for projecting
future default levels for the underlying portfolio.  Due to the
significant collateral deterioration, all PCM rating loss rates
exceed the credit enhancement available to each class of notes.

In addition to realized losses, the collateral continues to
experience negative migration with approximately 68.7% of the
current portfolio downgraded a weighted average of 5.9 notches
since last review.  The downgrades to the portfolio have left
approximately 51.2% of the portfolio with a Fitch derived rating
below investment grade and 47.5% with a rating in the 'CCC' rating
category or lower.  Given the class A-1 notes' credit enhancement
level of 1% and portfolio composition, Fitch expects significant
principal impairment for the class A-1 notes.

The underlying credit default swap provides for the possibility of
reimbursements from the CDS counterparty to the collateralized
debt obligation when a reference obligation balance is written up,
which would lead to a corresponding write-up in the CDO notes'
balances.  However, Fitch believes this to be an unlikely
occurrence.  All classes of notes are downgraded to 'C' to reflect
the fact that default is inevitable prior or at maturity.

Abacus 2005-CB1 is a partially funded synthetic CDO transaction
issued in December 2005 referencing a $750 million portfolio of
asset-backed securities.  The CDS counterparty is Goldman Sachs
Capital Markets, L.P., which is rated 'A+/F1+' with a Stable
Outlook by Fitch.  Presently, Abacus 2005-CB1's portfolio is
comprised primarily of subprime RMBS bonds (55.9%), CMBS (34.1%)
and other structured finance assets.  Subprime RMBS bonds of the
2005 vintage account for approximately 29.5% of the portfolio.

Fitch has downgraded these classes:

  -- $132,187,500 class A-1 notes to C' from 'CCC';
  -- $3,958,720 class A-2 notes to 'C' from 'CCC';
  -- $0 class B notes to 'C' from 'CC';
  -- $0 class C notes to 'C' from 'CC';
  -- $0 class D notes to 'C' from 'CC';
  -- $0 class E-1 notes to 'C' from 'CC';
  -- $0 class E-2 notes to 'C' from 'CC';
  -- $0 class F notes to 'C' from 'CC'.


ABACUS 2007-18: Fitch Downgrades Ratings on Five Classes of Notes
-----------------------------------------------------------------
Fitch Ratings has downgraded and removed from Rating Watch
Negative five classes issued by Abacus 2007-18 as a result of
significant negative credit migration of the commercial mortgage
backed securities collateral within the reference portfolio.

Since Fitch's last rating action in January 2009, approximately
41% of the portfolio has been downgraded, and 46.9% was placed on
Rating Watch Negative.  Approximately 96.8% of the portfolio has a
Fitch derived rating below investment grade and 35.3% has a rating
in the 'CCC' rating category or lower, compared to 50.7% and 2.5%
at last review.

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 degree of correlated default
risk of this reference collateral is high given the single sector
CMBS and vintage concentrations.

Due to the significant collateral deterioration, Fitch's loss
expectation approximates the credit enhancement available to the
class A-3 notes, indicating a real possibility for default.  The
class A-3 notes have been assigned a 'CCC' rating.  Fitch's loss
expectation exceeds the credit enhancement available to the
classes below class A-3.  Given the high probability of default of
the underlying assets and the expected low recoveries upon
default, the class B notes and B series 2 notes have been assigned
a 'CC' rating, indicating that default is probable.

For the class A-1 and A-2 notes, the credit enhancement provided
by the A-3 notes and below is insufficient to warrant ratings for
these classes above the 'CCC' rating category.

Abacus 2007-18 is a static synthetic CDO transaction issued in May
2007 that references a US$1 billion portfolio of CMBS and CRE CDO
securities.  The reference portfolio is composed of 91.3% CMBS
assets, of which 90% are from the 2005 through 2007 vintages, 8.8%
are SF CDOs from the 2006 and 2007 vintages, and the balance are
CMBS assets from the 2001 vintage (1.3%).  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.

Proceeds from the securities are invested in a pool of eligible
investments, which are currently held in the principal collection
account by the trustee.  Collateral market value risk is mitigated
through the collateral put agreement between the issuer and the
put counterparty, Goldman Sachs International.  The payment
obligations of the put counterparty are guaranteed by GSI, the
swap counterparty guarantor, except in the event of a Mandatory
Redemption.  A Mandatory Redemption can occur in an Event of
Default or termination event.

Fitch has downgraded these classes as indicated:

  -- $80,000,000 class A-1 notes to 'CCC' from 'BBB-';
  -- $50,000,000 class A-2 notes to 'CCC' from 'BB+';
  -- $11,500,000 class A-3 notes to 'CCC' from 'BB';
  -- $5,000,000 class B notes to 'CC' from 'BB';
  -- $17,500,000 class B series 2 notes to 'CC' from 'BB';

In addition, classes A-1 through B have been removed from Rating
Watch Negative.

Fitch does not rate classes C through R.


ALTERNATIVE LOAN: S&P Downgrades Rating on Class A 2005-59R Certs.
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
A certificates from Alternative Loan Trust Resecuritization 2005-
59R, a U.S. residential mortgage-backed securities resecuritized
real estate mortgage investment conduit transaction.  S&P lowered
the rating on class A to 'CCC' from 'AAA.' The downgrade reflects
significant deterioration in the performance of the loans backing
the underlying certificate.  This performance deterioration is so
severe that the credit enhancement for ALT 2005-59R is
insufficient to maintain the previous rating on the re-REMIC
class.

ALT 2005-59R, which closed in November 2005, is collateralized by
three underlying certificates that support the class A tranche.
The loans securing the underlying classes consist predominantly of
option adjustable-rate Alternative-A mortgage loans.

The class A certificates from ALT 2005-59R are supported by class
1-X (currently rated 'CCC') and classes P-1 and P-2 (both
currently rated 'NR') from Countrywide Home Loans Alternative Loan
Trust 2005-59.  The performance of the loans securing this trust
has declined precipitously in recent months.  This pool had
experienced losses amounting to 4.15% of the original pool balance
as of the October 2009 distribution, and has approximately 54.84%
of the current pool balance in delinquent loans.  Based on the
losses to date, the current pool factor of 0.5204 (52.04%), 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 25.90%, 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 Lowered

         Alternative Loan Trust Resecuritization 2005-59R

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A          12668AR98     CCC                  AAA


AMBAC ASSURANCE: S&P Withdraws Ratings on Two Medium-Term Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on two
medium-term note issues supported by Ambac Assurance Corp.'s
insurance policies.

The ratings on the two affected issues were based solely on the
full financial guarantee insurance policies that Ambac had
provided, which guaranteed the timely payment of interest and
principal according to each transaction's terms.

The rating actions follow the Nov. 18, 2009, lowering of S&P's
rating on Ambac to 'SD' from 'CC'.  As S&P outlined in S&P's
criteria, "Methodology: The Interaction of Bond Insurance and
Credit Ratings," published Aug. 24, 2009, S&P will withdraw its
rating on a bond insurance-backed security if the issue does not
have a Standard & Poor's underlying rating and its rating on the
insurer is lowered below 'BBB-'.

                        Ratings Withdrawn

                     LoneStar CAPCO Fund LLC
      $8.6 mil sr secd med-term nts ser 2005 due 03/01/2012

                                    Rating
                                    ------
             CUSIP             To            From
             -----             --            ----
                    --         NR            CC

                 Aegis Texas Venture Fund II L.P.
$27.377 mil medium term notes med-term nts ser 2008 due 08/01/2015

                                    Rating
                                    ------
             CUSIP             To            From
             -----             --            ----
             00767NAA0         NR            CC

                          NR - Not rated.


AMERICAN CORPORATE: Moody's Withdraws 'C' Rating on Receipts
------------------------------------------------------------
Moody's Investors Service announced that it has withdrawn the
rating of these receipts issued by American Corporate Accrual
Receipts, Series 1:

  -- US$24,000,000 Callable Principal Receipts, Withdrawn;
     Previously on December 17, 2008 Downgraded to C

The transaction is a structured note whose rating is based on the
underlying securities and legal structure of the transaction.  The
underlying securities are the US$400,000,000 8.1% Debentures due
6/15/2024 issued by General Motors Corporation.  The rating was
withdrawn following the bankruptcy filing by General Motors
Corporation earlier this year.


ANSONIA CDO: Moody's Reviews Ratings on Nine Classes of Notes
-------------------------------------------------------------
Moody's Investors Service continues the review for possible
downgrade of nine classes of Notes issued by Ansonia CDO 2006-1,
Ltd.  Moody's is leaving the Notes on review for possible
downgrade due to an unresolved dispute between the Issuer (Ansonia
CDO 2006-1, Ltd.) and the Counterparty regarding the calculation
amount due to the Counterparty under the Class A-FL Swap
Agreement.  The final resolution of the dispute will have direct
impact on the interest proceeds available for distribution to
Noteholders.

On August 26, 2009, Moody's downgraded Class B to Caa1 and placed
all nine classes of Notes on review for possible downgrade due to
an Event of Default caused by the non-payment of full interest on
certain classes, deterioration in the credit quality of the
underlying portfolio, and the uncertainty surrounding potential
Collateral liquidation in the current environment.

Ansonia CDO 2006-1, Ltd., is a collateralized debt obligation
backed by a portfolio of cash collateral in commercial mortgage
backed securities, commercial real estate collateralized debt
obligations, and Real Estate Investment Trust debt.  As of the
October 28, 2009 payment date, CMBS collateral comprised
approximately 94% of the portfolio with 19% of the CMBS
concentrated in 2006 vintage securitizations.  REIT debt comprises
5% of the portfolio and CRE CDO collateral constitutes the
remaining 1%.

Moody's has identified these parameters as key indicators of the
expected loss within CRE CDO transactions: weighted average rating
factor, weighted average life, weighted average recovery rate, and
Moody's asset correlation.

Moody's review will focus on potential impact from the resolution
of the dispute regarding the calculation amount and any change in
the key rating parameters.

Moody's rating action is:

  -- Cl. A-FL, Ba3 Placed Under Review for Possible Downgrade;
     previously on Aug 26, 2009 Ba3 Placed Under Review for
     Possible Downgrade

  -- Cl. A-FX, Ba3 Placed Under Review for Possible Downgrade;
     previously on Aug 26, 2009 Ba3 Placed Under Review for
     Possible Downgrade

  -- Cl. B, Caa1 Placed Under Review for Possible Downgrade;
     previously on Aug 26, 2009 Downgraded to Caa1 Placed Under
     Review for Possible Downgrade

  -- Cl. C, Caa1 Placed Under Review for Possible Downgrade;
     previously on Aug 26, 2009 Caa1 Placed Under Review for
     Possible Downgrade

  -- Cl. D, Caa1 Placed Under Review for Possible Downgrade;
     previously on Aug 26, 2009 Caa1 Placed Under Review for
     Possible Downgrade

  -- Cl. E, Caa2 Placed Under Review for Possible Downgrade;
     previously on Aug 26, 2009 Caa2 Placed Under Review for
     Possible Downgrade

  -- Cl. F, Caa2 Placed Under Review for Possible Downgrade;
     previously on Aug 26, 2009 Caa2 Placed Under Review for
     Possible Downgrade

  -- Cl. G, Caa2 Placed Under Review for Possible Downgrade;
     previously on Aug 26, 2009 Caa2 Placed Under Review for
     Possible Downgrade

  -- Cl. H, Caa3 Placed Under Review for Possible Downgrade;
     previously on Aug 26, 2009 Caa3 Placed Under Review for
     Possible Downgrade

Moody's monitors transactions on both a monthly basis through a
review of the available Trustee Reports and a periodic basis
through a full review.  Moody's prior review is summarized in a
press release dated March, 6 2009.


ARBOR REALTY: Fitch Downgrades Ratings on All Classes of Notes
--------------------------------------------------------------
Fitch Ratings has downgraded all classes of Arbor Realty Mortgage
Securities Series 2005-1 Ltd./LLC reflecting Fitch's base case
loss expectation of 40%.  Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market value and cash flow declines.

ARMSS 2005-1 is primarily collateralized by a combination of
senior (47%) and subordinate commercial real estate debt (48%).
Fitch expects significant losses upon default for these assets
since they are generally highly leveraged.  Further, three loans
(8.4%) are currently defaulted.  Fitch expects significant to full
losses on these loan interests.

ARMSS 2005-1 is a $470 million CRE collateralized debt obligation
managed by Arbor Realty Trust, Inc. The transaction has a five-
year reinvestment period that ends in April 2011.  As of the
October 2009 trustee report and per Fitch categorizations, the
CDO was substantially invested in 33 assets: multifamily (39.5%),
office (29.7%), hotel (4.7%), land (13.3%), mixed use (1.9%),
CRE CDOs (5%), and uninvested proceeds (1%).  All
overcollateralization and interest coverage ratios are currently
in compliance.

Under Fitch's updated methodology, approximately 67.6% 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 9.7% from either trailing 12-month third or
fourth quarter 2008 or T12 first quarter 2009 cash flows.  Fitch
estimates that average recoveries will be 40.8% as many of the
assets are highly leveraged and subordinate in nature.

The largest component of Fitch's base case loss expectation is a
defaulted mezzanine loan secured by an interest in a five property
multifamily portfolio located in Phoenix, Arizona.  The
sponsorship is currently in Chapter 11 bankruptcy, and the loan is
over 90+ days delinquent.  A full loss on the position is
expected.

The next largest component of Fitch's base case loss expectation
is a pari passu A-note secured by a 116,000 square foot
condominium interest in four floors of an office building located
in midtown Manhattan.  The space is occupied by four full floor
tenants at below market average rents.  Cash flow from the
property is insufficient to support debt service.  While Fitch
applied no haircut to property cash flow in the base case stress
scenario due to the below market rents and stability of the tenant
base, the loan is still expected to suffer a term default in the
'B' stress.

The third largest component of Fitch's base case loss expectation
consists of two CMBS rake bonds secured by a subordinate interest
in a 1,090,000 sf office property located in downtown Manhattan.
The property is expected to experience leasing challenges in the
next few years due to significant rollover risk associated with
the two largest tenants.  The loan matures in November 2009, and
the borrower has indicated that default is imminent.  Fitch
assumed 100% probability of default for this loan.

This transaction was analyzed according to the 'U.S. CREL CDO
Surveillance Criteria', which applies stresses to property cash
flows and debt service coverage ratio 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 and B notes' breakeven rates
are generally consistent with the 'BBB' rating category; the class
B through E notes' breakeven rates are generally consistent with
the 'BB' rating category; and the class F through H notes'
breakeven rates are generally consistent with the 'B' rating
category.

The class A through H 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 has downgraded, assigned Loss Severity ratings, and Rating
Outlooks to the classes:

  -- $161,500,000 class A-1 to 'BBB/LS4' from 'AAA'; Outlook
     Negative;

  -- $40,375,000 class A-2 to 'BBB/LS5' from 'AAA'; Outlook
     Negative;

  -- $57,000,000 class B to 'BB/LS5' from 'AA'; Outlook Negative;

  -- $24,291,159 class C to 'BB/LS5' from 'A+'; Outlook Negative;

  -- $8,356,159 class D to 'BB/LS5' from 'A'; Outlook Negative;

  -- $7,384,512 class E to 'BB/LS5' from 'A-'; Outlook Negative;

  -- $14,380,366 class F to 'B/LS5' from 'BBB+'; Outlook Negative;

  -- $10,688,110 class G to 'B/LS5' from 'BBB'; Outlook Negative;

  -- $14,574,695 class H to 'B/LS5' from 'BBB-'; Outlook Negative.

Additionally, all classes are removed from Rating Watch Negative.


ARBOR REALTY: Fitch Downgrades Ratings on All 2004-1 Notes
----------------------------------------------------------
Fitch Ratings downgrades all classes of Arbor Realty Mortgage
Securities Series 2004-1, Ltd./LLC, reflecting Fitch's base case
loss expectation of 46.3%.  Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market value and cash flow declines.

ARMSS 2004-1 is primarily collateralized by subordinate commercial
real estate debt (66.4% of total collateral is either B-notes,
mezzanine debt, or preferred equity positions).  Fitch expects
significant losses upon default for these assets since they are
generally highly leveraged debt classes.  Further, one loan (1.5%)
is currently defaulted.  Fitch expects a full loss on this B-note.

ARMSS 2004-1 is a $434 million CRE collateralized debt obligation
managed by Arbor Realty Trust, Inc.  The transaction had a four-
year reinvestment period that ended April 2009.  As of the October
2009 trustee report and per Fitch categorizations, the CDO was
substantially invested in 36 assets: B-notes (32.8%), CRE
mezzanine loans (23.3%), preferred equity positions (10.3%), whole
loans/A-notes (29.5%), CMBS (3.3%), a defeased CRE loan asset
(0.7%), and uninvested proceeds (0.1%).  All overcollateralization
and interest coverage ratios are currently in compliance.

Under Fitch's updated methodology, approximately 63.2% 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 10.9% from either trailing 12 month (T12)
third or fourth quarter 2008 or T12 first quarter 2009 cash flows.
Fitch estimates that average recoveries will be low at 26.8%, due
to the highly leveraged and subordinate nature of the assets.

The largest component of Fitch's base case loss expectation is a
pari passu A-note and a B-note secured by a 1,028 unit multifamily
property located in Ypsilanti, Michigan.  Performance has suffered
due to poor market conditions; and cash flow from the property is
not supporting debt service.  A significant loss is expected on
this loan.

The next largest component of Fitch's base case loss expectation
is a senior and junior B-note secured by a high end 390-unit
multifamily property located in Clearwater, Florida.  While
occupancy was 90.3% in March 2009, cash flow from the property was
not sufficient to support the loan; the loan was modified to
maintain a 4% interest rate for an additional 12 months to allow
further time to lease up the vacant units.  The interest rate will
revert to 7.25% in May 2010.  Based on the highly leveraged
position of these B-notes, Fitch expects a full loss.

The third largest component of Fitch's base case loss expectation
is a junior mezzanine position in a 1.2 million square foot office
tower located in midtown Manhattan.  While performance at the
property has been relatively stable, debt service is currently
unable to support the loan.  Further, the debt service requirement
is expected to increase beginning in late 2010 as the interest
only period expires.  Fitch expects a full loss on this
overleveraged position.

This transaction was analyzed according to the 'U.S. CREL CDO
Surveillance Criteria', which applies stresses to property cash
flows and 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 and B notes' breakeven rates are generally consistent
with the 'BB' rating category; and the class C and D notes'
breakeven rates are generally consistent with the 'B' rating
category.

The class A through D 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 has downgraded and assigned Loss Severity ratings and Rating
Outlooks to the classes:

  -- $179,793,874 class A to 'BB/LS4' from 'AAA'; Outlook
     Negative;

  -- $51,590,000 class B to 'BB/LS5' from 'AA'; Outlook Negative;

  -- $27,635,768 class C to 'B/LS5' from 'A-'; Outlook Negative;

  -- $11,183,232 class D to 'B/LS5' from 'BBB+'; Outlook Negative.

Additionally, all classes are removed from Rating Watch Negative.


AUDUBON PARK: Moody's Affirms 'Ba2' Ratings on Refunding Bonds
--------------------------------------------------------------
Moody's Investors Service has affirmed its Ba2 rating on the
Audubon Park Commission's Aquarium Revenue Refunding Bonds, Series
1997.  The rating outlook is stable.

The Audubon Commission is a component unit of the City of New
Orleans which has management agreements with the Audubon Nature
Institute to operate its facilities, including the Audubon Zoo and
Park, the Aquarium and Riverfront Park, the Audubon Insectarium,
the Species Survival Center, and the Louisiana Nature Center.  In
addition to the Aquarium revenue pledge, Moody's rating approach
considers the combined financial resources and operations of both
the Commission and the Institute.

Unlike the Series 1997 Aquarium Revenue Bonds, the majority of the
Commission's debt is General Obligation Limited Tax.  Moody's
currently rates the Audubon Commission Limited Tax Bonds, Series
1997 Ba1 with a stable outlook.  For more information on the
Audubon Commission Limited Tax Bonds, please see Moody's report
dated March 18, 2009.

Legal Security: Net revenue pledge of the Aquarium of the
Americas.  Security features include a debt service reserve fund
surety bond provided by MBIA, additional bonds test, and a minimum
of 1.75 times rate maintenance covenant.  Credit events impacting
the financial strength rating of MBIA (National Public Finance
Guarantee Corp. -- current financial strength rating of Baa1 with
a developing outlook) have not triggered any cure requirements
related to the debt service reserve fund.  Pledged revenues of
$6.1 million provided 3.9 times coverage of annual debt service in
2008.

Debt-Related Derivatives: None.  All of the Commission's bonded
debt is fixed rate.

                            Strengths

* Sustained recovery in visitor levels at the Commission's
  facilities including the Aquarium and Riverfront Park following
  Hurricane Katrina closure in late 2005 and early 2006.  In 2008,
  the Aquarium of the Americas had 631,196 visitors, a 6% increase
  from 2007, but 34% below the 2004 high.  With careful management
  of expenses, net revenue of the Aquarium covered debt service by
  4.3 times in 2007 and 3.9 times in 2008.  Management reports
  Aquarium attendance is up approximately 15% during 2009, with a
  higher proportion of visitors driving in from the region as
  opposed to tourists from further away.  Visitor levels have been
  aided by a new Audubon Experience membership program which
  allows members to attend both the Zoo and the Aquarium, which
  used to have separate membership programs.

* Continued public support from the City of New Orleans (rated
  Baa3 with a stable outlook).  Property tax revenue accounts for
  32% of Moody's adjusted operating revenue based on FY 2008.  For
  more information about changes in assessed property valuations
  in the City, see Moody's report on New Orleans dated March 18,
  2009.

* Ongoing private donor support for the Audubon Nature Institute,
  which operates the Aquarium, including $3.7 million in gift
  revenue in FY2008.

* Occasional capital support from the State of Louisiana (general
  obligation rating of A1 with a positive outlook) for various
  capital projects at the Audubon Zoo.  In addition, the
  Commission received $1.3 million of Federal Emergency Management
  Agency funds related to Hurricane Katrina in 2007 and 2008 which
  it has invested in capital.  A portion of the expected
  $5 million in support the Commission may receive from the FEMA
  related to damage at the Louisiana Nature Center may be approved
  for investments at the Zoo which is more likely to generate
  visitor revenue in support of the Commission's operations.  The
  Commission has no plans to issue additional debt.

                           Challenges

* Extremely thin unrestricted financial resource cushion at
  Commission with $1.1 million of resources cushioning debt and
  annual operating expenses by 0.02 times.  Cash and Investments
  totaled $2.6 million at the Commission at FYE 2008 for an
  organization with a $53 million expense base.  Expendable
  financial resources of $13.4 million at the FYE 2008 including
  the net assets of the Audubon Nature Institute, cushion debt 0.2
  times and expenses by 0.25 times.  Investment losses at the
  Audubon Nature Institute Foundation led to reduced expendable
  financial resources in FY 2008.  The pooled endowment lost 30.8%
  in CY 2008, but is up 20.1% during the first three quarters of
  CY 2009.  The asset allocation as of September 30, 2009 was 47%
  global equities, 19% hedge funds, 12% fixed income, 8% real
  estate, 7% multi strategy, and 7% cash and equivalents.

* Dependence on operating lines of credit which were fully drawn
  on at $4 million at the end of FY 2008 and are regularly used
  for capital and operating needs.  The revenues of the
  Commission's properties are seasonal and the Institute typically
  draws on its lines for operating purposes during the winter,
  gradually reducing the amount outstanding through early summer.
  Approximately half of the amount outstanding is for capital
  projects expected to be reimbursed by the State.

* Relatively weak operating performance at the Commission overall
  with a three-year average margin of -5% covering debt service an
  average of 1.5 times.  Future operating performance health will
  require continued careful management as evidenced by employee
  lay offs (23 employees on a 600 employee base) and other cost
  containment measures in 2009.

Recent Developments:

Gulf Opportunity Zone borrowing has given debt service relief for
several years (2006 through 2009), offset by the accretion of the
Commission's GO Zone liability through the Louisiana Office of
Community Development which totaled $15.1 million at FYE 2008.
There is some possibility that the State may forgive all or a
portion of the repayment obligation from the Commission.  In years
2010 and 2011 there will be no off-setting revenue from the GO
Zone program, increasing the cash debt service burden of the
Commission, from $3.4 million in 2009 to $5.6 million in 2010.  In
2012, the Series 1997 Aquarium Revenue Bonds mature, offsetting
the increased GO Zone debt service which will begin in that year
and end in 2026.

                             Outlook

The stable outlook for the Aquarium Revenue Bond rating reflects
Moody's expectations of sufficient debt service coverage from
operations, careful management of operations at the Commission, as
well as continued financial support from the City of New Orleans
(Baa3 general obligation rating with a stable outlook) .

                 What could change the rating-UP

Lasting recovery of visitor revenues combined with solid tax
revenue and donor support, financial resource growth and limited
future borrowing.  Improvement in the credit profile of the City
of New Orleans.

                What could change the rating-DOWN

Failure to maintain debt service coverage from Aquarium revenues;
decline in public support for the Commission; reduction in
financial resources; inability to renew operating lines of credit.

Aquarium And Riverfront Park Key Indicators (Fiscal Year 2008
Data):

* Aquarium admissions revenue: $5.9 million

* IMAX admissions revenue: $1.4 million

* Total debt: $63.1 million (including debt of Audubon Nature
  Institute)

* Total financial resources: $30.5 million (including Audubon
  Institute)

* Expendable financial resources to debt: 0.04 times

* Expendable financial resources to operations: 0.10 times

* Reliance on tax support: 32% of total revenue (includes debt
  service relief from State)

* Average comprehensive debt service coverage: 2.5 times

* City of New Orleans: General Obligation Rating of Baa3 with a
  stable outlook

                            Rated Debt

Net Revenue Pledge:

* Aquarium Revenue Refunding Bonds, Series 1997: Ba2, insured by
  MBIA (National Public Finance Guarantee Corp. has current
  financial strength rating of Baa1 with a developing outlook)

Limited Tax Pledge:

* Audubon Commission Aquarium Bonds, Series 2003A: insured by FSA
  (National Public Finance Guarantee Corp. has current financial
  strength rating of Baa1 with a negative outlook)

* Audubon Commission Aquarium Bonds, Series 2001 A and 2001 B:
  insured by FSA (National Public Finance Guarantee Corp. has
  current financial strength rating of Baa1 with a negative
  outlook)

* Audubon Commission Improvement and Refunding Zoo Bonds, Series
  1997: Ba1; insured by Ambac

The last report in the Aquarium Revenue Bonds was on August 13,
2007, when the Ba2 rating with a stable outlook was affirmed
outlook.


AUSTIN CONVENTION: Moody's Reviews 'Ba2' Ratings on Two Bonds
-------------------------------------------------------------
Moody's Investors Service has placed the Austin Convention
Enterprises, Inc.'s Baa3 and Ba2 ratings on its Convention Center
Hotel Revenue Refunding Bonds, Series 2006A and 2006B,
respectively, under review for possible downgrade.

The review for downgrade will evaluate ACE's exposure to the
competitive convention center and lodging market, the decline in
revenue per available room, which is in turn due to a decline in
the Average Daily Rate and Occupancy rate for 3Q09 as compared to
3Q08.  The review for downgrade also reflects the reduction in the
credit quality of the surety provider, Syncora Guarantee Inc.
(formally XL Capital Assurance Inc.) whose insurance financial
strength rating is now currently non-investment grade Ca with a
developing outlook.

ACE issued three tiers of tax exempt bonds totaling $265 million
in June 2001 -- ACE Hotel First Tier Revenue Bonds Series 2001A,
ACE Hotel Second Tier Revenue Bonds Series 2001B, and ACE Hotel
Third Tier Revenue Bonds Series 2001C -- to finance the Project.
In December 2006, ACE issued the tax exempt Series 2006A and 2006B
bonds totaling $260 million to refund the Series 2001A and 2001B
bonds.  Proceeds of the 2006A and 2006B bonds were used to
purchase the securities for the escrow account.  At the same time,
$7.71 million of the $20.5 million Series 2001C bonds were
retired.  The Series 2001C bonds which were not refunded, do not
carry an underlying rating.

The last rating action was on October 24, 2006, when the initial
Baa3 and Ba2 ratings were assigned to the Series 2006A and Series
2006B Convention Center Hotel Revenue Refunding Bonds.

Austin Convention Enterprises Inc.'s ratings were assigned by
evaluating factors Moody's believe are relevant to the credit
profile of the issuer, such as i) the business risk and
competitive position of the company versus others within its
industry, ii) the capital structure and financial risk of the
company, iii) the projected performance of the company over the
near to intermediate term, and iv) management's track record and
tolerance for risk.  These attributes were compared against other
issuers both within and outside of Austin Convention Enterprises'
core industry and Austin Convention Enterprises' ratings are
believed to be comparable to those of other issuers of similar
credit risk.

Austin Convention Enterprises Inc. was established to construct,
acquire, and operate the Hilton Austin hotel project (the
Project), which includes a hotel, parking garage and other related
facilities.  The 800-room full service hotel opened in January
2004 and is adjacent to the Austin Convention Center located in
downtown Austin, Texas.


BANC OF AMERICA: Fitch Downgrades Ratings on 21 2005-4 Certs.
-------------------------------------------------------------
Fitch Ratings has downgraded, removed from Rating Watch Negative,
and assigned Rating Outlooks and Loss Severity ratings to 21
classes of commercial mortgage pass-through certificates from Banc
of America Commercial Mortgage Inc. commercial mortgage pass-
through certificates series 2005-4.  A detailed list of rating
actions follows at the end of this release.

The downgrades are the result of loss expectations and reflect
Fitch's prospective views regarding commercial real estate market
value and cash flow declines.  Fitch foresees potential losses
could reach as high as 11.9% for this transaction should market
conditions not recover.  The rating actions are based on losses of
8.6%, including 100% of the term losses and 25% of the losses
anticipated to occur at maturity; the 8.6% recognizes all of the
losses anticipated in the next five years.  Of the recognized
losses, 64.5% were on loans reviewed in detail.

To determine potential defaults for each loan Fitch assumed cash
flow would decline by 10% from year-end 2008, which is consistent
with the analysis used in its review of recent vintage
transactions whereby cash flow was assumed to decline 15% from
year-end 2007 projected over a three year period.  If the stressed
cash flow would cause the loan to fall below 0.95 times, Fitch
assumed the loan would default during the term.  To determine
losses, Fitch used the above stressed cash flow, and applied a
market cap rate, ranging between 7.5% and 9.5%, for each specific
property type.  If the loan balance at default is less than the
stressed cash flow the loan would realize that loss.

These loss estimates were reviewed in more detail for loans
representing 67.2% of the pool and, in certain cases, revised
based on additional information and/or property characteristics.
Approximately 95% of the recognized losses were from loans
reviewed in detail.

Approximately 12.8% of the mortgages mature within the next five
years: 17.1% in 2010, 0% in 2011, 12.7% in 2012, 0.3% in 2013, and
0.7% in 2014.  All losses associated with these loans are fully
recognized in the rating actions.  Approximately 69% of the loans
mature in 2015.

Fitch identified 41 Loans of Concern (36.1%) within the pool, 18
of which (30%) are specially serviced.  Of the specially serviced
loans, five (7.3%) are current.  Of the current loans, Peachtree
Mall and three loans sponsored by DBSI are expected to be
transferred back to the master servicer.  Three (19.8%) of the
specially serviced loans are within the transaction's top 15 loans
(54.6%) by unpaid principal balance.

Four of the loans (13.7%) within the top 15 are expected to
default during the term, with loss severities ranging from 15% to
36%.  The largest contributors to loss are: Pacific Arts Plaza
(7.2%), Renaissance Baltimore Harborplace (6.9%) and Colonade
Apartments (2.5%)

Pacific Arts Plaza is an 825,061 square foot office property
located in Costa Mesa, CA.  This loan transferred to special
servicing in August 2009 for imminent default after the borrower
requested debt relief.  The property was approximately 74%
occupied as of the June 30, 2009 rent roll, compared to
approximately 88% at issuance.  As of June 30, 2009 the reported
debt service coverage ratio was 1.01x, compared to 1.32x at
issuance.  The loan is pari passu with the $132 million A-1 note
in the BACM 2005-3 transaction.  The loan was structured as full
interest only and the sponsor is Maguire Properties, L.P.

Renaissance Baltimore Harborplace is a 622 room hotel located
downtown Baltimore with waterfront access and is adjacent to
Harborplace.  The loan transferred to special servicing on July 1,
2009 and the servicer is currently working on a modification.  As
of June 30, 2009, the servicer reported a DSCR, occupancy, average
daily rate and revenue per available room of 0.72x, 59.1%, $174
and $103, respectively, compared to an occupancy, ADR and RevPAR
at issuance of 72.4%, $186 and $135, respectively.  The loan is
now amortizing on a 25 year schedule and the sponsor is Sunstone
Hotel Investors, Inc. After the modification is finalized, the
loan may return to the master servicer.

Colonade Apartments is a 535 unit multifamily and a 78,463 sf
office mixed-use property located in Jenkintown, PA, approximately
nine miles north of the Philadelphia central business district.
As of June 30, 2009 the servicer reported DSCR and occupancy were
0.68x and 46.5%.  The multifamily occupancy is approximately 91%,
while the office occupancy is 47%.  The sponsor is Jeffrey J.
Cohen.  The loan is now amortizing on a 30-year schedule,
following three years interest only.  .

Fitch has downgraded, removed from Rating Watch Negative and
assigned Rating Outlooks, LS and Recovery Ratings as indicated:

  -- $97.1 million class A-J to 'A/LS4' from 'AAA'; Outlook
     Negative;

  -- $31.7 million class B to 'BBB-/LS5' from 'AA'; Outlook
     Negative;

  -- $15.9 million class C to 'BB/LS5' from 'AA-'; Outlook
     Negative;

  -- $29.7 million class D to 'BB/LS5' from 'A'; Outlook Negative;

  -- $17.8 million class E to 'B/LS5' from 'A-'; Outlook Negative;

  -- $19.8 million class F to 'B-/LS5' from 'BBB+'; Outlook
     Negative;

  -- $17.8 million class G to 'B-/LS5' from 'BBB-'; Outlook
     Negative;

  -- $23.7 million class H to 'CCC/RR6' from 'BB+';

  -- $7.9 million class J to 'CCC/RR6' from 'BB';

  -- $7.9 million class K to 'CCC/RR6' from 'B+';

  -- $7.9 million class L to 'CCC/RR6' from 'B';

  -- $4.0 million class M to 'CCC/RR6' from 'B-';

  -- $5.9 million class N to 'CCC/RR6' from 'CCC/RR1';

  -- $5.9 million class O to 'CCC/RR6' from 'CCC/RR2'.

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

  -- $6.0 million class A-1 at 'AAA/LS2'; Outlook Stable;
  -- $215.5 million class A-2 at 'AAA/LS2'; Outlook Stable;
  -- $87.9 million class A-3 at 'AAA/LS2'; Outlook Stable;
  -- $70.0 million class A-4 at 'AAA/LS2'; Outlook Stable;
  -- $61.2 million class A-SB at 'AAA/LS2'; Outlook Stable;
  -- $485.9 million class A-5A at 'AAA/LS2'; Outlook Stable;
  -- $69.4 million class A-5B at 'AAA/LS2'; Outlook Stable;
  -- $220.3 million class A-1A at 'AAA/LS2'; Outlook Stable;
  -- Interest only Class XP at 'AAA'; Outlook Stable;
  -- Interest only Class XC at 'AAA'; Outlook Stable.

Fitch does not rate these classes:
  -- $23.8 million class P.


BANC OF AMERICA: Moody's Affirms Ratings on Nine 2005-3 Certs.
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings of nine classes and
downgraded 12 classes of Banc of America Commercial Mortgage,
Inc., Commercial Mortgage Pass-Through Certificates, Series 2005-
3.  The downgrades are due to higher expected losses for the pool
resulting from anticipated losses from loans in special servicing
and concerns about the refinance risk associated with loans
approaching maturity.  Eight loans, representing 17% of the pool,
mature within the next 24 months and have a Moody's stressed debt
service coverage ratio less than 1.0X.

The affirmations are due to key rating parameters, including
Moody's loan to value ratio, stressed DSCR and Herfindahl Index,
remaining within acceptable ranges.

On August 11, 2009, Moody's placed 12 classes on review for
possible downgrade due to the credit uncertainty surrounding
Maguire Properties Inc., the sponsor of the Pacific Arts Plaza
Loan (6.3% of the pool).  Maguire has experienced ongoing levels
of high effective leverage, declining operating performance, and
an inability to cover dividends from operating cash flow.  This
action concludes Moody's review of the transaction.  The rating
action is the result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.

As of the November 10, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by 3% to $2.10 billion
from $2.16 billion at securitization.  The Certificates are
collateralized by 109 mortgage loans ranging in size from less
than 1% to 10% of the pool, with the top ten loans representing
52% of the pool.  The pool contains one loan, representing 0.6% of
the pool, with an investment grade underlying rating.  At
securitization, two other loans, representing 8% of the pool, also
had had investment grade underlying ratings.  Due to declines in
performance, the leverage of these loans has increased and they
are now analyzed as part of the conduit pool.  Two loans,
representing 1% of the pool, have defeased and are collateralized
by U.S. Government securities.  At last review one loan,
representing less than 1.0% of the pool, had defeased.

Twelve loans, representing 9% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.

One loan has been liquidated from the pool, resulting in realized
losses of approximately $1.1 million (36% loss severity).  There
five eight loans, representing 17% of the pool, currently in
special servicing.  The largest specially serviced loan is the
Ridgedale Center Loan ($178 million -- 8.5% of the pool), which is
secured by a 340,800 square foot regional mall located in
Minnetonka, Minnesota.  The loan is owned by an affiliate of
General Growth Properties, Inc. and was transferred to special
servicing due to GGP's bankruptcy filing.  The property is
included in the bankruptcy filing.  The mall is anchored by Sears,
JCPenney and Macy's.  In-line shops were 91% occupied as of March
2009 compared to 92% at last review.  Performance has been stable
since securitization.  Moody's LTV and stressed DSCR are 107% and
0.89X, respectively, compared to 101% and 0.94X at last review.
Moody's does not predict a loss for this loan.

The second largest specially serviced loan is the Pacific Arts
Plaza Loan ($132.0 million -- 6.3% of the pool), which is secured
by four Class A office buildings and four stand alone restaurants
located in Costa Mesa, California.  The properties total 825,000
square feet.  The loan represents a 55% pari-passu interest in a
$242 million senior loan.  The property is also encumbered by a
$28 million junior loan which is included in the trust.  The loan
sponsor is Maguire.  As of December 2008, the property was 76%
occupied compared to 82% at last review.  The loan was transferred
to special servicing in August 2009 due to imminent default and
now is 30 days delinquent.  The servicer reported a 0.92X DSCR for
the first three months of 2009.

The remaining three specially serviced loans are secured by a mix
of office (2) and multifamily properties.  Moody's estimates a
$44 million aggregate loss for four of the specially serviced
loans (25% loss severity on average).  The servicer has recognized
an aggregate $61 million appraisal reduction for four of the
specially serviced loans.

Moody's was provided with full-year 2008 operating results for 99%
of the pool.  Moody's weighted average LTV is 112% compared to
108% at last review

Moody's stressed DSCR is 1.02X, essentially the same as at last
review.  Moody's stressed DSCR is based on Moody's net cash flow
and a 9.25% stressed rate applied to the loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple-notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 27, essentially the same as at last review.

The loan with an investment grade underlying rating is the
American Express Building Loan ($11.6 million -- 0.6% of the
pool), which is secured by a 132,000 square foot flex office
building located in De Pere, Wisconsin.  The entire building is
leased to American Express Company (Moody's senior unsecured
rating A3, negative outlook) through 2044.  .  The loan's
anticipated repayment date is January 1, 2010 and the borrower has
notified the servicer that he will not be paying off the loan at
that time.  Based on the loan documents, the interest rate will be
revised and all cash flow after operating expenses will be used to
pay the revised rate and to pay down the loan.  Moody's current
underlying rating and stressed DSCR are Baa3 and 1.37X,
respectively, the same as at last review.

The largest loan that previously had an underlying rating is the
Fiesta Mall Loan ($84.0 million -- 4.0% of the pool), which is
secured by the borrower's interest in a 1.0 million square foot,
regional mall (309,000 square feet of collateral) located in Mesa,
Arizona.  The center is anchored by Dillard's, Sears and Macy's.
The in-line space was 82% occupied as of July 2009 compared to 96%
at last review.  The property's performance declined in 2009 due
to the drop in occupancy.  The loan sponsor is Westcor.  The loan
is interest only for the entire term.  Moody's LTV and stressed
DSCR are 79% and 1.27X, respectively, compared to 75% and 1.33X at
last review.

The second largest loan that previously had an underlying rating
is the Queens Atrium Loan ($74.6 million -- 3.5% of the pool),
which is secured by two office buildings containing located in
Long Island City, New York.  The two building together total
1.0 million square feet.  The property was 97% occupied as of June
2009, the same as last review.  The largest tenant is the NYC
School Construction Authority, which occupies 48% of the premises
through September 2011.  Moody's LTV and stressed DSCR are 68% and
1.52X, respectively, essentially the same as last review.

The three largest conduit loans represent 24% of the pool.  The
largest conduit loan is the Woolworth Building Loan
($200.0 million -- 9.5% of the pool), which is secured by a
812,000 square foot Class B office building located in the
downtown submarket of New York City.  The property is also
encumbered by a $50 million junior loan which is included in the
trust.  The property was nearly 98% occupied as of June 2009
compared to 100% at last review.  Moody's LTV and stressed DSCR
are 100% and 0.97X, respectively, compared to 101% and 0.94X at
last review.

The second largest conduit loan is the Marley Station Loan
($114.4 million -- 5.5% of the pool), which is secured by a two-
story regional mall located in Glen Burnie, Maryland.  The center
is anchored by Sears, JC Penney and Macy's.  Boscov's was the
fourth anchor, but after the company's bankruptcy, its space
remains dark.  The in-line space was 64% occupied as of June 2009
compared to 95% at securitization.  Moody's LTV and stressed DSCR
are 136% and 0.72X, respectively, compared to 123% and 0.77X at
last review.

The third largest conduit loan is the IPC Louisville Portfolio
Loan ($99.2 million -- 4.7% of the loan), which is secured by
eight office properties located in Kentucky, New Hampshire and
Massachusetts.  As of June 2009, the portfolio was approximately
80% occupied compared to 87% at securitization.  The portfolio's
performance has declined due to a drop in occupancy and revenue.
Moody's LTV and stressed DSCR are 105% and 0.98X, respectively,
compared to 88% and 1.17X at last review

Moody's rating action is:

  -- Class A-1, $1,544,888, affirmed at Aaa; previously assigned
     Aaa on 7/15/2005

  -- Class A-2, $505,650,000, affirmed at Aaa; previously assigned
     Aaa on 7/15/2005

  -- Class A-3A, $279,216,000, affirmed at Aaa; previously
     assigned Aaa on 7/15/2005

  -- Class A-3B, $132,000,000, affirmed at Aaa; previously
     assigned Aaa on 7/15/2005

  -- Class A-SB, $70,360,000, affirmed at Aaa; previously assigned
     Aaa on 7/15/2005

  -- Class A-4, $460,255,000, affirmed at Aaa; previously assigned
     Aaa on 7/15/2005

  -- Class A-M, $216,104,000, affirmed at Aaa; previously assigned
     Aaa on 7/15/2005

  -- Class A-J, $132,364,000, downgraded to Aa2 from Aaa;
     previously placed on review for possible downgrade on
     3/19/2009

  -- Class XC, Notional, affirmed at Aaa; previously assigned Aaa
     on 7/15/2005

  -- Class XP, Notional, affirmed at Aaa; previously assigned Aaa
     on 7/15/2005

  -- Class B, $24,312,000, downgraded to Aa3 from Aa1; previously
     placed on review for possible downgrade on 3/19/2009

  -- Class C, $24,311,000, downgraded to A1 from Aa2; previously
     placed on review for possible downgrade on 3/19/2009

  -- Class D, $21,611,000, downgraded to A3 from Aa3; previously
     placed on review for possible downgrade on 3/19/2009

  -- Class E, $37,818,000, downgraded to Baa2 from A2; previously
     placed on review for possible downgrade on 3/19/2009

  -- Class F, $21,611,000, downgraded to Baa3 from A3; previously
     placed on review for possible downgrade on 3/19/2009

  -- Class G, $29,714,000, downgraded to Ba3 from Baa2; previously
     placed on review for possible downgrade on 3/19/2009

  -- Class H, $27,013,000, downgraded to Caa1 from Baa3;
     previously placed on review for possible downgrade on
     3/19/2009

  -- Class J, $27,013,000, downgraded to Caa3 from Ba2; previously
     placed on review for possible downgrade on 3/19/2009

  -- Class K, $13,507,000, downgraded to Ca from B1; previously
     placed on review for possible downgrade on 3/19/2009

  -- Class L, $10,805,000, downgraded to Ca from B2; previously
     placed on review for possible downgrade on 3/19/2009

  -- Class M, $10,805,000, downgraded to C from B3; previously
     placed on review for possible downgrade on 3/19/2009


BANC OF AMERICA: Moody's Affirms Ratings on Eight 2006-6 Certs.
---------------------------------------------------------------
Moody's Investors Service affirmed the ratings of eight classes
and downgraded 13 classes of Banc of America Commercial Mortgage
Inc. Commercial Mortgage Pass-Through Certificates, Series 2006-6.
The downgrades are due to higher expected losses for the pool
resulting from anticipated losses from loans in special servicing,
concerns about potential losses from loans approaching maturity
within the next 24 months, and concerns about highly levered
watchlisted loans.  Eight loans, representing 21% of the pool,
mature within the next 24 months and have a Moody's stressed debt
service coverage ratio less than 1.0X.

The affirmations are due to key rating parameters, including
Moody's Loan to Value ratio, stressed debt service coverage ratio
and the Herfindahl Index, remaining within acceptable ranges.

On August 11, 2009, Moody's placed 12 classes on review for
possible downgrade due to the credit uncertainty surrounding
Maguire Properties, Inc., the sponsor of the 777 Tower Loan
($273.0 million -- 11.2% of the pool).  On November 17, 2009,
Moody's placed the mezzanine Aaa rated class (Class A-M) on review
due to increased loss projections.  This action concludes those
reviews.  The rating action is the result of Moody's on-going
surveillance of commercial mortgage backed securities
transactions.

As of the November 11, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$2.4 billion from $2.5 billion at securitization.  The
Certificates are collateralized by 117 mortgage loans ranging in
size from less than 1% to 12% of the pool, with the top ten loans
representing 62% of the pool.

Twenty-eight loans, representing 36% of the pool, are on the
master servicer's watchlist.  The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.

One loan has been liquidated from the trust since securitization,
resulting in a $115,000 loss (4% loss severity).  Three loans,
representing 2% of the pool, are currently in special servicing.
The three specially serviced loans are secured by an office
property in Maryland, a hotel property in Nevada and a retail
property in New York.  Moody's estimates an aggregate $27 million
loss (56% loss severity on average) for the specially serviced
loans.  The special servicer has recognized a $500,000 appraisal
reduction for one of the specially serviced loans.

Moody's was provided with year-end 2008 and partial year 2009
operating results for 99% and 73% of the pool, respectively.
Moody's weighted average LTV for the pool, excluding specially
serviced loans with estimated losses, is 129% compared to 136% at
Moody's last review in February 2009.  Moody's prior review was
part of the first quarter 2009 ratings sweep of 2006-2008 vintage
conduit and fusion CMBS transactions.

Moody's stressed DSCR, excluding specially serviced loans with
estimated losses, is 0.81X compared to 0.76X at last review.
Moody's stressed DSCR is based on Moody's net cash flow and a
9.25% stressed rate applied to the loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple-notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf score of 19, essentially the same as last review.

The top three loans represent 31% of the pool.  The largest loan
is the Riverchase Galleria Loan ($305 million -- 12% of the pool),
which is secured by the borrower's interest in a 1.6 million
square foot regional mall (582,000 square feet of loan collateral)
located in Hoover, Alabama.  The mall is anchored by JCPenney,
Macy's and Sears.  The property was 90% occupied as of June 2009,
essentially the same as securitization.  The loan is on the
currently on the watchlist due to the bankruptcy of the sponsor,
General Growth Properties.  The property was not included in GGP's
bankruptcy filing.  Although property performance has been stable
since securitization, the property has not achieved the increased
cash flow originally projected at securitization.  The loan has an
anticipated repayment date of October 1, 2011.  Moody's LTV and
stressed DSCR are 144% and 0.64X, respectively, compared to 140%
and 0.67X at last review.

The second largest loan is the 777 Tower Loan ($273 million -- 11%
of the pool), which is secured by a Class A office building
located in Los Angeles, California with 1.0 million square feet of
net rentable area.  The loan sponsor is Maguire.  The property was
92% leased as of September 2009 compared to 88% at securitization.
The three largest tenants are Marsh USA Inc. (13% of the NRA,
lease expiration April 2018), American Home Assurance Company
(Moody's insurance financial strength rating Aa3; negative
outlook; 11% of the NRA, lease expiration August 31, 2013) and
Kirkland & Ellis (11% of the NRA; lease expiration February 28,
2010).  Kirkland & Ellis has notified the borrower of its
intention to vacate its premises at the end of its lease term.  In
addition, several other tenants, occupying approximately 6% of the
premises, have notified the borrower of their intent to vacate in
early 2010.  Moody's is concerned about the property's near-term
lease rollover exposure, given the softness of the Los Angeles
office market and concerns about Maguire's ability to fund tenant
costs due to its current financial issues.  The loan is interest
only for its entire term.  The loan is on the servicer's watchlist
due to low debt service coverage and sponsor concerns.  Moody's
LTV and stressed DSCR are 149% and 0.65X, respectively, compared
to 146% and 0.67X at last review.

The third largest loan is The Empire Mall Loan ($176 million -- 7%
of the pool), which is secured by the borrower's interest in a
1.1 million square foot retail center located in Sioux Falls,
South Dakota.  The mall is a joint venture between the Simon
Property Group and the Macerich Company.  The anchors include
JCPenney, Younkers, Macy's and Sears.  The property was 98% leased
as of June 2009 compared with 97% at securitization..  Moody's LTV
and stressed DSCR are 118% and 0.80X, respectively, compared to
145% and 0.67X at last review.

Moody's rating action is:

  -- Class A-1, $21,110,899, affirmed at Aaa; affirmed at Aaa on
     2/6/2009

  -- Class A-1A, $428,734,011, affirmed at Aaa; previously
     affirmed Aaa on 2/6/2009

  -- Class A-2, $481,700,000, affirmed at Aaa; previously affirmed
     Aaa on 2/6/2009

  -- Class A-3, $285,000,000, affirmed at Aaa; previously affirmed
     Aaa on 2/6/2009

  -- Class A-SB, $56,830,000, affirmed awt Aaa; previously
     affirmed Aaa on 2/6/2009

  -- Class A-4, $430,105,000, affirmed at Aaa; previously affirmed
     Aaa on 2/6/2009

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

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

  -- Class A-M, $246,220,000, downgraded to Aa2 from Aaa;
     previously Aaa on review for possible downgrade 11/17/2009

  -- Class A-J, $193,900,000, downgraded to Baa2 from A2;
     previously A2, on review for possible downgrade on 8/11/2009

  -- Class B, $49,244,000, downgraded to Ba2 from Baa1, previously
     Baa1, on review for possible downgrade on 8/11/2009

  -- Class C, $24,622,000, downgraded to B1 from Baa2, previously
     Baa2, on review for possible downgrade on 8/11/2009

  -- Class D, $30,778,000, downgraded to B3 from Ba1, previously
     Ba1, on review for possible downgrade on 8/11/2009

  -- Class E, $30,777,000, downgraded to Caa2 from Ba2, previously
     Ba2 on review for possible downgrade on 8/11/2009

  -- Class F, $27,700,000, downgraded to Ca from Ba3, previously
     Ba3, on review for possible downgrade on 8/11/2009

  -- Class G, $27,700,000, downgraded to Ca from B2, previously
     B2, on review for possible downgrade on 8/11/2009

  -- Class H, $30,778,000, downgraded to Ca from B3, previously
     B3, on review for possible downgrade on 8/11/2009

  -- Class J, $6,155,000, downgraded to C from Caa1, previously
     Caa1, on review for possible downgrade on 8/11/2009

  -- Class K, $9,233,000, downgraded to C from Caa1, previously
     Caa1, on review for possible downgrade on 8/11/2009

  -- Class L, $9,234,000, downgraded to C from Caa2, previously
     Caa2, on review for possible downgrade on 8/11/2009

  -- Class M, $3,078,000, downgraded to C from Caa2, previously
     Caa2, on review for possible downgrade on 8/11/2009


BEAR STEARNS: Fitch Takes Rating Actions on 2005-PWR7 Certs.
------------------------------------------------------------
Fitch Ratings takes various rating actions on Bear Stearns
Commercial Mortgage Securities Trust's commercial mortgage pass-
through certificates, series 2005-PWR7.  A detailed list of rating
actions follows at the end of this press release.

The downgrades are the result of Fitch's loss expectations and its
prospective views regarding cash flow declines and commercial real
estate market values.  Fitch forecasts potential losses of 5.0%
for this transaction, should market conditions not recover.  The
rating actions are based on the full losses of 5.0% as a majority
of loans mature in the next five years.  The bonds with Negative
Outlooks indicate classes that may be downgraded in the future.

To determine potential defaults for each loan, Fitch assumed cash
flow would decline by 10% from year-end 2008.  That is consistent
with the analysis used in its review of recent vintage
transactions whereby cash flow was assumed to decline 15% from
year-end 2007 projected over a three-year period.  If the stressed
cash flow would cause the loan to fall below 0.95 times debt
service coverage ratio, Fitch assumed the loan would default
during the term.  To determine losses, Fitch used the above
stressed cash flow and applied a market cap rate by property type,
ranging between 7.5% and 9.5%, to derive a value.  If the loan
balance at default is less than Fitch's derived value, the loan
would realize that amount of loss.  These loss estimates were
reviewed in more detail for loans representing 55.4% of the pool
and, in certain cases, revised based on additional information
and/or property characteristics.  Loss expectations attributed to
loans reviewed in detail represent 100% of the 5.0%.

Approximately 70% of the mortgages mature within the next five
years: 0.5% in 2011, 17.5% in 2014, and 51.8% in 2015.

Fitch identified 119 Loans of Concern (25.0%) within the pool, two
of which (8.0%) are specially serviced.  Six of the Fitch Loans of
Concern (18.8%) are within the transaction's top 15 loans, and two
(8.0%) is specially serviced.

Losses are expected on five (15.5%) of the loans within the Top
15: four (14.0%) have defaulted, or are expected to default during
the term, while losses on one loan (1.5%) are expected at
maturity.  Loss severities associated with these loans range from
9% to 48%.  The largest overall contributors to deal loss are:
Shops at Boca Park (5.4%), Marquis Apartments (4.3%), and Garden
State Pavilion (2.6%).

The Shops at Boca Park loan is secured by a 277,472 square foot
lifestyle center in Summerlin, NV, northwest of Las Vegas.  The
loan transferred to the special servicer Oct. 20, 2009 for
imminent default.  As of the August 2009 rent roll, the property
was 85% occupied, down from 97.9% at issuance.  The largest
tenants are The Great Indoors (50.22% of net rentable area,
expires 2022), Recreation Equipment, Inc.  (10.6%, expires 2019)
and The Cheesecake Factory (3.55%, expires 2015).  The property
has lost a number of tenants as Las Vegas and the surrounding
suburbs have been hit by the current economic downturn.  The Las
Vegas retail market continues to see the effect of the current
economic downturn with PPR forecasting vacancy to peak at 27.5%
next year.  The servicer reported DSCR as of July 31, 2009 was
0.96x.

The Marquis Apartments loan is collateralized by a 641-unit
multifamily property in King Prussia, PA.  Property amenities
include: 24-hour security, a fitness center, outdoor and indoor
heated pool, parking, a clubhouse and large outdoor recreation
areas.  Occupancy at the property declined to 78% during the
second quarter of 2009, down from 93% at issuance.  The servicer
reported DSCR as of June 30, 2009 was 0.78x, reflecting the drop
in occupancy.  The loan remains current as of November 2009;
however, Fitch expects the loan may default during the term due to
the declining occupancy.

The Garden State Pavilion loan is secured by a 389,384 sf anchored
retail center in Cherry Hill, New Jersey.  The largest tenants at
the property are Shop Rite (27.9% of NRA, expires 2024), Ross
Stores (11.7%, expires 2015), Staples (9.2%, expires 2013), Petco
(7.3%, expires 2016), Racetrack Supermarket (3.9%, expires 2024),
and Old Country Buffet (3.9%, expires 2013).  The loan transferred
to the special servicer Jan.  5, 2009 and is currently 90+ days
delinquent.  Occupancy has dropped to 72% from 82% at issuance.
The decline in occupancy was manly driven by the loss of Old Navy
and Rack Room Shoes.  As of Sept. 20, 2009, servicer reported DSCR
was 0.54x.  The special servicer is pursuing foreclosure of the
property.

Fitch has taken these rating actions as highlighted below.  The
rating actions include downgrades, removal of classes from Rating
Watch Negative, the assignment and revision of Recovery Ratings,
Loss Severity ratings and Rating Outlooks:

  -- $85.7 million class A-J to 'AA/LS3' from 'AAA'; Outlook
     Stable;

  -- $33.7 million class B to 'A/LS4' from 'AA'; Outlook Stable;

  -- $8.4 million class C to 'BBB/LS5' from 'AA-'; Outlook Stable;

  -- $15.5 million class D to 'BB/LS5' from 'A'; Outlook Stable;

  -- $11.2 million class E to 'BB/LS5' from 'BBB+'; Outlook
     Negative;

  -- $11.2 million class F to 'BB/LS5'from 'BBB'; Outlook
     Negative;

  -- $9.8 million class G to 'B/LS5' from 'BBB-'; Outlook
     Negative;

  -- $12.7 million class H to 'B-/LS5' from 'BB-'; Outlook
     Negative;

  -- $4.2 million class J to 'B-/LS5' from 'B+'; Outlook Negative;

  -- $4.2 million class K at 'CCC/RR6' from 'B';

  -- $5.6 million class L at 'CCC'/RR6 from 'B-';

  -- $4.2 million class M at 'C/RR6' from 'CCC/RR1';

  -- $1.4 million class N at 'C/RR6' from 'CC/RR1'.

Fitch also affirms these classes and assigns LS ratings, Rating
Outlooks and revises Recovery Ratings as indicated:

  -- $170.2 million class A-2 at 'AAA/LS1'; Outlook Stable;
  -- $106 million class A-AB at 'AAA/LS1'; Outlook Stable;
  -- $527.7 million class A-3 at 'AAA/LS1'; Outlook Stable;
  -- Interest-only class X-1 at 'AAA'; Outlook Stable;
  -- Interest-only class X-2 at 'AAA'; Outlook Stable;
  -- $2.8 million class P at 'C/RR6'.

Class A-1 has paid in full.  Fitch does not rate the $14 million
class Q.


BEAR STEARNS: Moody's Reviews Ratings on 24 2007-BBA8 Certificates
------------------------------------------------------------------
Moody's Investors Service placed 24 classes of Bear Stearns 2007-
BBA8 under review for possible downgrade.  This includes ten
pooled classes due to the deterioration in the overall performance
of the assets in the trust and 14 non-pooled, or rake, classes due
to performance issues specific to the Meristar Portfolio Loan, the
Prime Hospitality Portfolio Loan, the 980 Madison Avenue Loan and
the Carr America Portfolio Loan.

The certificates are collateralized by 14 floating-rate loans.
The largest three loans account for 50.2% of the trust balance
(40.2% of the pooled balance).  The pool composition includes
hotel properties (65.6% of the pooled balance), office (31.6%) and
multifamily (2.8%).  There is currently one loan in special
servicing (Le Meridien -- 2.9% of the pooled balance).

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

Moody's rating action is:

  -- Class B, $40,782,500, Placed Under Review for Possible
     Downgrade; previously affirmed at Aaa on 3/19/2009;

  -- Class C, $40,782,500, Placed Under Review for Possible
     Downgrade; previously affirmed at Aa1 on 3/19/2009;

  -- Class D, $40,782,500, Placed Under Review for Possible
     Downgrade; previously affirmed at Aa3 on 3/19/2009;

  -- Class E, $42,636,250, Placed Under Review for Possible
     Downgrade; previously affirmed at A1 on 3/19/2009;

  -- Class F, $25,952,500, Placed Under Review for Possible
     Downgrade; previously downgraded to A3 from A2 on 3/19/2009;

  -- Class G, $24,098,750, Placed Under Review for Possible
     Downgrade; previously downgraded to Baa2 from A3 on
     3/19/2009;

  -- Class H, $18,514,262, Placed Under Review for Possible
     Downgrade; previously downgraded to Baa3 from Baa1 on
     3/19/2009;

  -- Class J, $19,588,010, Placed Under Review for Possible
     Downgrade; previously downgraded to Ba1 from Baa2 on
     3/19/2009;

  -- Class K, $24,925,228, Placed Under Review for Possible
     Downgrade; previously downgraded to Ba3 from Baa3 on
     3/19/2009;

  -- Class L, $22,245,000, Placed Under Review for Possible
     Downgrade; previously downgraded to B2 from Ba2 on 3/19/2009;

  -- Class MS-4, $55,700,000, Placed Under Review for Possible
     Downgrade; previously downgraded to Aa3 from Aa2 on
     3/19/2009;

  -- Class MS-5, $29,800,000, Placed Under Review for Possible
     Downgrade; previously downgraded to A3 from A2 on 3/19/2009;

  -- Class MS-6, $48,407,965, Placed Under Review for Possible
     Downgrade previously downgraded to Ba1 from Baa2 on
     3/19/2009;

  -- Class MS-7, $17,692,036, Placed Under Review for Possible
     Downgrade; previously downgraded to Ba3 from Baa3 on
     3/19/2009;

  -- Class PH-1, $3,632,478, Placed Under Review for Possible
     Downgrade; previously downgraded to B1 from Ba1 on 3/19/2009;

  -- Class PH-2, $9,081,195, Placed Under Review for Possible
     Downgrade; previously downgraded to B2 from Ba2 on 3/19/2009;

  -- Class PH-3, $3,664,767, Placed Under Review for Possible
     Downgrade; previously downgraded to B3 from Ba3 on 3/19/2009;

  -- Class MA-1, $4,900,000, Placed Under Review for Possible
     Downgrade; previously downgraded to Ba1 from Baa1 on
     3/19/2009;

  -- Class MA-2, $3,400,000, Placed Under Review for Possible
     Downgrade; previously downgraded to Ba2 from Baa2 on
     3/19/2009;

  -- Class MA-3, $3,500,000, Placed Under Review for Possible
     Downgrade; previously downgraded to Ba3 from Baa3 on
     3/19/2009;

  -- Class MA-4, $5,700,000, Placed Under Review for Possible
     Downgrade; previously downgraded to B1 from Ba1 on 3/19/2009;

  -- Class CA-1, $964,900, Placed Under Review for Possible
     Downgrade; previously downgraded to Baa3 from A2 on
     3/19/2000;

  -- Class CA-2, $578,940, Placed Under Review for Possible
     Downgrade; previously downgraded to Ba1 from A3 on 3/19/2009;

  -- Class CA-3, $385,960, Placed Under Review for Possible
     Downgrade; previously downgraded to Ba2 from Baa1on 3/19/2009


BEAR STEARNS: S&P Downgrades Ratings on 151 2006-R1 Certificates
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 151
classes of certificates from Bear Stearns ALT-A Trust 2006-R1, a
U.S. residential mortgage-backed securities resecuritized real
estate mortgage investment conduit transaction.  A significant
number of the downgraded classes are exchangeable certificates
that may be exchanged for combination classes.

The downgrades reflect the significant deterioration in
performance of the loans backing the underlying certificates.
This performance deterioration is so severe that the credit
enhancement for BSAA 2006-R1 is insufficient to maintain the
previous ratings on the re-REMIC classes.  Classes V-A-1, VI-A-1,
VII-A-1, VIII-A-1, and IX-A-1 are backed by a certificate
insurance policy from Ambac Assurance Corp.  The ratings on these
classes are the greater of the rating on Ambac and the standalone
ratings on the classes without the benefit of the insurance.

BSAA 2006-R1, which closed in September 2006, is collateralized by
10 underlying classes from two different trusts that support 10
independent groups within the re-REMIC.  The loans securing the 10
underlying classes consist predominantly of long-reset adjustable-
rate Alternative-A mortgage loans.

The groups I through IX certificates from BSAA 2006-R1 are
supported by nine classes from Bear Stearns ALT-A Trust 2006-4.
The group I certificates are supported by class II-3A-3 (currently
rated 'CCC').  The group II certificates are supported by class
II-3A-4 (currently rated 'CCC').  The group III certificates are
supported by class III-3A-2 (currently rated 'CCC').  The group IV
certificates are supported by class III-3A-3 (currently rated
'CCC').  The group V certificate is supported by class II-2A-2
(currently rated 'D').  The group VI certificate is supported by
class II-3A-5 (currently rated 'D').  The group VII certificate is
supported by class III-1A-2 (currently rated 'CCC').  The group
VIII certificate is supported by class III-2A-2 (currently rated
'CCC').  The group IX certificate is supported by class III-3A-4
(currently rated 'CCC').  The group X certificates from BSAA 2006-
R1 are supported by class II-B-1 from Bear Stearns ALT-A Trust
2006-5 (currently rated 'D').

The performance of the loans securing the group II structure for
classes II-2A-2, II-3A-3, II-3A-4, and II-3A-5 from Bear Stearns
ALT-A Trust 2006-4 has declined significantly in recent months.
The group II pool had experienced losses of 10.31% of the original
pool balance as of the October 2009 distribution, and currently
has approximately 44.45% of the current pool balance in delinquent
loans.  Based on the losses to date, the current pool factor of
0.5254 (52.54%), which represents the outstanding pool balance as
a proportion of the original balance, and the pipeline of
delinquent loans, S&P's current projected loss for this pool is
24.46%, which exceeds the level of credit enhancement available to
cover losses.

The performance of the loans securing the group III structure for
classes III-1A-2, III-2A-2, III-3A-2, III-3A-3, and III-3A-4 from
Bear Stearns ALT-A Trust 2006-4 has declined precipitously in
recent months.  The group III pool had experienced losses of 5.24%
of the original pool balance as of the October 2009 distribution,
and currently has approximately 42.81% of the current pool balance
in delinquent loans.  Based on the losses to date, the current
pool factor of 0.6065 (60.65%), and the pipeline of delinquent
loans, S&P's current projected loss for this pool is 20.67%, which
exceeds the level of credit enhancement available to cover losses.

The performance of the loans securing the group II structure for
class II-B1 from Bear Stearns ALT-A Trust 2006-5 has been
deteriorating sharply in recent months.  The group II pool had
experienced losses of 5.45% of the original pool balance as of the
October 2009 distribution, and currently has approximately 43.88%
of the current pool balance in delinquent loans.  Based on the
losses to date, the current pool factor of 0.5807 (58.07%), and
the pipeline of delinquent loans, S&P's current projected loss for
this pool is 20.41%, which exceeds the level of credit enhancement
available to cover losses.

Over the past two years, S&P has revised its RMBS default and loss
assumptions, and consequently 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 expectation.

                         Ratings Lowered

                Bear Stearns ALT-A Trust 2006-R1
                          Series 2006-R1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        I-A-1      073866AA3     CC                   AAA
        I-X-1      073866AB1     CC                   AAA
        I-X-2      073866AC9     CC                   AAA
        I-X-3      073866AD7     CC                   AAA
        I-X-4      073866AE5     CC                   AAA
        I-X-5      073866AF2     CC                   AAA
        I-AE-1                   CC                   AAA
        I-AE-2                   CC                   AAA
        I-AE-3                   CC                   AAA
        I-AE-4                   CC                   AAA
        I-AE-5                   CC                   AAA
        I-AE-6                   CC                   AAA
        I-AE-7                   CC                   AAA
        I-AE-8                   CC                   AAA
        I-AE-9                   CC                   AAA
        I-AE-10                  CC                   AAA
        I-AE-11                  CC                   AAA
        I-AE-12                  CC                   AAA
        I-AE-13                  CC                   AAA
        I-AE-14                  CC                   AAA
        I-AE-15                  CC                   AAA
        I-AE-16                  CC                   AAA
        I-AE-17    073866BJ3     CC                   AAA
        I-AE-18                  CC                   AAA
        I-AE-19                  CC                   AAA
        I-AE-20                  CC                   AAA
        I-AE-21                  CC                   AAA
        I-AE-22                  CC                   AAA
        I-AE-23                  CC                   AAA
        I-AE-24                  CC                   AAA
        I-AE-25                  CC                   AAA
        I-AE-26                  CC                   AAA
        I-AE-27                  CC                   AAA
        I-AE-28                  CC                   AAA
        I-AE-29                  CC                   AAA
        I-AE-30                  CC                   AAA
        II-A-1     073866AG0     CC                   AAA
        II-X-1     073866AJ4     CC                   AAA
        II-X-2     073866AK1     CC                   AAA
        II-X-3     073866AL9     CC                   AAA
        II-X-4     073866AM7     CC                   AAA
        II-X-5     073866AN5     CC                   AAA
        II-AE-1                  CC                   AAA
        II-AE-2                  CC                   AAA
        II-AE-3                  CC                   AAA
        II-AE-4                  CC                   AAA
        II-AE-5                  CC                   AAA
        II-AE-6                  CC                   AAA
        II-AE-7                  CC                   AAA
        II-AE-8                  CC                   AAA
        II-AE-9                  CC                   AAA
        II-AE-10                 CC                   AAA
        II-AE-11                 CC                   AAA
        II-AE-12                 CC                   AAA
        II-AE-13   073866BK0     CC                   AAA
        II-AE-14                 CC                   AAA
        II-AE-15                 CC                   AAA
        II-AE-16                 CC                   AAA
        II-AE-17                 CC                   AAA
        II-AE-18                 CC                   AAA
        II-AE-19                 CC                   AAA
        II-AE-20   073866BL8     CC                   AAA
        II-AE-21   073866BN4     CC                   AAA
        II-AE-22                 CC                   AAA
        II-AE-23                 CC                   AAA
        II-AE-24                 CC                   AAA
        II-AE-25                 CC                   AAA
        II-AE-26                 CC                   AAA
        II-AE-27                 CC                   AAA
        II-AE-28                 CC                   AAA
        II-AE-29                 CC                   AAA
        II-AE-30                 CC                   AAA
        III-A-1    073866AP0     CCC                  AAA
        III-X-1    073866AQ8     CCC                  AAA
        III-X-2    073866AR6     CCC                  AAA
        III-X-3    073866AS4     CCC                  AAA
        III-X-4    073866AT2     CCC                  AAA
        III-X-5    073866AU9     CCC                  AAA
        III-AE-1                 CCC                  AAA
        III-AE-2                 CCC                  AAA
        III-AE-3                 CCC                  AAA
        III-AE-4                 CCC                  AAA
        III-AE-5                 CCC                  AAA
        III-AE-6                 CCC                  AAA
        III-AE-7                 CCC                  AAA
        III-AE-8                 CCC                  AAA
        III-AE-9                 CCC                  AAA
        III-AE-10                CCC                  AAA
        III-AE-11                CCC                  AAA
        III-AE-12                CCC                  AAA
        III-AE-13                CCC                  AAA
        III-AE-14                CCC                  AAA
        III-AE-15                CCC                  AAA
        III-AE-16                CCC                  AAA
        III-AE-17                CCC                  AAA
        III-AE-18                CCC                  AAA
        III-AE-19                CCC                  AAA
        III-AE-20                CCC                  AAA
        III-AE-21                CCC                  AAA
        III-AE-22                CCC                  AAA
        III-AE-23                CCC                  AAA
        III-AE-24                CCC                  AAA
        III-AE-25                CCC                  AAA
        III-AE-26                CCC                  AAA
        III-AE-27                CCC                  AAA
        III-AE-28                CCC                  AAA
        III-AE-29                CCC                  AAA
        III-AE-30  073866BM6     CCC                  AAA
        IV-A-1     073866AV7     CCC                  AAA
        IV-X-1     073866AH8     CCC                  AAA
        IV-X-2     073866AW5     CCC                  AAA
        IV-X-3     073866AX3     CCC                  AAA
        IV-X-4     073866AY1     CCC                  AAA
        IV-X-5     073866AZ8     CCC                  AAA
        IV-AE-1                  CCC                  AAA
        IV-AE-2                  CCC                  AAA
        IV-AE-3                  CCC                  AAA
        IV-AE-4                  CCC                  AAA
        IV-AE-5                  CCC                  AAA
        IV-AE-6                  CCC                  AAA
        IV-AE-7                  CCC                  AAA
        IV-AE-8                  CCC                  AAA
        IV-AE-9                  CCC                  AAA
        IV-AE-10                 CCC                  AAA
        IV-AE-11                 CCC                  AAA
        IV-AE-12                 CCC                  AAA
        IV-AE-13                 CCC                  AAA
        IV-AE-14                 CCC                  AAA
        IV-AE-15                 CCC                  AAA
        IV-AE-16                 CCC                  AAA
        IV-AE-17                 CCC                  AAA
        IV-AE-18                 CCC                  AAA
        IV-AE-19                 CCC                  AAA
        IV-AE-20                 CCC                  AAA
        IV-AE-21                 CCC                  AAA
        IV-AE-22   073866BH7     CCC                  AAA
        IV-AE-23                 CCC                  AAA
        IV-AE-24                 CCC                  AAA
        IV-AE-25                 CCC                  AAA
        IV-AE-26                 CCC                  AAA
        IV-AE-27                 CCC                  AAA
        IV-AE-28                 CCC                  AAA
        IV-AE-29                 CCC                  AAA
        IV-AE-30                 CCC                  AAA
        V-A-1      073866BA2     CC                   AAA
        VI-A-1     073866BB0     CC                   AAA
        VII-A-1    073866BC8     CCC                  AAA
        VIII-A-1   073866BD6     CCC                  AAA
        IX-A-1     073866BE4     CCC                  AAA
        X-A-1      073866BF1     D                    AA
        X-X-1      073866BG9     D                    AA


BEAR STEARNS: S&P Downgrades Ratings on 15 2007-Top26 Securities
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 15
classes of commercial mortgage-backed securities from Bear Stearns
Commercial Mortgage Securities Trust 2007-Top26 and removed them
from CreditWatch with negative implications.  In addition, S&P
affirmed its ratings on eight 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 its rating actions.  The downgrades of the subordinate
classes also reflect credit support erosion S&P anticipate will
occur upon the eventual resolution of one specially serviced loan,
as well as its analysis of two loans that 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, S&P calculated an adjusted debt service coverage of
1.70x and a loan-to-value ratio of 98.2%.  S&P further stressed
the loans' cash flows under S&P's 'AAA' scenario to yield a
weighted average DSC of 1.00x and an LTV of 138.2%.  The implied
defaults and loss severity under the 'AAA' scenario were 76.0% and
33.0%, respectively.  All of the DSC and LTV calculations S&P
noted above exclude one of the four specially serviced loans
($4.2 million 0.2%) and the two loans that S&P deemed to be
credit-impaired ($18.8 million, 0.9%).  S&P separately estimated
losses for these loans, which S&P included in its 'AAA' scenario
implied default and loss figures.

The affirmation of the ratings on the principal and interest
certificates reflects subordination levels that 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 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.

                       Credit Considerations

As of the November 2009 remittance report, four loans
($89.3 million total exposure, 4.1%) in the pool are with the
special servicer, Centerline Servicing Inc. (Centerline),
including one of the top 10 loans, which S&P discuss in detail
below.  The specially serviced loans by payment status are: two
are more than 90 days delinquent ($13.7 million, 0.7%); one is 60
days delinquent ($65.0 million, 3.1%); and one is current
($7.2 million, 0.4%).

The Viad Corporate Center loan is the sixth-largest loan in the
pool and the largest loan with the special servicer.  The loan has
a trust balance of $65.0 million (3.1%) and is secured by a 24-
story 476,000?sq.-ft. class A office building in Phoenix, Ariz.
The reported DSC for the property as of year-end 2008 was 1.18x,
down from 1.23x at issuance.  The loan was transferred to the
special servicer on March 23, 2009, due to imminent default, and
it was 60 days delinquent as of the November 2009 remittance
report.  Centerline is reviewing a modification proposal sent by
the borrower, and Standard & Poor's will continue to monitor this
loan.

The three remaining specially serviced loans have balances that
individually represent less than 0.5% of the total pool balance.
Standard & Poor's estimated losses for one of these loans.  The
remaining two loans with the special servicer are potential
candidates for modifications and have reported DSCs of 1.33x and
2.20x.  In addition to the specially serviced loans, S&P deemed
two loans ($18.8 million, 0.9%) to be credit-impaired due to an
increased risk of default because of a decrease in DSC attributed
to a substantial drop in occupancy.

                       Transaction Summary

As of the November 2009 remittance report, the collateral pool
balance was $2.08 billion, which is approximately 98.7% of the
balance at issuance.  There are currently 235 loans in the pool,
down from 237 at issuance.  The master servicers for the
transaction, Wells Fargo Bank N.A.  (Wells Fargo) and Midland Loan
Services Inc., provided financial information for 99.8% of the
pool, and 99.1% of the financial information was full-year 2008 or
interim-2009 data.  S&P calculated a weighted average DSC of 1.79x
for the pool based on the reported figures.  S&P's adjusted DSC
and LTV were 1.70x and 98.2%, respectively.  S&P's adjusted DSC
and LTV figures exclude one of the four specially serviced loans
($4.2 million 0.2%) and the two loans that S&P deemed to be
credit-impaired ($18.8 million, 0.9%), for which S&P separately
estimated losses.  Wells Fargo provided DSC figures for all three
loans, and based on these figures, S&P calculated a weighted
average DSC of 0.75x.  The transaction has not experienced any
principal losses to date.  Thirty-six loans ($257.1 million,
12.4%) are on the master servicers' watchlists, including one of
the top 10 loans, which S&P discuss in detail below.  Twenty-six
loans ($143.9 million, 6.9%) have a reported DSC below 1.10x, and
20 of these loans ($121.6 million, 5.9%) have a reported DSC of
less than 1.0x.

                     Summary Of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$707.3 million (34.0%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.98x for the top 10 loans.
One of the top 10 loans ($65.0 million, 3.1%) is with the special
servicer, and one of the top 10 loans ($45.0 million, 2.2%)
appears on the master servicer's watchlist, which S&P discuss in
detail below.  S&P's adjusted DSC and LTV for the top 10 loans are
1.76x and 95.3%, respectively.

The DoubleTree Hotel Jersey City loan is the eighth-largest loan
in the pool and the largest loan on the master servicer's
watchlist, with a trust balance of $45.0 million (2.2%).  The loan
is secured by a 198-room hotel property in Jersey City, N.J.  The
loan appears on the watchlist due to a drop in DSC and occupancy.
The servicer reported a DSC of 0.66x for the six months ended
June 30, 2009, down from 2.07x at issuance.  However, the loan was
reported as current in its payment status as of the November 2009
remittance report.

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

      Ratings Lowered And Removed From Creditwatch Negative

   Bear Stearns Commercial Mortgage Securities Trust 2007-Top26
           Commercial mortgage pass-through certificates
            Rating
                  ------
      Class     To      From            Credit enhancement (%)
      -----     --      ----            ----------------------
      A-M       A       AAA/Watch Neg                    17.23
      A-J       BBB     AAA/Watch Neg                     9.50
      B         BB+     AA/Watch Neg                      7.47
      C         BB      AA-/Watch Neg                     6.59
      D         BB-     A/Watch Neg                       5.19
      E         B+      A-/Watch Neg                      4.43
      F         B+      BBB+/Watch Neg                    3.55
      G         B       BBB/Watch Neg                     2.66
      H         B-      BBB-/Watch Neg                    1.77
      J         B-      BB+/Watch Neg                     1.65
      K         CCC+    BB/Watch Neg                      1.52
      L         CCC+    BB-/Watch Neg                     1.27
      M         CCC     B+/Watch Neg                      1.14
      N         CCC     B/Watch Neg                       0.89
      O         CCC-    B-/Watch Neg                      0.76

                         Ratings Affirmed

   Bear Stearns Commercial Mortgage Securities Trust 2007-Top26
          Commercial mortgage pass-through certificates

          Class      Rating      Credit enhancement (%)
          -----      ------      ----------------------
          A-1        AAA                          27.36
          A-2        AAA                          27.36
          A-3        AAA                          27.36
          A-AB       AAA                          27.36
          A-4        AAA                          27.36
          A-1A       AAA                          27.36
          X-1        AAA                            N/A
          X-2        AAA                            N/A

                       N/A - Not applicable.


BRYANT PARK: Moody's Confirms Ratings on Three Classes of Notes
---------------------------------------------------------------
Moody's Investors Service announced that it has confirmed the
ratings of these notes issued by Bryant Park CDO Ltd., a synthetic
collateralized loan obligation issued in January 2005 referencing
a portfolio of primarily senior secured loans and structured
finance securities:

  -- US$23,000,000 Class A-1 Floating Rate Senior Notes Due
     2019 (current balance of $13,401,991), Confirmed at A1;
     previously on April 16, 2009 A1 Placed Under Review for
     Possible Downgrade;

  -- US$28,000,000 Class A-2 Floating Rate Senior Notes Due
     2019, Confirmed at Baa1; previously on February 5, 2009
     Downgraded to Baa1 and Placed Under Review for Possible
     Downgrade;

  -- US$30,000,000 Class B Floating Rate Deferrable Senior
     Subordinate Notes Due 2019, Confirmed at B3; previously on
     June 9, 2009 Downgraded to B3 and Placed Under Review for
     Possible Downgrade.

According to Moody's, the rating actions reflect the action taken
by Moody's on the insurance financial strength rating of Assured
Guaranty Municipal Corp. (formerly Financial Security Assurance
Inc.), which acts as Guarantor under the Investment Agreement in
the transaction.  On November 12, 2009, Moody's confirmed the Aa3
insurance financial strength rating of Assured Guaranty Municipal
Corp. with a negative outlook.  Moody's also notes that the deal
has demonstrated relatively stable credit performance since the
last rating actions taken on June 9, 2009.  In particular, the
weighted average rating factor has increased only slightly and is
currently 2879 as of the last trustee report, dated October 2,
2009, versus 2795 as of the May 10, 2009 trustee report.
Additionally, securities rated B3 and below make up approximately
14.7% of the underlying portfolio in October as compared to 14.96%
in May.  Moody's also observes that although the Class A, B and C
overcollateralization levels have deteriorated since the previous
rating action, the Class A-1 Notes have delevered considerably and
will likely continue to delever as a result of the diversion of
excess spread due to the failure of the Class B and C
overcollateralization tests.  In particular, the Class A-1 Notes
received approximately $3.3M on the last payment date in October.
Finally, Moody's notes that although the transaction is exposed to
a significant concentration of mezzanine and junior CLO tranches
in the underlying portfolio, Moody's has already completed its
review of U.S. cash flow CLOs and expects most of these CLOs'
ratings to be remain stable in the near term.

On February 5, 2009, Moody's downgraded the Class A-1 Notes, Class
A-2 Notes , Class B Notes and Class C Notes as a result of the
additional risk posed to the noteholders due to the action taken
by Moody's on the insurance financial strength rating of Financial
Security Assurance Inc. On November 21, 2008, Moody's downgraded
the financial strength rating of Financial Security Assurance Inc.
to Aa3 from Aaa.  On June 9, 2009 the Class B Notes and Class C
Notes were further downgraded as a result of the application of
revised and updated CLO modeling assumptions as well as the
deterioration in the credit quality of the transaction's
underlying portfolio.  The Class A-1 Notes and Class A-2 Notes
remained on review for possible downgrade, because Financial
Security Assurance Inc. was placed under review for possible
downgrade on May 20, 2009.  The Class B Notes also remained on
review for possible downgrade due to the high concentration of CLO
tranches in the underlying portfolio.


BUCHANAN SPC: S&P Withdraws 'D' Ratings on Various Classes
----------------------------------------------------------
Standard & Poor's Ratings Services withdrew its 'D' ratings on the
notes issued by Buchanan SPC's series 2006-I, 2006-II, 2006-III,
and 2006-IV, all U.S. synthetic collateralized debt obligation
transactions backed by mezzanine tranches of residential mortgage-
backed securities transactions.

S&P withdrew its ratings after the tranches incurred full
principal losses, which resulted from the credit events of the
underlying reference entities.

                        Ratings Withdrawn

                          Buchanan SPC

                                                 Rating
                                                 ------
     Series             Class                  To       From
     ------             -----                  --       ----
     2006-I             A1J                    NR       D
     2006-II            A2                     NR       D
     2006-III           A4                     NR       D
     2006-IV            B                      NR       D


CAPITAL AUTO: S&P Raises Ratings on Six Classes of Notes
--------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on six
classes of notes issued from Capital Auto Receivables Trust's
series 2007-SN1, 2007-SN2, and 2007-SNE.  At the same time, S&P
affirmed the ratings on nine classes of notes issued from CARAT's
series 2007-SN1, 2007-SN2, 2007-SNG, 2008-SNA, 2008-SNB, 2008-SND,
and 2008-SNH.

The upgrades reflect S&P's view of the substantial and ongoing
increase in credit enhancement available to the classes, as a
percent of the current pool balance, due to amortization and the
improved residual value of the collateral, which has helped all of
the transactions build or maintain credit support to their
required levels as specified in the related transaction documents.
Credit enhancement for the upgraded securities is currently
consistent with S&P's residual loss stresses for these specific
transactions at the raised rating levels.

On March 12, 2009, S&P lowered its ratings on 11 classes of notes
issued from CARAT's series 2007-SN1, 2007-SN2, 2007-SNE, 2007-SNG,
2008-SNA, 2008-SNB, and 2008-SND because of the substantial
decrease in residual values of the vehicles coming off lease
compared with their initial base residual values set at close for
the transactions.  The base residual value reflects the lower of
the contract value and a third-party forecast.  At that point in
time, S&P revised its residual loss expectations and stated that
S&P no longer believed that the current credit enhancement in
these transactions was sufficient to maintain the previous ratings
when S&P considered its revised residual loss stress assumptions.
However, as a result of the amortization of the collateral and the
improved residual values of the collateral, the amount of hard
credit enhancement has increased since S&P's March 2009 review.

The affirmations reflect S&P's view that the credit enhancement
for the affirmed ratings is consistent with S&P's residual stress
scenarios for the current rating levels.

                             Table 1

                    REVISED RESIDUAL STRESS*

        Rating category      Revised residual stress (%)(i)
        ---------------      ------------------------------
        AAA                  40-45
        AA                   35-40
        A                    30-35
        BBB                  25-30

                       * As of March 2009.

(i) The residual stress percentages are expressed as a percentage
    of the original base residual value and are approximations
    pertaining only to the specific transactions in this press
    release.

As of the October 2009 distribution period, the base residual
value made up approximately 70%-90% of the current securitized
balance for all of the outstanding transactions, up from
approximately 58%-64% at close.  The underlying collateral for all
of the transactions experienced residual gains between the July
2009 and October 2009 distribution periods, and these trends are
vastly different from those in the prior months.  In most of the
months prior, each transaction experienced residual losses from
the returned cars after their respective leases ended.  Despite
the improvement, S&P's residual rating stress scenarios continue
to incorporate residual loss assumptions that are consistent with
the double-digit losses that were displayed in late 2008 through
early 2009.  Nevertheless, S&P believes the upgraded notes are
currently enhanced to a level that is consistent with S&P's
residual rating level stresses, which S&P revised in March 2009.
The current level of credit enhancement for these classes is
higher than at the time of S&P's March 2009 rating actions.
Additionally, residual values have not continued to deteriorate;
instead, they have increased.  Many of the transactions originated
in 2007 and 2008 have lease termination dates that are
concentrated over a very short period of time.  S&P believes this
heightens residual value risk because a significant percentage of
leases could be exposed to the same event and market-value risk
that may be present at the time these leases mature.  S&P factored
the residual maturity schedule concentrations into S&P's analysis
and believe that the credit enhancement is sufficient to maintain
the ratings at their raised and affirmed levels.

All of the transactions S&P reviewed are structured with hard
credit support in the form of overcollateralization and a reserve
account.  In addition, the class A, B, and C notes issued from
CARAT's series 2007-SN1 and 2007-SN2 benefit from subordination.
Currently, the reserve account and overcollateralization for each
transaction are at their respective targets.  At the time of the
March 2009 rating actions, the reserve accounts for CARAT's series
2007-SN1 and 2007-SN2 were being drawn on to cover losses.  These
accounts have since built back to their required levels, as
specified in the related transaction documents, largely because of
the residual gains over the past couple months.  In addition to
the hard credit support, all of the transactions benefit from
monthly excess spread.

                             Table 2
                       Hard Credit Support

                                          Total hard credit
       Series     Class  Pool factor (%)  support* (%)
       ------     -----  ---------------  -----------------
       2007-SN1   A      32.51                   53.37
       2007-SN1   B      32.51                   46.45
       2007-SN1   C      32.51                   39.68
       2007-SN1   D      32.51                   32.30
       2007-SN2   A      48.31                   42.44
       2007-SN2   B      48.31                   36.75
       2007-SN2   C      48.31                   30.02
       2007-SN2   D      48.31                   23.81
       2007-SNE   A      52.30                   32.69
       2007-SNG   A      64.50                   28.29
       2008-SNA   A      66.62                   26.50
       2008-SNB   A      66.97                   26.20
       2008-SND   A      72.48                   27.25
       2008-SNH   A      61.67                   51.23

* Consists of overcollateralization and a reserve account as of
  the October 2009 distribution period.  In addition, credit
  support includes subordination for the class A, B, and C notes
  from series 2007-SN1 and 2007-SN2.

Furthermore, S&P has revised its expected cumulative net credit
losses based on the current performance for each transaction (see
table 3).  Credit losses for most of the transactions remain in
line with or lower than S&P's initial expectations.  However, S&P
has slightly increased its credit loss expectation for the CARAT
2008-SND transaction.

                             Table 3

                 Expected Cumulative Net Losses
            As of the October 2009 Distribution Month

                                      Initial      Revised
                   Pool      Current  expected     expected
        Series     factor(%) CNL* (%) CNL (%)      CNL (%)
        ------     --------  -------  --------     --------
        2007-SN1   32.51     0.98     1.60-1.70    1.50-1.60
        2007-SN2   48.31     0.60     1.65-1.75    1.35-1.45
        2007-SNE   52.30     0.99     2.10-2.20    2.10-2.20
        2007-SNG   64.50     0.75     2.35-2.45    2.20-2.30
        2008-SNA   66.62     0.59     2.15-2.25    1.95-2.05
        2008-SNB   66.97     0.52     2.10-2.20    1.95-2.05
        2008-SND   72.48     0.48     1.55-1.65    1.95-2.05
        2008-SNH   61.67     0.33     3.80-3.90    1.95-2.05

                  * CNL -- Cumulative net losses.

Standard & Poor's believes the remaining credit support will be
sufficient to support the notes at the raised and affirmed rating
levels.

                         Ratings Raised

               Capital Auto Receivables Asset Trust

                                      Rating
                                      ------
                Series    Class   To         From
                ------    -----   --         ----
                2007-SN1  B       AAA        A+
                2007-SN1  C       AA-        BBB
                2007-SN1  D       BBB        BB
                2007-SN2  B       AA-        A
                2007-SN2  C       BBB        BBB-
                2007-SNE  A       A-         BBB+

                        Ratings Affirmed

               Capital Auto Receivables Asset Trust

                    Series    Class   Rating
                    ------    -----   ------
                    2007-SN1  A-4     AAA
                    2007-SN2  A-3     AAA
                    2007-SN2  A-4     AAA
                    2007-SN2  D       BB-
                    2007-SNG  A       BBB
                    2008-SNA  A       BBB
                    2008-SNB  A       BBB
                    2008-SND  A       BBB
                    2008-SNH  A       AAA


CAPMARK VII: Moody's Reviews Ratings on 11 Classes of Notes
-----------------------------------------------------------
Moody's Investors Service placed eleven classes of Notes issued by
Capmark VII -- CRE Ltd. on review for possible downgrade due to
deterioration in the credit quality of the underlying portfolio.

Capmark VII -- CRE Ltd. is a revolving commercial real estate
collateralized debt obligation transaction backed by a portfolio
of whole loan debt (100% of the pool).  As of October 7, 2009, the
aggregate Notes balance of the transaction, including the Income
Notes, has decreased to $917 million from $1,000 million at
issuance, due to an approximately $87 million pay-down to the
Class A-1Notes.  The pay-down was triggered as a result of the
failing of the Class A/B, Class C/D/E, and Class F/G/H Principal
Coverage Tests.  The trustee reported Class A/B Principal Coverage
Test is 112.9% (versus trigger of 115.0%) compared to 116.5% at
last review.  Per the Indenture, the failure of any Principal
Coverage Test results in all scheduled interest and principal
payments being directed to pay down the most senior notes, until
the Principal Coverage Test is satisfied.  As a result, interest
shortfalls have reached Class C which is now PIKing versus Class F
at last review.

Eight assets totaling over $125 million par amount (14% of the
pool) were listed as defaulted.  Moody's has identified these
parameters as key indicators of the expected loss within CRE CDO
transactions: weighted average rating factor, weighted average
life, weighted average recovery rate, and Moody's asset
correlation.  Moody's review will focus on potential losses from
defaulted collateral and any changes in the key rating parameters.

Capmark Finance Inc, as the advancing agent for the deal, is
responsible for future funding obligations that represent
approximately 18% of the deal.  Capmark Finance Inc., filed for
Chapter 11 bankruptcy in October 2009.  Moody's downgraded the
ratings of the parent company, Capmark Financial Group Inc.
(Capmark), to C on September 4, 2009, following Capmark's
announcement of its potential sale, second quarter 2009 operating
results and its restructuring efforts.

Capmark Investments, L.P., is the Collateral Manager and was not
an entity listed in the bankruptcy.  In July 2009, Capmark sold
the management contracts of the CRE CDO to Urdang Capital
Management Inc. and entered into a non-discretionary sub-advisory
agreement with Urdang.

The rating action is:

  -- Cl. A-1, Aaa Placed Under Review for Possible Downgrade;
     previously on August 31, 2006 Assigned Aaa

  -- Cl. A2, Baa3 Placed Under Review for Possible Downgrade;
     previously on April 9, 2009 Downgraded to Baa3

  -- Cl. B, B2 Placed Under Review for Possible Downgrade;
     previously on April 9, 2009 Downgraded to B2

  -- Cl. C, Caa2 Placed Under Review for Possible Downgrade;
     previously on April 9, 2009 Downgraded to Caa2

  -- Cl. D, Caa3 Placed Under Review for Possible Downgrade;
     previously on April 9, 2009 Downgraded to Caa3

  -- Cl. E, Caa3 Placed Under Review for Possible Downgrade;
     previously on April 9, 2009 Downgraded to Caa3

  -- Cl. F, Caa3 Placed Under Review for Possible Downgrade;
     previously on April 9, 2009 Downgraded to Caa3

  -- Cl. G, Caa3 Placed Under Review for Possible Downgrade;
     previously on April 9, 2009 Downgraded to Caa3

  -- Cl. H, Caa3 Placed Under Review for Possible Downgrade;
     previously on April 9, 2009 Downgraded to Caa3

  -- Cl. J, Ca Placed Under Review for Possible Downgrade;
     previously on April 9, 2009 Downgraded to Ca

  -- Cl. K, Ca Placed Under Review for Possible Downgrade;
     previously on April 9, 2009 Downgraded to Ca

Moody's monitors transactions on both a monthly basis through a
review of the available Trustee Reports and a periodic basis
through a full review.  Moody's prior review is summarized in a
press release dated April 9, 2009.


CHASE MORTGAGE: S&P Downgrades Ratings on 16 2007-A1 Securities
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 16
classes from Chase Mortgage Finance Trust Series 2007-A1, a U.S.
seasoned prime jumbo residential mortgage-backed securities
transaction issued in 2007.  Additionally, S&P affirmed its
ratings on 15 classes from this transaction.

The downgrades and affirmations incorporate S&P's current and
projected losses based on the dollar amounts of loans currently in
the transactions' delinquency, foreclosure, and real estate owned
pipelines, as well as S&P's projection of future defaults.  S&P
also incorporated cumulative losses to date in its analysis when
assessing rating outcomes.

For information on how S&P derives its loss assumptions, S&P's use
of loss curve forecasting methodology, and how S&P incorporate
each transaction's current delinquency (including 60- and 90-day
delinquencies), default, and loss trends into S&P's analysis,
please see the articles list in the Related Research section
below.

As part of its analysis, S&P considered the characteristics of the
underlying mortgage collateral, as well as macroeconomic
influences.  For example, S&P's assessment of the risk profile of
the underlying mortgage pools influences its default projections,
while S&P's outlook for housing price declines and the health of
the housing market influence its loss severity assumptions.

The lowered ratings reflect S&P's belief that the amount of credit
enhancement available for the downgraded classes is not sufficient
to cover losses at the previous rating levels, given S&P's current
projected losses.

The affirmations reflect S&P's belief that there is sufficient
credit enhancement to support the ratings at their current levels.
Certain senior classes also benefit from senior-support classes
that would provide support to a certain extent before any
applicable losses could affect the super-senior certificates.  The
subordination of classes within the structure provides credit
support for the transaction.

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.  For prime jumbo
transactions, 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 235% for a 'AAA' rating.  For example, in general,
S&P would assess whether one class could withstand approximately
127% 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 154% 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 235% of its
base-case loss assumptions under its analysis.

The collateral backing this deal originally consisted
predominantly of seasoned prime jumbo adjustable-rate mortgage
loans secured by one- to four-family properties.

S&P monitors these transactions to incorporate updated losses and
delinquency pipeline performance to assess whether, in S&P's view,
the applicable credit enhancement features are sufficient to
support the current ratings.  S&P will continue to monitor this
transaction and take additional rating actions as S&P deems
appropriate.

                         Ratings Lowered

           Chase Mortgage Finance Trust Series 2007-A1
                       Series      2007-A1

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       1-A2       161630AB4     BBB-                 AAA
       1-A6       161630AF5     BBB-                 AAA
       2-A4       161630AK4     BBB-                 AAA
       3-A2       161630AM0     BBB-                 AAA
       4-A2       161630AP3     BBB-                 AAA
       5-A1       161630AQ1     AA                   AAA
       5-A2       161630AR9     BBB-                 AAA
       7-A2       161630AV0     BBB-                 AAA
       8-A2       161630AX6     BBB-                 AAA
       10-A1      161630BA5     AA                   AAA
       10-A2      161630BB3     BBB-                 AAA
       I-M        161630CP1     CCC                  AA
       I-B1       161630CR7     CC                   A
       I-B2       161630CT3     CC                   BBB
       I-B3       161630CX4     CC                   BB
       I-B4       161630CZ9     CC                   B

                        Ratings Affirmed

           Chase Mortgage Finance Trust Series 2007-A1
                       Series      2007-A1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 1-A1       161630AA6     AAA
                 1-A3       161630AC2     AAA
                 1-A4       161630AD0     AAA
                 1-A5       161630AE8     AAA
                 2-A1       161630AG3     AAA
                 2-A2       161630AH1     AAA
                 2-A3       161630AJ7     AAA
                 3-A1       161630AL2     AAA
                 4-A1       161630AN8     AAA
                 6-A1       161630AS7     AAA
                 6-A2       161630AT5     AAA
                 7-A1       161630AU2     AAA
                 8-A1       161630AW8     AAA
                 9-A1       161630AY4     AAA
                 9-A2       161630AZ1     AAA


CITY OF ALHAMBRA: Fitch Assigns 'BB' Rating on $43.3 Mil. Bonds
---------------------------------------------------------------
Fitch Ratings has assigned its 'BB' rating on the expected
issuance of approximately $43.3 million City of Alhambra,
California revenue bonds (Atherton Baptist Homes Project), series
2009A and 2009B.  The Rating Outlook is Stable.

The series 2009A bonds ($28.7 million) will be issued as fixed-
rate bonds and will amortize over 30 years.  The series 2009B
bonds ($14.6 million) will be issued as fixed-rate bonds and are
expected to be retired from initial entrance fees.  Bond proceeds
will fund the construction of 50 independent living apartments,
related amenities and a new parking structure on Atherton's
campus, fund a debt service reserve fund, and retire approximately
$9 million in outstanding loans.  The bonds are expected to sell
via negotiation in December 2009.

The 'BB' rating considers the construction and fill-up risk of the
project in a difficult economic environment balanced by Atherton's
long history and stable occupancy rates, and adequate liquidity
relative to expenses.  Atherton is a continuing care retirement
community that was established in 1914 and has been at its current
location since 1926.  Annual occupancy at Atherton's independent
living apartments has averaged around 87% rate since 2005.
Through the nine-month interim period ending Sept. 30, 2009,
Atherton had $6.5 million in unrestricted cash and investments,
translating into 207 days-cash-on-hand.

Other rating drivers include Atherton's high debt burden, its
small revenue base, and operating pressures resulting from the
overall downturn in the U.S. economy.  With this issuance,
Atherton's pro forma debt burden is very high, resulting in a pro
forma cash-to-debt position of 22%, before occupancy of new units,
and after repayment of the series 2009B from entrance fees.  Pro
forma MADS as a percent of revenues is also very high at 20.2% and
is covered at 0.8 times (at fiscal year-end 2008).  In addition,
due to its smaller revenue base, Fitch believes that unexpected
vacancies or longer than expected turnover of apartments and
assisted living units could cause a greater volatility in
Atherton's financial performance, especially in light of the
challenging operating environment facing continuing care
retirement centers during the recession.

The Stable Rating Outlook reflects Fitch's belief that Atherton
will continue to experience very good occupancy rates through the
construction period, will maintain its focus on revitalizing its
current facilities through measured increases in entrance fees and
services fees, and will be successful in completion of its
construction project on time and on budget.

Atherton is located on a 15-acre campus in Alhambra, California,
approximately 10 miles east of downtown Los Angeles.  The facility
consists of 170 ILUs, 32 ALUs, six memory-loss ALUs, and 99 SNF
beds.  Total revenue in 2008 was $13 million.  Atherton has
covenanted to provide annual and quarterly disclosure through the
Municipal Rule Making Board's EMMA system.


CITY OF EVANSVILE: Moody's Cuts Housing Revenue Bond Rating to Ba1
------------------------------------------------------------------
Moody's has downgraded these 6 housing finance agency multifamily
transactions and removed them from Watchlist, following a review
of each transaction's ability to maintain cash flow sufficiency
assuming a 0% reinvestment rate.

This action affects approximately $44 in outstanding debt.  All of
these transactions are secured by a mortgage that is guaranteed by
credit enhancement from either GNMA, Fannie Mae, Freddie Mac or
FHA.  None of these issues have a Guaranteed Investment Contract
that assures a fixed rate of return on invested cash, and
therefore all are subject to interest rate risk on retained
revenues.  As a result, revenue from the monthly mortgage
receipts, interest earned on those receipts from money market
funds or other short-term investments and monthly mortgage
payments need to be sufficient to support debt service on the
bonds.  Moody's analyzed each transaction's projected mortgage
revenue, assuming no reinvestment earnings on the monthly mortgage
receipts and determined that there would not be sufficient
coverage of debt service consistent with a Aaa rating.  The
downgrade of the ratings follows Moody's methodology, "Moody's
Methodology Update: Change in Interest Rate Assumptions for
Housing Transactions Which Rely on Investment Earnings Prompted by
Unprecedented Low Interest Rates," published in November, 2009.

1. $8,310,000 of Indianapolis (City of) IN, Multifamily Housing
   Revenue Bonds (Cambridge Station Apartments, Phase II) Series
   2005.  Downgraded to Aa2 from Aaa.  Last rated on 11/12/2009,
   when it was put on Watchlist for Possible Downgrade.

2. $7,490,000 of Bexar County Housing Finance Corporation, TX
   Multfamily Housing Revenue Bonds (GNMA Collateralized -
   Wurzbach Manor Apartments Project) 2003.  Downgraded to A2 from
   Aaa.  Last rated on 10/14/2009, when it was put on Watchlist
   for Possible Downgrade.

3. $16,504,000 of Indianapolis (City of) IN Multifamily Housing
   Revenue Bonds (GNMA Collateralized Mortgage Loan - Braeburn
   Village Apartments) Series 2001A.  Downgraded to A2 from Aaa.
   Last rated on 8/24/2009, when it was put on Watchlist for
   Possible Downgrade.

4. $9,340,000 of Town of Clarence, Erie County, Industrial
   Development Agency, GNMA Collateralized Civic Facility Revenue
   Bonds (2002 Bristol Village, Inc. Project).  Downgraded to A2
   from Aaa.  Last rated on 8/24/2009, when it was put on
   Watchlist for Possible Downgrade.

5. $1,524,000 of Evansville (City of) IN Multifamily Housing
   Revenue Bonds (GNMA Collateralized Mortgage Loan - Village
   Community Partners III, LP Project) Series 2001.  Downgraded to
   Baa1 from Aaa.  Last rated on 7/24/2009, when it was put on
   Watchlist for Possible Downgrade.

6. $831,000 of Evansville (City of) IN Multifamily Housing Revenue
   Bonds (GNMA Collateralized Mortgage Loan - Vann Park
   Apartments, Phase IV Project) Series 2001.  Downgraded to Ba1
   from Aaa.  Last rated on 7/23/2009, when it was put on
   Watchlist for Possible Downgrade.


COBALTS TRUST: S&P Puts 'BB' Rating on CreditWatch Negative
-----------------------------------------------------------
Standard & Poor's Ratings Services placed its 'BB' rating on
COBALTS Trust For Sprint Capital Notes' $25 million certificates
series 2002-1 on CreditWatch with negative implications.

The rating on the certificates is dependent solely on the rating
on the underlying security, Sprint Capital Corp.'s 6.875% notes
due Nov. 15, 2028 ('BB/Watch Neg').

The rating action reflects the Nov. 11, 2009, placement of S&P's
rating on the underlying security on CreditWatch with negative
implications.


COLUMBIA COUNTY: S&P Junks Rating on $13.575 Mil. 1999 Bonds
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its long-term rating to
'CCC' from 'B-' on Columbia County Hospital Authority,
Pennsylvania's, $13.575 million series 1999 health care revenue
bonds, issued for Bloomsburg Hospital.

The downgrade is due to a significant weakening of an already thin
balance sheet with only 12 days' cash on hand and 10% cash to debt
as of Sept. 30, 2009.  A 'CCC' rated entity is currently
vulnerable to nonpayment and is dependent on favorable business,
financial, and economic conditions to meet its financial
commitment on the obligation.  Bloomsburg is current on all
bondholder payments, which are paid to the trustee monthly.  All
trustee held funds ($1.4 million) remain intact.

The 'CCC' rating reflects thin liquidity fueled mostly by losses
and capital investment with 12 days' cash on hand as of Sept. 30,
2009, compared with 28 days as of June 30, 2008; ongoing operating
losses with negative margins over the past five years and
continuing year to date, although at a much lower level, with the
majority of the losses driven by employed physicians and the
hospital posting a profit from operations; overleveraged balance
sheet with debt to capitalization of 117%, which stems from
negative unrestricted net assets of $4 million as of fiscal year-
end June 30, 2009; debt service coverage levels that are below
1.0x, however, are much improved for the obligated group only
(more than 2.0x); and location in a competitive environment with
'AA' rated Geisinger Health System just eight miles away.

In addition, Bloomsburg's small size and revenue base makes the
hospital more vulnerable to economic, business, physician, and
reimbursement pressures as small changes can have a much bigger
effect.  Bloomsburg Hospital operates a 30-staffed-bed general-
acute-care hospital in central Pennsylvania.  The obligated group
includes the hospital; the parent, Bloomsburg Health System;
Columbia-Montour Home Health Services/Visiting Nurse Assn.; and
Bloomsburg Health Care Center, a 149-bed skilled-nursing facility.
However, this analysis is based on the entire Bloomsburg Health
System including employed physicians, an ambulatory health
services corporation, and outreach clinics.  Bloomsburg Health
System is not a party to any swaps at this time.

"The outlook is stable at the lower rating level, however, there
is significant concern regarding Bloomsburg's ongoing viability
and Bloomsburg has no financial cushion and improved profitability
and cash flow are imperative to maintaining the current rating,"
said Standard & Poor's credit analyst Emily Wong.  "Bloomsburg
will need to meet or exceed its fiscal 2010 budget to maintain the
stable outlook," said Ms. Wong.

Standard & Poor's expects fiscal 2010 to be an improvement from
the pervious year due to continued volume increases and
stabilization of its employed physician business line.  A lower
rating is likely if the fiscal 2010 budget is not met and
operating losses continue at historical levels or if liquidity
does not improve.


COMM 2007-C9: S&P Downgrades Ratings on 24 Classes of CMBS
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 24
classes of commercial mortgage-backed securities from COMM 2007-
C9, including three raked classes, and removed 21 of them from
CreditWatch with negative implications.  In addition, S&P affirmed
its ratings on six other classes from the same transaction.

The downgrades of the ratings on the pooled certificates follow
S&P's analysis of the transaction using its U.S. conduit and
fusion CMBS criteria, which was the primary driver of its rating
actions.  The downgrades of the subordinate and mezzanine classes
also reflect credit support erosion S&P anticipates will occur
upon the eventual resolution of several specially serviced loans,
as well as three loans that S&P considers 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
1.34x and a loan-to-value ratio of 125.3%.  S&P further stressed
the loans' cash flows under its 'AAA' scenario to yield a weighted
average DSC of 0.76x and an LTV of 173.5%.  The implied defaults
and loss severity under the 'AAA' scenario were 96.8% and 44.0%,
respectively.  The DSC and LTV calculations S&P noted above
exclude three ($41.2 million, 1.4%) of the four specially serviced
loans and three loans that S&P deemed to be credit-impaired
($186.0 million, 6.4%).  S&P separately estimated losses for these
loans and included them in S&P's 'AAA' scenario implied default
and loss figures.

The affirmations of the ratings on the pooled principal and
interest certificates reflect subordination levels that are
consistent with the outstanding ratings.

The downgrades of the "E57" raked certificates reflect S&P's
analysis of the 135 East 57th Street loan.  The raked certificates
derive 100% of their cash flows from the subordinate portion of
this loan.  The lowered ratings on the "E57" certificates follow
S&P's revised valuation of the loan, which has declined 23% since
issuance due to declining net cash flow.

S&P affirmed its ratings on the class XS and XP interest-only
certificates based on its current criteria.  S&P published a
request for comment proposing changes to its IO criteria on June
1, 2009.  After S&P 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.

                      Credit Considerations

As of the November 2009 remittance report, four loans
($44.4 million, 1.5%) in the pool are with the special servicer,
Helios AMC LLC.  A breakdown of the specially serviced loans by
payment status is: three are more than 90 days delinquent
($41.2 million, 1.4%), and one is 60 days delinquent
($3.2 million, 0.1%).  Two of the specially serviced loans have
appraisal reduction amounts in effect totaling $8.2 million.

In addition to the specially serviced loans, S&P deemed three
loans ($186.0 million, 6.4%) to be credit-impaired.  The largest
credit-impaired loan is the Ritz-Carlton Key Biscayne loan, which
is the fourth-largest loan in the pool and the second-largest loan
on the watchlist.  The loan has a trust balance of $160.0 million
(5.5%) and is secured by a 302-room luxury hotel built in 2001 in
Key Biscayne, Fla.  The trailing-12-month DSC was 0.68x as of
July 31, 2009, down from 1.59x at issuance.  The property has
experienced a significant decline in room revenue due to
deteriorating market conditions, and given the decline in DSC, S&P
believes the loan has experienced a moderate reduction in value
since issuance and is at an increased risk of default.

The two remaining credit-impaired loans have balances that
individually represent less than 0.6% of the total pool balance.

                        Transaction Summary

As of the November 2009 remittance report, the collateral pool
balance was $2.893 billion, which is 99.7% of the balance at
issuance.  The number of loans in the pool, at 109, is unchanged
since issuance.  The master servicers for the transaction are
Capmark Finance Inc. and Key Bank Real Estate Capital.  As of the
November 2009 remittance report, the master servicers provided
financial information for 98.8% of the pool, and 97.7% of the
servicer-provided information was full-year 2008 or interim-2009
data.  S&P calculated a weighted average DSC of 1.39x for the pool
based on the reported figures.  S&P's adjusted DSC and LTV were
1.34x and 125.3%, respectively.  S&P's adjusted DSC and LTV
figures exclude three of the four specially serviced loans and
three loans that S&P deemed to be credit-impaired.  S&P estimated
losses separately for these six loans.  The master servicers
provided DSC figures for five of these six loans, and based on
these figures, S&P calculated a weighted average DSC of 1.18x.
The transaction has not experienced any principal losses to date.
Twenty-five loans ($746.6 million, 25.8%) are on the master
servicers' watchlists, including two of the top 10 loans.
Nineteen loans ($323.7 million, 11.2%) have a reported DSC below
1.10x, and 12 of these loans ($204.4 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
$1.523 billion (53.2%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.45x for the top 10 loans.
Two of the top 10 loans ($381.3 million, 13.2%) appear on the
master servicers' watchlists, including the Ritz-Carlton Key
Biscayne loan, which S&P discussed above, and the DDR Portfolio
loan, which S&P discussed below.  In addition, although it doesn't
appear on the watchlist, the 135 East 57th Street loan has
experienced deteriorating cash flows, and S&P discuss it further
below.  S&P's adjusted DSC and LTV for the top 10 loans are 1.35x
and 117.7%, respectively.

The 135 East 57th Street loan is the 10th-largest loan in the pool
and has a whole-loan balance of $85.0 million, which consists of a
$67.5 million (2.9%) senior pooled component and a $15.5 million
subordinate nonpooled component.  The subordinate component is
raked to the "E57" certificates.  The period interest-only loan is
secured by the leasehold interest in a 427,483-sq.-ft. office
property in midtown Manhattan.  DSC was 2.05x for the year ended
Dec. 31, 2008, and occupancy was 92% as of June 2009.  However,
after a period of arbitration between the borrower and the owner
of the fee interest in the land underneath the property, the
annual ground rent was increased to $12.6 million from $525,000.
While this was a scheduled readjustment and is retroactive to
Jan. 1, 2008, it is significantly higher than the $10.8 million
annual ground rent that the borrower anticipated at issuance.  As
a result, Standard & Poor's adjusted valuation has declined 23%
since issuance.

The DDR Portfolio loan is the second-largest loan in the pool and
the largest loan on the watchlist.  The loan was current in its
debt service payments as of the November 2009 remittance report
and has a trust balance of $221.3 million (7.7%).  The loan is
secured by 52 retail centers across 10 states totaling 7.3 million
sq. ft. The loan appears on the watchlist because three of the
properties had Circuit City as a tenant.  The reported DSC as of
year-end 2008 was 1.51x, which is relatively unchanged from 1.49x
at issuance.

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

      Ratings Lowered And Removed From Creditwatch Negative

                           COMM 2007-C9
          Commercial mortgage pass-through certificates

                 Rating
                 ------
     Class     To      From            Credit enhancement (%)
     -----     --      ----            ----------------------
     A-4       A       AAA/Watch Neg                    30.08
     A-1A      A       AAA/Watch Neg                    30.08
     AM        BBB-    AAA/Watch Neg                    20.05
     AM-FL     BBB-    AAA/Watch Neg                    20.05
     AJ        BB      AAA/Watch Neg                    13.28
     AJ-FL     BB      AAA/Watch Neg                    13.28
     B         BB-     AA+/Watch Neg                    12.16
     C         B+      AA/Watch Neg                     11.15
     D         B+      AA-/Watch Neg                    10.03
     E         B+      A+/Watch Neg                      9.15
     F         B       A/Watch Neg                       8.40
     G         B       A-/Watch Neg                      7.52
     H         B-      BBB+/Watch Neg                    6.27
     J         B-      BBB/Watch Neg                     5.01
     K         B-      BBB-/Watch Neg                    3.89
     L         CCC+    BB+/Watch Neg                     3.13
     M         CCC     BB/Watch Neg                      2.63
     N         CCC-    BB-/Watch Neg                     2.26
     O         CCC-    B+/Watch Neg                      2.01
     P         CCC-    B/Watch Neg                       1.63
     Q         CCC-    B-/Watch Neg                      1.38

                         Ratings Lowered

                           COMM 2007-C9
          Commercial mortgage pass-through certificates

                 Rating
                 ------
     Class     To      From            Credit enhancement (%)
     -----     --      ----            ----------------------
     E57-1     B+      A-                                 N/A
     E57-2     B       BBB                                N/A
     E57-3     CCC-    BB+                                N/A

                         Ratings Affirmed

                           COMM 2007-C9
          Commercial mortgage pass-through certificates

          Class      Rating      Credit enhancement (%)
          -----      ------      ----------------------
          A-1        AAA                          30.08
          A-2        AAA                          30.08
          A-3        AAA                          30.08
          A-AB       AAA                          30.08
          XS         AAA                            N/A
          XP         AAA                            N/A

                       N/A - Not applicable.


CORPORATE-BACKED: Moody's Withdraws 'C' Rating on Class A-1
-----------------------------------------------------------
Moody's Investors Service announced that it has withdrawn the
rating of these certificates issued by Corporate-Backed Trust
Certificates, Series 2001-8:

  -- 1,303,000 Class A-1 Certificates; Withdrawn; Previously on
     December 17, 2008 Downgraded to C

The transaction is a structured note whose rating is based on the
underlying securities and legal structure of the transaction.  The
underlying securities are the $32,575,000 aggregate principal
amount of 8.10% Debentures issued by General Motors Corporation
whose Moody's rating was withdrawn following the bankruptcy filing
by General Motors Corporation.


CORPORATE BACKED: S&P Puts 'BB-' Rating on CreditWatch Negative
---------------------------------------------------------------
Standard & Poor's Ratings Services placed its 'BB' rating on
Corporate Backed Trust Certificates, Sprint Capital Note-Backed
Series 2003-17's $25 million class A-1 certificates on CreditWatch
with negative implications.

The rating on the certificates is dependent solely on the rating
on the underlying security, Sprint Capital Corp.'s 6.875% notes
due Nov. 15, 2028 ('BB/Watch Neg').

The CreditWatch placement reflects S&P's Nov. 11, 2009, placement
of the underlying security on CreditWatch with negative
implications.


CREDIT SUISSE: Fitch Puts Ratings on 2003-CK2 Notes on Neg. Watch
-----------------------------------------------------------------
Fitch Ratings has placed nine classes of Credit Suisse First
Boston Mortgage Securities Corp., series 2003-CK2 on Rating Watch
Negative due to expected losses and potential shortfalls
associated with loans in special servicing (10.8%) as well as the
potential for adverse selection with only 73 non-defeased loans
remaining in the pool.  The classes will remain on Rating Watch
Negative until additional details on the workouts become
available.

The two largest specially serviced loans in the pool are 2300
Imperial Building (3.9%) and Michigan Equity U Portfolio (3.7%).

2300 Imperial Building consists of a 157,225 square foot office in
El Segundo, California.  The loan transferred to the special
servicer in November 2009 for imminent default.  Occupancy at the
property decreased to 48.2% when Boeing (81,418 sf, 51.8% NRA,
59.6% EGI, $37.20/sf) vacated at the June 30, 2008 lease end date.
Occupancy has remained below 50% since June 2008.  The borrower
continues to face difficulty in leasing the available space and
cites the soft market conditions as the primary reason for the
property's poor performance.

Michigan Equity U Portfolio consists of a 16-property office
portfolio, totaling 340,065 sf and located in Lansing, MI.  The
loan has been in special servicing since May 2008 after several
unauthorized ownership transfers had occurred.  Although the
special servicer negotiated a loan modification with the borrower
in the first quarter 2009 (1Q09), members of the borrowing entity
subsequently did not agree to the terms of the modification.  The
special servicer has decided to pursue foreclosure, resulting in
an increase of Fitch expected losses since Fitch's last rating
action.

Fitch has placed these classes on Rating Watch Negative:

  -- $12.4 million class F 'AAA';
  -- $19.8 million class G 'AAA';
  -- $14.8 million class H 'AA';
  -- $17.3 million class J 'A+';
  -- $17.3 million class K 'BBB+'
  -- $4.9 million class L 'BBB';
  -- $13.6 million class M 'BB'
  -- $6.2 million class N 'B+';
  -- $4.9 million class O 'B'.


CREDIT SUISSE: Fitch Takes Rating Actions on 2005-C1 Certs.
-----------------------------------------------------------
Fitch Ratings takes various actions on several classes of Credit
Suisse First Boston Mortgage Securities Corp., series 2005-C1.

The downgrades are the result of loss expectations and reflect
Fitch's prospective views regarding commercial real estate market
value and cash flow declines.  Fitch forecasts potential losses of
9% for this transaction, should market conditions not recover.
The rating actions are based on losses of 9%, as a majority of the
loans mature in the next five years.  The bonds with Negative
Outlooks indicate classes that may be downgraded in the future
should full potential losses be realized.

To determine potential defaults for each loan Fitch assumed cash
flow would decline by 10% from year-end 2008, which is consistent
with the analysis used in its review of recent vintage
transactions whereby cash flow was assumed to decline 15% from
year-end 2007 projected over a three-year period.  If the stressed
cash flow would cause the loan to fall below 0.95 times, Fitch
assumed the loan would default during the term.  To determine
losses, Fitch used the above stressed cash flow, and applied a
market cap rate, ranging between 7.5% and 9.5%, to derive a value.
If the loan balance at default is less than Fitch's derived value,
the loan would realize that amount of loss.  These loss estimates
were reviewed in more detail for loans representing 59% of the
pool and, in certain cases, revised based on additional
information and/or property characteristics.  Loss expectations
attributed to loans reviewed in detail represent approximately 85%
of the recognized losses.

Approximately 86.5% of the mortgages mature within the next five
years: 3.9% in 2010, 12% in 2011, 3.8% in 2012, 42.1% in 2013, and
24.7% in 2014.

Fitch identified 46 Loans of Concern (35%) within the pool, 14 of
which (14%) are specially serviced.  Of the specially serviced
loans, one (8.4%) is current.

Losses are expected on seven (16.1%) of the loans within the Top
15: five (10.7%) are expected to default during the term, while
losses on two loans (5.4%) are expected at maturity.  Loss
severities associated with these loans range from 6% to 75%.  The
largest overall contributors to deal loss are: BP Multifamily
Portfolio (3.4%), Rachel Bridge Apartments (2.8%), and Shoppes at
Plantation Acres (0.7%).

BP Multifamily Portfolio is comprised of four cross-collateralized
and cross-defaulted loans, secured by four multifamily properties
located in Addison, Mesquite (two properties), and Richardson, TX.
The properties consist of a total of 1,178 units, which were 92%
occupied at issuance.  Performance has declined since issuance
with the servicer reported debt-service coverage ratio for the
portfolio as of year-end 2008 at 1.16x and occupancy down to 77%.
The loans are sponsored by Chowdary Yalamanchili, the sponsor of
several smaller multifamily loans in Fitch's rated transactions
that have defaulted.  Fitch modeled the loan with a higher
probability of default during the loan term due to declining
occupancy and ongoing concerns with the sponsor and potential for
future defaults and deterioration in property conditions.

Rachel Bridge Apartments is a 960 unit rent stabilized apartment
complex, built in 1962 and renovated in 1992, located within the
Washington Heights neighborhood in Manhattan.  Performance has
declined since issuance due to increased operating expenses.  The
loan is also a Fitch Loan of Concern due to deferred maintenance
at the property and outstanding real estate taxes.  Fitch expects
that the loan may default at maturity as cash flow is not expected
to increase to a level that would meet Fitch's refinance criteria.

Shoppes at Plantation Acres is a 57,003 square foot anchored
retail center consisting of three tenants and located in
Plantation, FL.  The loan transferred to special servicing in
February 2009 due to imminent default as a result of the major
tenant, Circuit City which occupied 78% of the net rentable area,
filing bankruptcy and vacating their space.  The special servicer
has filed foreclosure and continues ongoing forbearance
discussions with the borrower who continues to market the vacant
space.  As of May 2009, the servicer reported debt service
coverage ratio was 0.18x, and the property was 23% occupied.  Of
the remaining tenants, one occupying 12% of NRA has an upcoming
lease expiration in Feburary 2010.  Fitch modeled the loan with a
higher probability of default during the term due to weak market,
the inability to lease up the vacant space, and future tenant
rollover.

Fitch downgrades, removes from Rating Watch Negative, and assigns
Outlooks and LS ratings:

  -- $92.5 million class A-J to 'AA/LS4' from 'AAA'; Outlook
     Stable;

  -- $43.4 million class B to 'BBB-/LS5' from 'AA'; Outlook
     Stable;

  -- $13.2 million class C to 'BB/LS5' from 'AA-'; Outlook Stable;

  -- $24.5 million class D to 'BB/LS5' from 'A'; Outlook Stable;

  -- $18.9 million class E to 'B-/LS5' from 'A-'; Outlook
     Negative;

  -- $20.8 million class F to 'B-/LS5' from 'BBB+'; Outlook
     Negative;

  -- $15.1 million class G to 'B-/LS5' from 'BBB'; Outlook
     Negative;

  -- $18.9 million class H to 'B-/LS5' from 'BBB-'; Outlook
     Negative;

  -- $5.7 million class J to 'B-/LS5' from 'BB'; Outlook Negative;

  -- $5.7 million class K to 'B-/LS5' from 'BB-'; Outlook
     Negative;

  -- $5.7 million class L to 'B-/LS5' from ''B+'; Outlook
     Negative;

  -- $5.7 million class M to 'CCC/RR1' from 'B';

  -- $5.7 million class N to 'CCC/RR6' from 'B-'.

Fitch affirms and lowers the Recovery Rating of this class:

  -- $3.8 million class O to 'CCC/RR6' from 'CCC/RR1'.

Fitch also affirms and assigns Rating Outlooks on these classes:

  -- $71.2 million class A-2 at 'AAA/LS2'; Outlook Stable;
  -- $113.1 million class A-AB at 'AAA/LS2'; Outlook Stable;
  -- $181.6 million class A-3 at 'AAA/LS2'; Outlook Stable;
  -- $674.3 million class A-4 at 'AAA/LS2'; Outlook Stable;
  -- Interest-only class A-X at 'AAA'; Outlook; Stable;
  -- Interest-only class A-SP at 'AAA'; Outlook Stable.

Fitch does not rate the $22.6 million class P.  Class A-1 is paid
in full.


CREDIT SUISSE: Moody's Affirms Ratings on Five 2007-C4 Certs.
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings of five classes and
downgraded 21 classes of Credit Suisse Commercial Mortgage Trust,
Commercial Mortgage Pass-Through Certificates, Series 2007-C4.
The downgrades are due to higher expected losses for the pool
resulting from anticipated losses from specially serviced and
highly leveraged watchlisted loans.

The affirmations are due to key rating parameters, including
Moody's loan to value ratio, stressed debt service coverage ratio
and the Herfindahl Index, remaining within acceptable ranges.

Although Moody's is affirming the super-senior Classes A-1, A-2,
A-3, A-AB and A-X based on current parameters, Moody's is
concerned that potential losses could be significantly higher than
currently projected due to the poor performance of a large portion
of the pool.  Approximately 98% of the pool has a Moody's stressed
DSCR below 1.00X.  If estimated losses were to increase by an
additional 10% over current estimated losses, Classes A-AB and A-3
would likely be downgraded by one to three notches.  These classes
have the longest weighted average life among the super senior
classes.

On August 11, 2009, Moody's placed 19 classes on review for
possible downgrade due to the credit uncertainty surrounding
Maguire Properties Inc., the sponsor of two loans representing 10%
of the outstanding deal balance, and anticipated losses from loans
in special servicing.  On November 6, 2009, Moody's added two
super-senior Aaa classes to the review because anticipated losses
from specially serviced and watchlisted loans were higher than
originally projected.  The action concludes the full review of the
transaction.  This action is the result of Moody's on-going
surveillance of commercial mortgage backed securities
transactions.

As of the October 19, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$2.06 billion from $2.08 billion at securitization.  The
Certificates are collateralized by 214 mortgage loans ranging in
size from less than 1% to 15% of the pool, with the top ten loans
representing 46% of the pool.

Fifty-seven loans, representing 40% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.

The pool has experienced a minimal $1,200 loss from the
liquidation of one loan.  Eighteen loans, representing 13% of the
pool, are currently in special servicing.  The largest specially
serviced loan is the 2600 Michelson Loan ($95.0 million -- 4.6% of
the pool) which is secured by a Class A office property located in
Irvine, California with 307,000 square feet or net rentable area.
The loan sponsor is Maguire.  The loan was transferred to special
servicing in August 2009 for imminent default and is currently 30
days delinquent.  The property was 73% occupied as of June 2009
compared to 98% at securitization.  The largest tenants include
Citicorp (12% of the NRA; lease expiration June 2013) and LA
Fitness (20% of the NRA; lease expiration January 2011).

The second largest specially serviced loan is the Meyberry House
Loan ($90.0 million -- 4.4% of the pool), which is secured by a
179-unit apartment building located on the Upper East Side of
Manhattan in New York City.  In addition to the first mortgage
loan, there is a $34.0 million mezzanine loan held outside the
trust.  The loan has been in special servicing several times since
securitization and was most recently transferred to special
servicing in September 2009 due to imminent default.  The borrower
has not been successful in achieving the revenue originally
projected by converting rent stabilized units to market rates.
Currently 66% of the property is at market rates, a modest
improvement over the 59% market rate occupancy at securitization.
The property was 91% occupied as of August 2009.  The loan
sponsors are The Atlas Group and Lehman Brothers.

The remaining 16 specially serviced loans are secured by a mix of
multifamily, office, retail and industrial properties.  Moody's
estimates a $141.6 million aggregate loss (54% loss severity) for
the specially serviced loans.

Moody's was provided with partial or full-year 2008 operating
results for 89% of the pool.  Moody's weighted average LTV ratio,
excluding the specially serviced loans, is 163% compared to 179%
at Moody's prior review in February 2009.  The previous review was
part of Moody's first quarter 2009 ratings sweep of 2006-2008
vintage CMBS transactions.

Moody's stressed DSCR is 0.73X compared to 0.63X at last review.
Moody's stressed DSCR is based on Moody's net cash flow and a
9.25% stressed rate applied to the loan balance.

Moody's uses a variation of the Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple-notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 25, essentially the same as at last review.

The three largest loans represent 27% of the outstanding pool
balance.  The largest loan is the Shutters on the Beach and Casa
Del Mar Portfolio Loan ($310.0 million -- 15% of the pool), which
is secured by two luxury hotel properties located in Santa Monica,
California.  Shutters on the Beach is a 198-room full service
hotel and Casa Del Mar is a 129-room bed and breakfast inn.  The
combined occupancy and RevPAR for the trailing 12-month period
ending August 2009 was 85% and $299, respectively, compared to 77%
and $448 at securitization.  Both properties are performing better
than their respective markets in terms of their occupancy rates;
however, they are performing below Moody's original projections
because of declines in tourist and business travel due to the
economic recession.  The loan is on the servicer's watchlist due
to a decline in debt service.  The servicer's reported DSCR for
the 12-month period ending June 2009 was 0.93X compared to 1.18X
for the 12-month period ending December 2008.  Moody's is
concerned that this loan represents a significant default risk
because of poor performance.  The high-end luxury hotel market has
been particularly negatively impacted during the economic
recession and it is not expected to recover in the short term.
Moody's LTV and stressed DSCR are 258% and 0.42X, respectively,
compared to 272% and 0.41X at last review.

The second largest loan is the 245 Fifth Avenue Loan
($140.0 million -- 6.8% of the pool), which is secured by a
303,000 SF office building located in midtown Manhattan.  The
property was 94% leased as of June 2009, similar to last review.
The largest tenants include Citibank (15% of the NRA; lease
expiration December 2012) and Datamonitor (9% of the NRA; lease
expiration July 2012).  The servicer's reported DSCR for the first
six months of 2009 was 0.93X.  The loan matures on May 2012.
Moody's is concerned that this loan is a high default risk at loan
maturity because of its high leverage and low stressed debt
service coverage.  Moody's LTV and stressed DSCR are 179% and
0.58X, respectively, compared to 160% and 0.59X at last review.

The third largest conduit loan is the City Tower Loan
($115.6 million -- 5.6% of the pool), which is secured by a
411,000 SF office building located in Orange County, California.
The loan sponsor is Maguire.  The property was 77% leased as of
June 2009 compared to 95% at securitization.  The property has
significant lease rollover exposure over the next three years.
The largest tenants include Maguire Properties (18% of the NRA;
lease expiration February 2010), St. Paul Fire & Marine (15% of
the NRA; lease expiration April 2013) and Liberty Mutual (10% of
the NRA; lease expiration August 2011).  The servicer's reported
actual DSCR for the six-month period ending June 2009 was 0.97X
compared to 0.80X for the 12-month period ending December 2008.
Moody's feels that this loan is a high default risk due to the
property's poor operating performance and the likely departure of
Maguire Properties in February 2010.  Moody's LTV and stressed
DSCR are 266% and 0.40X, respectively, compared to 167% and 0.58X
at last review.

Moody's rating action is:

  -- Class A-1, $14,356,186, affirmed at Aaa; previously assigned
     Aaa on 10/8/2007

  -- Class A-X, Notional, affirmed at Aaa; previously assigned Aaa
     on 10/8/2007

  -- Class A-2, $219,200,000, affirmed at Aaa; previously assigned
     Aaa on 10/8/2007

  -- Class A-3, $333,792,000, affirmed at Aaa; previously assigned
     Aaa on 10/8/2007

  -- Class A-AB, $36,935,000, affirmed at Aaa; previously assigned
     Aaa on 10/8/2007

  -- Class A-4, $566,172,000, downgraded to Aa2 from Aaa;
     previously placed on review for possible downgrade on
     11/6/2009

  -- Class A-1-A, $274,230,564, downgraded to Aa2 from Aaa;
     previously placed on review for possible downgrade on
     11/6/2009

  -- Class A-1-AM, $158,126,000, downgraded to A3 from Aaa;
     previously placed on review for possible downgrade on
     8/11/2009

  -- Class A-M, $50,000,000, downgraded to A3 from Aaa; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class A-1-AJ, $61,868,000, downgraded to Ba2 from A2;
     previously placed on review for possible downgrade on
     8/11/2009

  -- Class A-J, $50,000,000, downgraded to Ba2 from A2; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class B, $23,414,000, downgraded to B2 from A3; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class C, $28,618,000, downgraded to Caa2 from Baa1;
     previously placed on review for possible downgrade on
     8/11/2009

  -- Class D, $23,414,000, downgraded to Ca from Baa2; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class E, $18,211,000, downgraded to Ca from Baa3; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class F, $18,211,000, downgraded to Ca from Ba1; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class G, $20,813,000, downgraded to Ca from Ba2; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class H, $20,812,000, downgraded to C from B1; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class J, $26,016,000, downgraded to C from B3; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class K, $28,618,000, downgraded to C from Caa1; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class L, $20,812,000, downgraded to C from Caa1; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class M, $7,805,000, downgraded to C from Caa3; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class N, $5,203,000, downgraded to C from Caa3; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class O, $5,203,000, downgarded to C from Caa3; placed on
     review for possible downgrade on 8/11/2009

  -- Class P, $5,203,000, downgraded to C from Ca; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class Q, $7,805,000, downgraded to C from Ca; previously
     placed on review for possible downgrade on 8/11/2009


CREDIT SUISSE: Moody's Reviews Ratings on 15 2007-C3 Certificates
-----------------------------------------------------------------
Moody's Investors Service continued the review for possible
downgrade of 15 classes from Credit Suisse Commercial Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series 2007-
C3.  The classes were placed on review for possible downgrade on
August 11, 2009, due to higher expected losses for the pool
resulting from anticipated losses from specially serviced loans.
Moody's is placing three additional classes on review for possible
downgrade, adding them to the existing classes already on review
for possible downgrade, because anticipated losses from specially
serviced and highly leveraged watchlisted loans are higher than
originally projected.

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

As of the October 19, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$2.67 billion from $2.68 billion at securitization.  The
Certificates are collateralized by 242 mortgage loans ranging in
size from less than 1% to 6% of the pool, with the top ten loans
representing 31% of the pool.

The pool has not experienced any losses since securitization.
Currently 25 loans, representing 11% of the pool, are in special
servicing.

Forty-four loans, representing 26% of the pool, are on the master
servicer's watchlist.  The top two loans of the pool, comprising
11%, are on the watchlist.  The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.  Not all loans on the
watchlist are delinquent or have significant issues.

Classes K through T pool have experienced interest shortfalls
totaling $2.7 million.

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

Moody's rating action is:

  -- Class A-M, $268,479,000, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 7/30/2007

  -- Class A-J, $201,359,000, currently rated A1, on review for
     possible downgrade; previously downgraded to A1 from Aaa on
     2/9/2009

  -- Class B, $16,780,000, currently rated A2, on review for
     possible downgrade; previously downgraded to A2 from Aa1 on
     2/9/2009

  -- Class C, $40,272,000, currently rated A3, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class D, $26,847,000, currently rated Baa1, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class E, $20,136,000, currently rated Baa2, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class F, $23,492,000, currently rated Baa3, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class G, $30,204,000, currently rated Ba2, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class H, $33,560,000, currently rated B1, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class J, $30,204,000, currently rated B3, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class K, $30,204,000, currently rated Caa1, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class L, $10,068,000, currently rated Caa2, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class M, $6,712,000, currently rated Caa2, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class N, $10,068,000, currently rated Caa3, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class O, $6,712,000, currently rated Caa3, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class P, $6,712,000, currently rated Caa3, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class Q, $10,068,000, currently rated Ca, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009

  -- Class S, $6,712,000, currently rated Ca, on review for
     possible downgrade; previously placed on review for possible
     downgrade on 8/11/2009


CREDIT SUISSE: S&P Downgrades Ratings on 14 2007-TFL1 Certs.
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 14
classes of commercial mortgage pass-through certificates from
Credit Suisse First Boston Mortgage Securities Corp.'s series
2007-TFL1.  At the same time, S&P removed all 14 ratings from
CreditWatch with negative implications.

According to the November 2009 trustee remittance report, pool
statistics were:

* There were 10 loans in the pool, including senior participation
  interests in eight floating-rate mortgage loans and two
  floating-rate whole-mortgage loans;

* There were mortgages on 25 office properties, nine hotel
  properties, and one mixed-use property; and

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

The reasons for the downgrades include:

Lodging properties, which constitute 66% ($798.4 million) of the
pooled trust balance (according to the November 2009 trustee
remittance report), have experienced valuation declines that
ranged between 24% and 64% below the levels S&P assessed at
issuance.  S&P's valuations incorporated actual declines in
revenue per available room and S&P's expectations for future
declines.

Office properties, which make up 14% ($172.9 million) of the
pooled trust balance, experienced valuation declines ranging
between 18% and 30% below issuance levels.  S&P generally
attribute the declines to depressed rental rates and/or higher
vacancy rates.

The distribution of interest amounts to the class A-X-1 and A-X-2
interest-only certificates are made pro rata to the class A-1
certificate, which S&P downgraded accordingly.  S&P published a
request for comment proposing changes to S&P's 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 lowered.

                        Lodging Collateral

Hotel properties secure seven loans in the pool totaling
$798.4 million (66% of the pooled trust balance).  These
properties are predominantly in Manhattan (48% of the remaining
pool balance), Las Vegas (12%), Aruba (11%), and Beverly Hills
(6%).  S&P based its hotel analyses, in part, on a review of the
available borrower's operating statements for year-to-date 2009,
the 12 months ended Dec. 31, 2008, and the borrower's 2009
budgets, as well as the Smith Travel Research (STR) reports.  A
reduction in business and leisure travel has, in S&P's opinion,
significantly affected the performance of lodging collateral.
S&P's analysis factored in actual RevPAR declines at each property
and also considered local lodging market conditions.  According to
STR, the New York lodging market posted a 31% decline in RevPAR
for the first nine months of 2009 compared with 2008, whereas the
general U.S. hotel industry reported an 18% decline in RevPAR for
the same period.

                       Largest Lodging Loan

The Park Central Hotel loan, the largest lodging loan and the
second-largest loan in the pool, is secured by a 934-room full-
service hotel in Manhattan.  The current trust balance is
$203.0 million (17% of the remaining pool balance), and the whole-
loan balance is $407.0 million.  In addition, the equity interests
in the borrower of the whole loan secure $58.0 million of
mezzanine debt.  The master servicer, KeyCorp Real Estate Capital
Markets Inc. (KeyCorp), reported a 1.60x debt service coverage and
96% occupancy for the 12 months ended June 30, 2009.  S&P's
adjusted valuation has fallen 50% since issuance, primarily due to
the decline in RevPAR and an increase in operating expenses.
According to STR, the property's RevPAR has decreased 34% year-to-
date as of August 2009.  The loan matures in November 2010 and has
two one-year extension options remaining.

             Lodging Loans With The Special Servicer

SLS at Beverly Hills, the seventh-largest loan in the pool, has a
trust balance of $70.0 million (6% of the remaining pool balance)
and a whole-loan balance of $114.1 million.  In addition, the
equity interests in the borrower of the whole loan secure
$24.9 million of mezzanine debt.  The loan, secured by a 297-room
full-service upscale hotel in Beverly Hills, Calif., was
transferred to the special servicer, ORIX Capital Markets, on
Oct. 5, 2009, due to imminent default based on pending maturity on
Dec. 9, 2009.  The loan did not meet its debt yield test extension
requirement in order for the borrower to exercise one of its two
remaining extension options.  As of Dec. 31, 2008, KeyCorp
reported property cash flow that was insufficient to cover
operating expenses, and as of June 2009, KeyCorp reported 48%
occupancy.  S&P's adjusted valuation has declined 57% since
issuance due primarily to a significant decrease in RevPAR.
According to KeyCorp, the borrower continues to pay interest on
the loan.  ORIX has ordered an appraisal and continues to monitor
the loan.

The Allerton Hotel of Chicago loan, which was recently transferred
to the special servicer, Wells Fargo Bank N.A., is secured by a
443-room, full-service hotel in Chicago.  This loan has a current
trust balance of $40.0 million (3% of the remaining pool balance)
and a whole-loan balance of $69.0 million.  In addition, the
equity interests in the borrower of the whole loan secure
$10.0 million of mezzanine debt.  This loan was transferred to
Wells Fargo on Nov. 6, 2009, due to maturity default.  The loan
did not meet its DSC extension requirements for the borrower to
exercise one of its two remaining extension options.  The master
servicer reported a 0.94x DSC for the 12 months ended Sept. 30,
2009, and 67% occupancy as of June 2009.  S&P's adjusted valuation
has declined 51% since issuance due primarily to a decrease in
RevPAR.  According to STR, the property's RevPAR had decreased 31%
year-to-date as of May 2009.  According to the special servicer,
this loan is current, and the lender amended the loan on Nov. 6,
2009.  The amendment allows the borrower the opportunity of a
forbearance period until Jan. 9, 2010.  In addition, with respect
to the second extension option only, the borrower will pay the
loan in full on Jan. 9, 2010, if it fails to comply with all
requirements.

    Lodging Loans With Maturities Within The Next Three Months
                        Not Discussed Above

The Doubletree Guest Suites Times Square loan, the fourth-largest
loan in the pool, has a trust and whole-loan balance of
$140.0 million (12% of the pooled trust balance).  In addition,
the equity interests in the borrower of the whole loan secure
$130.0 million of mezzanine debt.  This loan, secured by a 460-
room, full-service hotel in New York City, matures in January 2010
and has two one-year extension options remaining.  According to
KeyCorp, the borrower has provided written notification requesting
to exercise one of its two remaining extension options.  S&P's
adjusted valuation has declined 51% since issuance due primarily
to a decrease in RevPAR.  According to STR, the property's RevPAR
had decreased 30% year-to-date as of August 2009.

The Renaissance Aruba Beach Resort & Casino loan, the fifth-
largest loan in the pool, has a trust balance of $128.0 million
(11% of the remaining pool balance) and a whole-loan balance of
$200.0 million.  This loan, secured by a 558-room (including
timeshare units), full-service resort lodging facility in
Oranjestad, Aruba, matures in January 2010 and has two one-year
extension options remaining.  According to KeyCorp, the borrower
has provided written notification requesting to exercise one of
its two remaining extension options, as well as a loan
modification.  However, the loan does not meet its debt yield test
extension requirement.  KeyCorp is currently in discussions with
the borrower.  S&P's adjusted valuation has declined 24% since
issuance due primarily to a decrease in RevPAR.  According to STR,
the property's RevPAR had decreased 26% year-to-date as of May
2009.

                        Office Collateral

Office properties secure two loans totaling $172.9 million (14% of
the remaining pool balance).  All of the office properties are in
the San Francisco Bay Area.  Most of the office properties have
experienced lower rental rates and/or higher vacancies since
issuance.

                       Largest Office Loan

The Hines Portfolio loan, the largest office loan and the sixth-
largest loan in the pool, has a trust balance of $125.0 million
(10% of the pooled trust balance) and a whole-loan balance of
$270.0 million.  This loan is secured by 17 cross-collateralized
and cross-defaulted class B+ office, flex/research and
development, and industrial properties totaling 1.6 million sq.
ft. in the San Jose/Silicon Valley area of Northern California.
KeyCorp reported a 3.77x DSC for the 12 months ended Sept. 30,
2009, and 74% occupancy as of June 2009.  S&P's adjusted valuation
is down 18% since issuance due primarily to increased operating
expenses.  The loan matures in November 2010 and has one one-year
extension option remaining.

         Office Loans With Maturities Within Three Months
                        Not Discussed Above

The Central Research Park loan, the ninth-largest loan in the
pool, has a trust balance of $47.9 million (4% of the remaining
pool balance) and a whole-loan balance of $92.0 million.  In
addition, the equity interests in the borrower of the whole loan
secure $20.0 million of mezzanine debt.  This loan, secured by
eight suburban office buildings in Sunnyvale, Calif., matures in
January 2010 and has two one-year extension options remaining.
According to KeyCorp, the borrower has not yet indicated whether
it intends to exercise one of its remaining extension options.
S&P's adjusted valuation is down 30% since issuance, due primarily
to lower-than-expected rental revenue.

                      Mixed-Use Collateral

The Manhattan Mall loan, the largest retail loan and the largest
loan in the pool, has a trust and whole-loan balance of
$232.0 million (19% of the remaining pool balance).  The loan is
secured by a 1.0 million-sq.-ft. retail and office mixed-use
property in New York City.  Manhattan Mall is a 13-story, class A
office and retail center containing office space on floors three
through 11 and retail space on floors one and two and on the two
lower-level floors.  KeyCorp reported a 2.80x DSC for year-end
2008 and 95% occupancy as of June 2009.  Standard & Poor's
adjusted valuation for the loan is comparable to its valuation at
issuance.  The loan matures in February 2010, and has two one-year
extension options remaining.  According to KeyCorp, the borrower
has not yet indicated whether it intends to exercise one of its
remaining extension options.

      Ratings Lowered And Removed From Creditwatch Negative

       Credit Suisse First Boston Mortgage Securities Corp.
  Commercial mortgage pass-through certificates series 2007-TFL1

                Rating
                ------
   Class      To      From              Credit Enhancement (%)
   -----      --      ----              ----------------------
   A-1        AA      AAA/Watch Neg                      45.40
   A-2        BBB+    AAA/Watch Neg                      25.47
   B          BB+     AA+/Watch Neg                      22.13
   C          B+      AA/Watch Neg                       18.97
   D          B       AA-/Watch Neg                      16.84
   E          B-      A+/Watch Neg                       14.73
   F          CCC+    A/Watch Neg                        12.37
   G          CCC     A-/Watch Neg                       10.16
   H          CCC-    BBB+/Watch Neg                      7.89
   J          CCC-    BBB/Watch Neg                       5.68
   K          CCC-    BB+/Watch Neg                       2.63
   L          CCC-    BB/Watch Neg                         N/A
   A-X-1      AA      AAA/Watch Neg                        N/A
   A-X-2      AA      AAA/Watch Neg                        N/A

                       N/A - Not applicable.


CREDIT SUISSE: S&P Downgrades Ratings on 15 2006-C2 Securities
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 15
classes of commercial mortgage-backed securities from Credit
Suisse Commercial Mortgage Trust Series 2006-C2, seven of which
S&P sets to 'D', and removed them from CreditWatch with negative
implications.  In addition, S&P affirmed its ratings on five
classes from the same transaction.

The downgrades follow S&P's analysis of the transaction using its
U.S. conduit and fusion CMBS criteria, and reflect credit support
erosion S&P anticipate will occur upon the eventual resolution of
the loans that are with the special servicer, Centerline Servicing
Inc., as well as one loan S&P considers to be credit-impaired.  In
addition, interest shortfalls due to an appraisal subordinate
entitlement reduction on the second-largest asset in the pool, the
Fortunoff Portfolio loan,  caused us to lower the ratings on the
class H, J, K, L, M, N, and O certificates  to 'D'.  S&P expects
the interest shortfalls to recur for an extended period of time.
Liquidity considerations also contributed to the other rating
actions, including the class F and G certificates, which have not
received their optimal interest payments for two and three months,
respectively.  If these shortfalls persist, S&P may lower the
ratings further, potentially to 'D'.  These shortfalls are due, in
part, to an ARA in effect for the Babcock and Brown FX 1 loan;
this ARA is subject to change pending receipt of a final appraisal
by Centerline.

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 1.36x and a loan-to-value ratio of 102.9%.  S&P further
stressed the loans' cash flows under its 'AAA' scenario to yield a
weighted average DSC of 0.93x and an LTV of 131.8%.  The implied
defaults and loss severity under the 'AAA' scenario were 81.1% and
36.8%, respectively.  The DSC and LTV calculations exclude nine
specially serviced loans ($274.7 million, 19.6%) and one credit-
impaired loan ($7.4 million, 0.5%).  S&P separately estimated
losses for these loans, and S&P include them 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 rating on the IO certificates S&P affirmed.

Eleven loans ($278.7 million, 19.9%) in the pool, including the
largest, second- and 10th-largest loans, are with Centerline.
Seven of the loans ($94.7 million, 6.8%) are more than 90 days
delinquent, two ($24.5 million, 1.8%) are 60 days delinquent, one
($157.4 million, 11.2%) is 30 days delinquent, and one
($2.1 million, 0.2%) is less than 30 days delinquent.  Seven loans
have ARAs in effect totaling $100.3 million.  The weighted average
DSC for these loans is 0.98x.

The primary driver of the rating actions is the performance of the
largest and second-largest loans in the pool.  Each of these loans
has ARAs in effect, which combined represent 95.4% of the
aggregate ARA amount in effect against all specially serviced
assets.  The Babcock & Brown FX 1 loan ($157.4 million, 11.2%) is
the largest loan in the pool.  It is secured by a 13-property
multifamily portfolio consisting of 4,990 units spread over eight
properties in Texas, four properties in South Carolina, and one in
Alabama.  The loan was transferred to Centerline on March 18,
2009, due to imminent default.  Several properties in this
portfolio were damaged in Hurricane Ike, and the borrower had
sought forbearance based on its inability to fund necessary
capital repairs.  Centerline is assessing the properties' capital
needs and evaluating its potential resolution strategies.
Occupancy was 90.0% as of June 30, 2009, and DSC was 1.05x as of
Dec. 31, 2008.  The ARA in effect against this asset is subject to
revision upon receipt of a final appraisal by Centerline.
Standard & Poor's considered brokers' opinions of value and market
comparables in its analysis and believes the loan may experience a
significant loss upon resolution.

The Fortunoff Portfolio loan ($70.3 million, 5.0%) is the second-
largest loan in the pool and is secured by a fee and leasehold
interest in a 208,000-sq.-ft. single-tenant retail property in
Westbury, N.Y., and a leasehold interest in a 150,000-sq.-ft.
single-tenant retail property in Woodbridge, N.J.  The loan was
transferred to Centerline on Jan. 14, 2009, due to the bankruptcy
of the sole tenant, the Fortunoff chain of department stores,
which vacated the premises on June 2, 2009, following its
liquidation.

The properties have been vacant since then, and efforts to secure
new tenants have not yet been successful.  Negotiations for a
forbearance agreement are ongoing.  The ARA in effect against this
asset is based on a May 2009 appraisal.  The related ASER amount
associated with this ARA is sufficient, in and of itself, to
prompt interest shortfalls on the classes S&P downgraded to 'D'.
Standard & Poor's anticipates a significant loss upon the
resolution of this asset.

The Lincoln Green Apartments loan ($22.7 million, 1.6%) is the
10th-largest loan in the pool and is secured by a 680-unit
multifamily property in San Antonio, Texas.  The loan was
transferred to Centerline on Nov. 11, 2009, due to imminent
default.  The property has experienced a decline in occupancy and
cash flow, and the borrower has indicated an unwillingness to fund
future debt service.  Occupancy was 67.0% as of March 31, 2009,
and DSC was 0.82x as of Dec. 31, 2008.  Standard & Poor's
anticipates a moderate loss upon the resolution of this asset.

                       Transaction Summary

As of the November 2009 remittance report, the aggregate trust
balance was $1.40 billion, which represents 97.5% of the aggregate
trust balance at issuance.  There are 193 loans in the pool, which
is unchanged issuance.  The master servicer for the transaction is
Wachovia Bank N.A.  Wachovia provided financial information for
98.8% of the pool, and 90.7% of the servicer-provided information
was full-year 2008 or interim 2009 data.  S&P calculated a
weighted average DSC of 1.27x for the pool based on the reported
figures.  S&P's adjusted DSC and LTV were 1.36x and 102.9%,
respectively.  S&P's adjusted figures exclude nine specially
serviced loans and one credit-impaired loan.  S&P estimated losses
separately for these loans.  To date, the transaction has not
realized any principal losses.  Forty-four loans ($200.8 million,
14.3%) are on the master servicer's watchlist, including two of
the top 10 loans.  Thirty-nine loans ($425.4 million, 30.3%) have
a reported DSC of less than 1.10x, and 25 of these loans
($198.3 million, 14.1%) have a reported DSC of less than 1.0x.

                     Summary Of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$472.7 billion (33.7%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.15x for the top 10 loans.
The sixth- and ninth-largest loans in the pool ($51.3 million,
3.7%) appear on the master servicer's watchlist.  S&P's adjusted
DSC and LTV for the top 10 loans were 1.30x and 110.8%,
respectively.

The Summit Hill loan ($27.2 million, 1.9%) is the sixth-largest
loan in the pool and is secured by a 411-unit multifamily complex
in Chapel Hill, North Carolia.  The loan appears on the watchlist
due to a reported DSC of 1.03x as of Dec. 31, 2008.  Occupancy was
90.0% as of June 22, 2009.

The Parc at Duluth loan ($24.2 million, 1.7%) is the ninth-largest
loan in the pool and is secured by a 163-unit senior housing
community in Duluth, Ga.  The loan appears on the watchlist due to
low DSC and a decline in occupancy.  A new marketing manager has
been engaged to address this situation.  Occupancy was 70.0% as of
June 30, 2009, and DSC was 0.95x as of Dec. 31, 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

     Credit Suisse Commercial Mortgage Trust Series 2006-C2
          Commercial mortgage pass-through certificates

                  Rating
                  ------
   Class  To              From          Credit enhancement (%)
   -----  --              ----          ----------------------
   A-M    BBB+            AAA/Watch Neg                  20.50
   A-J    B+              AAA/Watch Neg                  13.32
   B      B-              AA/Watch Neg                   11.14
   C      CCC+            AA-/Watch Neg                  10.25
   D      CCC             A/Watch Neg                     8.58
   E      CCC-            A-/Watch Neg                    7.30
   F      CCC-            BBB+/Watch Neg                  6.15
   G      CCC-            BBB/Watch Neg                   4.74
   H      D               BBB-/Watch Neg                  3.59
   J      D               BB+/Watch Neg                   3.20
   K      D               BB/Watch Neg                    2.82
   L      D               BB-/Watch Neg                   2.43
   M      D               B+/Watch Neg                    2.31
   N      D               B-/Watch Neg                    1.79
   O      D               CCC+/Watch Neg                  1.41

                        Ratings Affirmed

      Credit Suisse Commercial Mortgage Trust Series 2006-C2
          Commercial mortgage pass-through certificates

             Class  Rating     Credit enhancement (%)
             -----  ------     ----------------------
             A-1    AAA                         30.74
             A-2    AAA                         30.74
             A-3    AAA                         30.74
             A-1A   AAA                         30.74
             AX     AAA                           N/A


CREST G-STAR: S&P Downgrades Ratings on Three Classes of Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class B-1, B-2, and C notes issued by Crest G-Star 2001-2 Ltd., a
static collateralized debt obligation of asset-backed securities
transaction consisting primarily of mezzanine commercial mortgage-
backed securities and REIT assets.  At the same time, S&P affirmed
its ratings on the class A and combo notes.

The downgrades reflect deterioration in the credit quality of the
underlying collateral in the portfolio since S&P's last rating
actions in May 2009.

                         Ratings Lowered

                     Crest G-Star 2001-2 Ltd.

                                        Rating
                                        ------
               Class                To         From
               -----                --         ----
               B-1                  BBB+       A-
               B-2                  BBB+       A-
               C                    B-         B+

                         Ratings Affirmed

                     Crest G-Star 2001-2 Ltd.

                   Class                Rating
                   -----                ------
                   A                    AAA
                   Combo                BBB


CWCAPITAL COBALT: Moody's Reviews Ratings on Eight Classes
----------------------------------------------------------
Moody's Investors Service placed eight classes of Notes issued by
CWCapital Cobalt Vr Ltd. on review for possible downgrade due to
deterioration in the credit quality of the underlying portfolio.

CWCapital Cobalt Vr Ltd. is a static commercial real estate
collateralized debt obligation transaction backed by a portfolio
of commercial mortgage backed securities (77% of the pool) and CRE
CDOs (23% of the pool).  As of October 26, 2009, the aggregate
Notes balance of the transaction, including the Preferred Shares,
has decreased to $3,348 million from $3,431 million at issuance,
due to approximately $83 million in pay-down to the Class A-
1Notes.  This is due to the classification of $2,036 million of
collateral par as impaired securities.  Per the Indenture,
interest payments received on impaired securities are treated as
principal payments directed to pay down the Notes in order of
priority of distribution.  As a result, interest shortfalls have
reached Class A-2 per the latest Trustee Report.

Moody's has identified these parameters as key indicators of the
expected loss within CRE CDO transactions: weighted average rating
factor, weighted average life, weighted average recovery rate, and
Moody's asset correlation.  Moody's review will focus on potential
losses from the underlying collateral and any changes to the key
rating parameters.

The rating action is:

  -- Cl. A-1, A2 Placed Under Review for Possible Downgrade;
     previously on March 6, 2009 Downgraded to A2

  -- Cl. A-2, Ba3 Placed Under Review for Possible Downgrade;
     previously on March 6, 2009 Downgraded to Ba3

  -- Cl. B, B3 Placed Under Review for Possible Downgrade;
     previously on March 6, 2009 Downgraded to B3

  -- Cl. C, B3 Placed Under Review for Possible Downgrade;
     previously on March 6, 2009 Downgraded to B3

  -- Cl. D, Caa1 Placed Under Review for Possible Downgrade;
     previously on March 6, 2009 Downgraded to Caa1

  -- Cl. E, Caa1 Placed Under Review for Possible Downgrade;
     previously on March 6, 2009 Downgraded to Caa1

  -- Cl. F, Caa2 Placed Under Review for Possible Downgrade;
     previously on March 6, 2009 Downgraded to Caa2

  -- Cl. G, Caa3 Placed Under Review for Possible Downgrade;
     previously on March 6, 2009 Downgraded to Caa3

Moody's monitors transactions on both a monthly basis through a
review of the available Trustee Reports and a periodic basis
through a full review.  Moody's prior review is summarized in a
press release dated March 6, 2009.


CWCAPITAL COBALT: S&P Downgrades Ratings on 10 Classes to 'D'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D' on
10 classes from CWCapital COBALT Vr Ltd., a commercial real estate
collateralized debt obligation transaction.  S&P's 'AAA' rating on
class A-1 remains on CreditWatch with negative implications.

The downgrades to 'D' of classes A-2 through K reflect S&P's
analysis of the interest shortfalls affecting these classes, which
S&P believes will recur for the foreseeable future and will not be
recovered.  This assessment reflects S&P's interpretation of the
transaction's governing documents regarding COBALT Vr's payment
waterfall, including the disbursement of monies received from the
underlying assets.

S&P left its 'AAA' rating on class A-1 unchanged based on its
analysis of the transaction, including the underlying assets, and
its expectation that class A-1 will continue to receive interest
due.  The class A-1 rating remains on CreditWatch negative because
of the transaction's exposure to commercial mortgage-backed
securities with ratings on CreditWatch negative ($854.6 million,
25.2%).

As of the Oct. 26, 2009, trustee report, classes A-2 through K
are subject to an aggregate unpaid interest shortfall of
$64.4 million.  The unpaid interest shortfall is a result of the
classification of certain CMBS assets as impaired securities
($2.036 billion, 60%).  According to the governing transaction
documents, an asset can be deemed impaired for several reasons,
including a CreditWatch negative placement on or downgrade of
the rating on the asset.  Standard & Poor's has downgraded
$623.9 million (18.4%) of the underlying CMBS assets, and the
ratings on an additional $854.6 million (25.2%) are currently
on CreditWatch negative.  As a result of the impairment
classifications on the assets, all interest payments received
from these securities are classified as principal proceeds and
applied toward the reduction of the class A-1 principal balance.
After class A-1 principal is fully repaid, the principal proceeds
and interest proceeds from impaired securities will be applied
toward the repayment of the principal of subsequent classes but
not toward the repayment of unpaid interest shortfalls.

According to S&P's interpretation of the transaction documents,
there are no mechanisms in place in the payment waterfall to allow
for the repayment of the interest shortfalls, except for an event
of default or the declaration of a redemption event.

According to the Oct. 26, 2009, trustee report, COBALT Vr's
current assets included 233 classes ($2.567 billion, 76.5%) of
CMBS pass-through certificates from 49 distinct transactions.
Cobalt Vr's non-CMBS assets include secured notes issued by the CM
Trust ($406.6 million, 12%) backed by six classes from CRIIMI MAE
Commercial Mortgage Trust's series 1998-C1, a CMBS resecuritized
real estate mortgage investment conduit transaction, and 10
classes ($388.5 million, 11.5%) from ten CRE CDO transactions.

S&P expects to update or resolve the CreditWatch negative
placement on class A-1 in conjunction with S&P's resolution of the
CreditWatch placements on the underlying CMBS assets.

                         Ratings Lowered

                     CWCapital COBALT Vr Ltd.
                       $3.432 billion notes

                           Rating
                           ------
             Class    To              From
             -----    --              ----
             A2       D               BBB+/Watch Neg
             B        D               BBB+/Watch Neg
             C        D               BBB-/Watch Neg
             D        D               BB+/Watch Neg
             E        D               BB+/Watch Neg
             F        D               BB/Watch Neg
             G        D               BB-/Watch Neg
             H        D               B-/Watch Neg
             J        D               CCC-/Watch Neg
             K        D               CCC-/Watch Neg

             Rating Remaining On Creditwatch Negative

                     CWCapital COBALT Vr Ltd.
                       $3.432 billion notes

                     Class    Rating
                     -----    ------
                     A1       AAA/Watch Neg


GE COMMERCIAL: S&P Downgrades Ratings on 11 2005-C2 Securities
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 11
classes of commercial mortgage-backed securities from GE
Commercial Mortgage Corp.'s series 2005-C2 and removed them from
CreditWatch with negative implications.  In addition, S&P affirmed
its ratings on 11 classes from the same transaction and removed
six of them 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 credit support erosion S&P
anticipate will occur upon the eventual resolution of several
specially serviced loans.  S&P's analysis included a review of the
credit characteristics of all of the loans in the pool.  Using
servicer-provided financial information, S&P calculated an
adjusted debt service coverage of 1.45x and a loan-to-value ratio
of 103.2%.  S&P further stressed the loans' cash flows under its
'AAA' scenario to yield a weighted average DSC of 0.99x and an LTV
of 132.1%.  The implied defaults and loss severity under the 'AAA'
scenario were 61.9% and 38.0%, respectively.  All of the DSC and
LTV calculations noted above exclude three ($22.4 million, 1.4%)
of the five specially serviced assets, and 16 ($135.3 million,
8.6%) defeased loans.  S&P separately estimated losses for the
three specially serviced assets, which are included in its 'AAA'
scenario implied default and loss figures.

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-
C and X-P 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 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

As of the November 2009 remittance report, five assets
($82.6 million, 5.2%) in the pool were with the special servicer,
LNR Partners Inc.  A breakdown of the specially serviced assets by
payment status is: two are real estate owned ($19.1 million,
1.2%), one is more than 90 days delinquent ($3.2 million, 0.2%),
one is in its grace period ($50.0 million, 3.2%), and one is
current ($10.2 million, 0.7%).  Three of the specially serviced
loans have appraisal reduction amounts in effect totaling
$8.4 million.

The largest loan with the special servicer and the fifth-largest
in the pool is the 125 West 55th Street loan with a total exposure
of $50.2 million (3.2%).  The loan was transferred to the special
servicer on Aug. 21, 2009, due to imminent maturity default.  The
loan matures March 1, 2010.  The loan is in its grace period and
is secured by a 555,475-sq.-ft. office building in Midtown
Manhattan.  For year-end 2008, the reported DSC was 2.02x and
occupancy was 100%, up from 1.58x and 100% at issuance.  The
borrower has requested an extension for the maturing loan.

The remaining specially serviced loans have balances that
individually represent less than 0.7% of the total pool balance.
S&P's estimated losses for three of these assets (1.4%) range from
28.5% to 61.3%.  S&P expects the fourth (0.6%) to be returned to
the master servicer.  The borrower was in a dispute with the trust
over the release of a letter of credit, which has been settled.

                        Transaction Summary

As of the November 2009 remittance report, the collateral pool
consisted of 139 loans with an aggregate trust balance of
$1.58 billion, which represents approximately 85.0% of the trust
balance at issuance.  There are 139 loans in the pool, down from
142 at issuance.  Sixteen loans ($135.3 million, 8.6%) in the pool
have been defeased.  The master servicer for the transaction,
GEMSA Loan Services L.P., provided financial information for 99.8%
of the pool; 93.4% of the financial information was full-year 2008
data or interim-2009 data.  S&P's adjusted DSC and LTV were 1.45x
and 103.2%, respectively.  S&P's adjusted DSC and LTV figures
exclude three ($22.4 million, 1.4%) of the five specially serviced
assets for which S&P separately estimated losses.  GEMSA provided
DSC figures for two of these three loans, and based on these
figures, S&P calculated a weighted average DSC of 1.61x.  Twenty-
nine loans (34.1%) are on GEMSA's watchlist, including five of the
top 10 loans.  Fifteen loans ($281.2 million, 17.8%) have a
reported DSC of less than 1.10x, and 12 of these loans
($219.6 million, 13.9%) have a reported DSC of less than 1.0x.

                     Summary of Top 10 Loans

The top 10 loan exposures have an aggregate outstanding balance of
$498.5 million (31.5%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC for the top 10 loans of 1.55x.
Five of the top 10 loans ($303.0 million, 19.1%) appear on GEMSA's
watchlist, and one loan ($50.0 million, 3.2%) is with the special
servicer as discussed above.  S&P's adjusted DSC and LTV for the
top 10 loans are 1.37x and 118.9%, respectively.  The three
largest loans on GEMSA's watchlist are discussed below.

The Fountain Place Office loan is the largest loan in the pool and
the largest loan on GEMSA's watchlist.  The loan is current and
has a trust balance of $105.9 million (6.7%), and appears on the
watchlist due to low DSC.  The loan is secured by a 1.2 million-
sq.-ft. office building located in Dallas.  The reported DSC and
occupancy for year-end 2008 was 0.54x and 67.2%.  However, Tenet
Health signed a lease for 164,954 sq. ft. (13.7% of net rentable
area) at the property in 2008.  The Tenet Health space is
currently under construction and construction is expected to be
completed later this month.  Including the Tenet Health lease,
occupancy will increase to 80.3%.

The Loews Miami Beach Hotel loan is the second-largest loan in the
pool and the second-largest loan on GEMSA's watchlist.  The loan
appears on the watchlist due to insufficient windstorm insurance
coverage.  The loan is current and has a trust balance of
$69.5 million (4.4%) and a whole-loan balance of $139.0 million.
The loan is secured by a 790-room full service hotel in Miami
Beach, Fla.  The reported DSC for year-end 2008 was 3.38x.

The Centro Watt Georgia Retail Portfolio loan is the third-largest
loan in the pool.  The loan is on GEMSA's watchlist due to the
bankruptcy of two major tenants.  The loan is current and has a
trust balance of $66.0 million (4.2%).  The loan is secured by
three cross-collateralized and cross-defaulted retail power
centers totaling 691,196 sq. ft. located in the suburbs of
Atlanta, Ga.  Circuit City and Linen 'N Things occupied a total of
77,535 sq. ft. (11.2% of NRA) in the portfolio but closed in late
2008.  In addition, the Broyhill Furniture Galleries and Broyhill
by Hudson stores, which occupied a total of 77,298 sq. ft. (11.2%
of NRA), are also dark.  According to the June 30, 2009, rent
roll, and excluding the Circuit City, Linen 'N Things, and
Broyhill tenants, occupancy is 76.7%.  For the trailing 12 months
ending June 30, 2009, the reported DSC for the portfolio was
1.85x, down from 1.89x at year-end 2008.

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

                   GE Commercial Mortgage Corp.
   Commercial mortgage pass-through certificates series 2005-C2

                Rating
                ------
     Class     To     From             Credit enhancement (%)
     -----     --     ----             ----------------------
     A-J       BBB+   AAA/Watch Neg                     13.92
     B         BBB    AA+/Watch Neg                     13.04
     C         BBB-   AA/Watch Neg                      11.12
     D         BB+    AA-/Watch Neg                     10.10
     E         BB     A/Watch Neg                        8.48
     F         BB-    A-/Watch Neg                       7.45
     G         B+     BBB+/Watch Neg                     6.12
     H         B+     BBB/Watch Neg                      5.09
     J         B      BB+/Watch Neg                      3.77
     K         B      BB-/Watch Neg                      3.18
     L         B-     B+/Watch Neg                       2.74

      Ratings Affirmed And Removed From Creditwatch Negative

                    GE Commercial Mortgage Corp.
   Commercial mortgage pass-through certificates series 2005-C2

                Rating
                ------
     Class     To      From             Credit enhancement (%)
     -----     --      ----             ----------------------
     A-4       AAA     AAA/Watch Neg                    23.33
     A-1A      AAA     AAA/Watch Neg                    23.33
     M         B-      B-/Watch Neg                      2.15
     N         CCC+    CCC+/Watch Neg                    2.00
     O         CCC     CCC/Watch Neg                     1.56
     P         CCC-    CCC-/Watch Neg                    1.27

                         Ratings Affirmed

                    GE Commercial Mortgage Corp.
    Commercial mortgage pass-through certificates series 2005-C2

            Class     Rating    Credit enhancement (%)
            -----     ------    ----------------------
            A-2       AAA                        23.33
            A-3       AAA                        23.33
            A-AB      AAA                        23.33
            X-C       AAA                          N/A
            X-P       AAA                          N/A

                      N/A -- Not applicable.


GREENWICH STRUCTURED: S&P Downgrades Rating on Class N-3 Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
N-3 note from Greenwich Structured ARM Products CI 2006-1, a
residential mortgage-backed securities resecuritized real estate
mortgage investment conduit transaction, to 'CCC' from 'BB'.  At
the same time, S&P affirmed its 'BBB-' rating on the class N-2
note.

The downgrade reflects the performance of the loans backing the
underlying certificates.  The affirmation reflects the sufficient
credit enhancement within GSAP 2006-1 to maintain the rating on
class N-2, which is supported by the N-3 class.

GSAP 2006-1, which closed in March 2006, is collateralized by 11
underlying classes that support the notes within the re-REMIC.
The loans securing the 11 underlying classes consist predominately
of long-reset adjustable-rate Alternative-A mortgage loans.

The classes that support the classes N-2 and N-3 notes from GSAP
2006-1 are classes X-1, X-2, and X-3 (each currently rated 'AAA'),
B-5 (currently rated 'D'), and B-6 and P (both currently rated
'NR') from Harborview Mortgage Loan Trust 2004-10, and classes X
(currently rated 'AA'), B-4, and B-5 (both currently rated 'D'),
and B-6 and P (both currently rated 'NR') from Harborview Mortgage
Loan Trust 2005-6.

The performance of the loans securing Harborview Mortgage Loan
Trust 2004-10 has declined in recent months.  This pool had
experienced losses of 0.73% of the original pool balance as of the
October 2009 distribution, currently has approximately 26.90% of
the current pool balance in delinquent loans, and a pool factor of
.1485 (14.85%), which represents the outstanding pool balance as a
proportion of the original balance.

The performance of the loans securing Harborview Mortgage Loan
Trust 2005-6 has also declined in recent months.  This pool had
experienced losses of 1.64% of the original pool balance as of the
October 2009 distribution, and currently has approximately 36.98%
of the current pool balance in delinquent loans.  Based on the
losses to date, the current pool factor of .1124 (11.24%), and the
pipeline of delinquent loans, S&P's current projected loss for
this pool is 4.38%.

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 expectation.

                          Rating Lowered

            Greenwich Structured ARM Products CI 2006-1
                        Series      2006-1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        N-3        39700UAC8     CCC                  BB

                         Rating Affirmed

           Greenwich Structured ARM Products CI 2006-1
                        Series      2006-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 N-2        39700UAB0     BBB-


G-STAR 2005-5: Fitch Downgrades Ratings on Six Classes of Notes
---------------------------------------------------------------
Fitch Ratings has downgraded six classes of notes issued by G-Star
2005-5 Ltd. as a result of continued credit deterioration in the
portfolio since Fitch's last rating action in August 2008.
Approximately 68.5% of the portfolio has been downgraded since
that time.  The details of the rating action follow at the end of
this press release.

As of the October 2009 trustee report, the current balance of the
portfolio is approximately $521.5 million.  Defaulted securities,
as defined in the transaction's governing documents, now comprise
35.1% of the portfolio compared to 0.5% at last review.  The
downgrades to the portfolio have left approximately 80.6% of the
portfolio with a Fitch derived rating below investment grade and
50.1% with a rating in the 'CCC' rating category or lower
(including defaulted assets), compared to 44.9% and 10.7%,
respectively, at last review.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Structured Finance Portfolio Credit Model for projecting
future default levels for the underlying portfolio.  Due to the
significant collateral deterioration, all PCM rating loss rates
exceed the credit enhancement available to each class of notes.
The transaction is currently paying down in a straight sequential
order and is expected to continue to do so until maturity.  Given
these factors, Fitch believes that the likelihood of default for
all classes of notes in this transaction can be assessed without
performing cash flow model analysis under the framework described
in the 'Global Criteria for Cash Flow Analysis in CDOs' report.

While some portion of the interest collections is currently being
used to pay down the class A-1 notes due to failing coverage
tests, the magnitude of this additional credit enhancement is not
considered sufficient enough to offset the significant
deterioration in the credit quality of the portfolio.  As a
result, Fitch believes that default is probable for the class A-1
notes and has downgraded the class to 'CC'.

The class A-2, class A-3, class B, class C and income notes are
downgraded to 'C' due to the inevitability of their default at or
prior to maturity.  While the class A-2 and class A-3 notes are
still receiving timely interest distributions, the outstanding
balance of the class A-1 notes relative to the performing portion
of the portfolio makes it unlikely for the class A-2 notes to
receive any significant principal repayment.  The class B, class C
and income notes are not expected to receive any interest or
principal distributions going forward.

G-Star 2005-5 is a structured finance collateralized debt
obligation that closed on March 16, 2005 and is managed by MBIA
Asset Management Corp., who replaced Ventras Capital Advisors LLC
on Nov. 11, 2009.  The portfolio is composed of residential
mortgage-backed securities (62.7%), commercial mortgage-backed
securities (16%), commercial real estate loans (13.3%) and SF CDOs
(8%).

Fitch has downgraded these classes of G-Star 2005-5 as indicated:

  -- $332,859,598 class A-1 notes downgraded to 'CC' from 'BBB';
  -- $60,000,000 class A-2 notes downgraded to 'C' from 'BB';
  -- $37,000,000 class A-3 notes downgraded to 'C' from 'BB-';
  -- $21,815,736 class B notes downgraded to 'C' from 'B';
  -- $24,780,571 class C notes downgraded to 'C' from 'CCC';
  -- $35,000,000 income notes downgraded to 'C' from 'CC'.


GE COMMERCIAL: Fitch Takes Rating Actions on 2005-C3 Certs.
-----------------------------------------------------------
Fitch Ratings takes various actions on GE Commercial Mortgage
Corporation, series 2005-C3 commercial mortgage pass-through
certificates, including downgrades of 14 classes.  A detailed list
of rating actions follows at the end of this release.

The downgrades are the result of Fitch's loss expectations and its
prospective views regarding cash flow declines and commercial real
estate market values.  Fitch forecasts potential losses of 4.7%
for this transaction, should market conditions not recover.  The
rating actions are based on the full losses of 4.2% as a majority
of loans mature in the next five years.  The bonds with Negative
Outlooks indicate classes that may be downgraded in the future.

To determine potential defaults for each loan, Fitch assumed cash
flow would decline by 10% from year-end 2008.  That is consistent
with the analysis used in its review of recent vintage
transactions whereby cash flow was assumed to decline 15% from
year-end 2007 projected over a three-year period.  If the stressed
cash flow would cause the loan to fall below 0.95 times DSCR,
Fitch assumed the loan would default during the term.  To
determine losses, Fitch used the above stressed cash flow and
applied a market cap rate by property type, ranging between 7.5%
and 10%, to derive a value.  If the loan balance at default is
less than Fitch's derived value, the loan would realize that
amount of loss.  These loss estimates were reviewed in more detail
for loans representing 59.7% of the pool and, in certain cases,
revised based on additional information and/or property
characteristics.  Loss expectations attributed to loans reviewed
in detail represent approximately 82% of the 4.7%.

Approximately 38.5% of the mortgages mature within the next five
years: 28.1% in 2010, 0% in 2011, 10.4% in 2012, 0% in 2013, and
0% in 2014.  All losses associated with these loans are fully
recognized in the rating actions.

Fitch identified 15 Loans of Concern (16.8%) within the pool, four
of which (6.5%) are specially serviced, three of which are current
(6.3%) and one (0.1%) that is 90-days delinquent.

Fitch's analysis resulted in loss expectations for four of the top
15 loans.  Two of which (7.8%) are assumed to default during the
loan term, as the stressed cash flow is below 0.95x DSCR.  Two
additional loans (5.9%) are assumed to incur losses at maturity
based on its balloon loan balance being greater than the implied
value of the properties.  Fitch expects that ten of the top 15
loans may default at maturity based on an insufficient accrued
equity position as calculated in Fitch's refinance test; however,
Fitch's analysis did not result in a loss for these ten loans
based on its derived values being higher than the current loan
amounts.  A loan would pass the refinance test if the stressed
cash flow would achieve a 1.25x DSCR as calculated based on a 30
year amortization schedule and an 8% coupon.  One loan (7.3%) is
expected to payoff at maturity based on its strong performance.

The largest contributors to loss are: One Main Place (3.3%),
Garden City Plaza (4.5%) and 12000 Biscayne Office Building
(0.6%).

One Main place is secured by a one million sf office building
located in downtown Dallas, TX.  The servicer-reported June 2009
debt service coverage ratio and occupancy were 0.94x and 71.7%,
respectively.  Occupancy at the property has recently dropped due
in part to Ernst & Young's non-renewal of their space (10.1%).
Based on current performance and anticipated declines, losses are
expected prior to the loan's maturity in 2012.

Garden City Plaza is secured by four adjacent, five story office
buildings totaling 583,017 sf located in Garden City, New Jersey.
The servicer-reported June 2009 DSCR and occupancy were 0.94x and
88.1% compared to the DSCR and occupancy of 1.20x and 97.4% at
issuance.  The subject's performance has declined due to increases
in operating expenses and declines in occupancy.

12000 Biscayne Office Building is secured by a 150,924 sf office
building located in Miami, Florida.  The subject's performance has
declined due to a decrease in occupancy.  The servicer-reported YE
2008 DSCR and occupancy were 0.96x and 61.0% compared to the DSCR
and occupancy of 1.20x and 88.2% at issuance.

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

  -- $161.4 million class A-J to 'AA/LS3' from 'AAA'; Outlook
     Stable;

  -- $13.2 million class B to 'AA/LS5' from 'AA+'; Outlook
     Negative;

  -- $29.1 million class C to 'A/LS5' from 'AA'; Outlook Negative;

  -- $21.2 million class D to 'BBB/LS5' from 'AA-'; Outlook
     Negative;

  -- $34.4 million class E to 'BBB-/LS5' from 'A'; Outlook
     Negative;

  -- $18.5 million class F to 'BB/LS5' from 'A-'; Outlook
     Negative;

  -- $23.8 million class G to 'BB/LS5' from 'BBB+'; Outlook
     Negative;

  -- $21.2 million class H to 'B/LS5' from 'BBB'; Outlook
     Negative;

  -- $31.7 million class J to 'B-/LS5' from 'BBB-'; Outlook
     Negative;

  -- $7.9 million class K to 'B-/LS5' from 'BB+'; Outlook
     Negative;

  -- $7.9 million class L to 'B-/LS5' from 'BB'; Outlook Negative;

  -- $10.6 million class M to 'B-/LS5' from 'BB-'; Outlook
     Negative;

  -- $2.6 million class N to 'B-/LS5' from 'B+'; Outlook Negative;

  -- $7.9 million class O to 'B-/LS5' from 'B'; Outlook Negative.

Also, Fitch affirms and assigns Loss Severity ratings for these
classes as indicated:

  -- $31.4 million class A-1 at 'AAA/LS1'; Outlook Stable;
  -- $117.4 million class A-2 at 'AAA/LS1'; Outlook Stable;
  -- $180 million class A-3FX at 'AAA/LS1'; Outlook Stable;
  -- $25 million class A-3FL at 'AAA/LS1'; Outlook Stable;
  -- $145.4 million class A-4 at 'AAA/LS1'; Outlook Stable;
  -- $118.2 million class A-5 at 'AAA/LS1'; Outlook Stable;
  -- $75 million class A-6 at 'AAA/LS1'; Outlook Stable;
  -- $74.5 million class A-AB at 'AAA/LS1'; Outlook Stable;
  -- $386.7 million class A-7A at 'AAA/LS1'; Outlook Stable;
  -- $55.2 million class A-7B at 'AAA/LS1'; Outlook Stable;
  -- $435.8 million class A-1A at 'AAA/LS1'; Outlook Stable;
  -- Interest only class X-C at 'AAA'; Outlook Stable;
  -- Interest only class X-P at 'AAA'; Outlook Stable.

The $7.9 million class P and $23.8 million class Q are not rated
by Fitch.


GS MORTGAGE: Moody's Reviews Ratings on Nine Series 2004-C1 Certs.
------------------------------------------------------------------
Moody's Investors Service placed nine classes of GS Mortgage
Securities Corporation II, Commercial Mortgage Pass-Through
Certificates, Series 2004-C1 on review for possible downgrade due
to higher expected losses for the pool resulting from anticipated
losses from loans in special servicing, concerns about loans
approaching maturity in an adverse environment, and interest
shortfalls.  The pool has paid down significantly since Moody's
last review, but the pool's exposure to specially serviced loans
has also increased, from 0% to 21%.  The rating action is the
result of Moody's on-going surveillance of commercial mortgage
backed securities transactions.

As of the November 10, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by 65% to $308 million
from $892 million at securitization.  The Certificates are
collateralized by 25 mortgage loans ranging in size from less than
1% to 17% of the pool, with the top ten non-defeased loans
representing 55% of the pool.  Eight loans, representing 36% of
the pool, have defeased and are collateralized with U.S.
Government securities compared with 15 loans (37%) at Moody's last
review.

Four loans, representing 27% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.

Two loans have been liquidated from the pool, resulting in an
aggregate realized loss of less than $50,000.  Six loans,
representing 21% of the pool, are currently in special servicing.
The largest specially serviced loan is the Hyatt Regency Dearborn
($28.8 million -- 9.3% of the pool), which is secured by a 246-
room full-service hotel located in Dearborn, Michigan.  This loan
is currently in the process of foreclosure.  The remaining five
specially serviced loans are secured by a mix of multifamily and
retail properties.  The servicer has recognized an aggregate
appraisal reduction of $14.6 million for three of the specially
serviced loans.

As a result of loans being transferred to special servicing, the
transaction has experienced interest shortfalls to Moody's rated
classes.  Currently below investment-grade rated Classes N through
P are experiencing interest shortfalls totaling approximately
$367,000.

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

Moody's rating action is:

  -- Class F, $13,384,000, currently rated Baa1, on review for
     possible downgrade; previously assigned Baa1 on 6/23/2004

  -- Class G, $7,808,000, currently rated Baa2, on review for
     possible downgrade; previously assigned Baa2 on 6/23/2004

  -- Class H, $7,807,000, currently rated Baa3, on review for
     possible downgrade; previously assigned Baa3 on 6/23/2004

  -- Class J, $5,557,000, currently rated Ba1, on review for
     possible downgrade; previously assigned Ba1 on 6/23/2004

  -- Class K, $3,346,000, currently rated Ba2, on review for
     possible downgrade; previously assigned Ba2 on 6/23/2004

  -- Class L, $3,346,000, currently rated Ba3, on review for
     possible downgrade; previously assigned Ba3 on 6/23/2004

  -- Class M, $4,461,000, currently rated B1, on review for
     possible downgrade; previously assigned B1 on 6/23/2004

  -- Class N, $3,346,000, currently rated B2, on review for
     possible downgrade; previously assigned B2 on 6/23/2004

  -- Class O, $3,346,000, currently rated B3, on review for
     possible downgrade; previously assigned B3 on 6/23/2004


GS MORTGAGE: Moody's Affirms Ratings on 13 2005-GG4 Certificates
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 13 classes and
downgraded 14 classes of GS Mortgage Securities Corporation II,
Commercial Mortgage Pass-Through Certificates, Series 2005-GG4.

The downgrades are due to higher expected losses for the pool
resulting from estimated losses from loans in special servicing,
concerns about refinancing risk associated with loans approaching
maturity in an adverse environment, and increased credit quality
dispersion.  Fourteen loans, representing 10% of the pool, mature
within the next 24 months and have a Moody's stressed debt service
coverage ratio below 1.00X.

The affirmations are due to key rating parameters, including
Moody's loan to value ratio, stressed DSCR and the Herfindahl
Index, remaining within acceptable ranges.

On August 11, 2009, Moody's placed 14 classes on review for
possible downgrade due to the credit uncertainty surrounding
Maguire Properties Inc., the sponsor of four loans representing
10% of the outstanding deal balance.  Maguire has experienced
ongoing levels of high effective leverage, declining operating
performance, and an inability to cover dividends from operating
cash flow.  This action concludes Moody's review of the
transaction.  The rating action is the result of Moody's on-going
surveillance of commercial mortgage backed securities
transactions.

As of the November 13, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 5% to
$3.81 billion from $4.0 billion at securitization.  The
Certificates are collateralized by 186 mortgage loans ranging in
size from less than 1% to 5% of the pool, with the top ten non-
defeased loans representing 30% of the pool.  The pool contains
two loans with investment grade underlying ratings, representing
6% of the pool.  At securitization a third loan, the Cascade Mall
Loan ($38.2 million -- 1.0% of the pool) also had an underlying
rating.  However, the performance of the property securing the
loan has declined and the loan is now analyzed as part of the
conduit pool because of increased leverage.  Ten loans,
representing 8% of the pool, have defeased and are collateralized
with U.S. Government securities.  The share of defeased loan was
also 8% at last review.

Forty-one loans, representing 25% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.  Not all loans on the
watchlist are delinquent or have significant issues.

One loan has been liquidated from the pool since securitization,
resulting in a realized loss of $454,305 (1% loss severity).  Five
loans, representing 4% of the pool, are in special servicing.  The
largest specially serviced loan is the Astor Crowne Plaza Hotel
Loan ($80.3 million -- 2% of the pool), which is secured by two
adjacent full-service hotels located in New Orleans, Louisiana.
The two hotels contain 707-guestrooms.  The loan was transferred
to special servicing in May 2009 for payment default.  The second
largest specially serviced loan is the Temple Mall Loan
($36 million -- 1% of the pool), which is secured by a 447,000
square foot regional mall located in Temple, Texas.  The loan was
transferred to special servicing in September 2008 for imminent
default.  Steve & Barry's, which occupied 13% of the premises at
securitization, vacated in 2008 after filing for Chapter 11
bankruptcy.  Although the loan is current, the borrower has
indicated an inability to sustain debt service payments due the
mall's current vacancy.  The remaining three specially serviced
loans are secured by a mix of lodging, retail and office
properties.  Moody's estimates an aggregate loss of $62.3 million
(37% loss severity on average) from the specially serviced loans.
The servicer has recognized an aggregate $21.4 million appraisal
reduction on two of the specially serviced loans.

Moody's was provided with full-year 2008 and partial-year 2009
operating results for 94% and 82% of the pool, respectively.
Moody's weighted average LTV for the conduit component is 105%,
essentially the same as at last review.  Although the overall pool
LTV has remained relatively stable, the pool has experienced
increased credit quality dispersion.  Based on Moody's analysis,
58% of the pool has a LTV ratio in excess of 100% compared to 52%
at last review.

Moody's stressed DSCR for the conduit component is 0.99X compared
to 1.02X at last review.  Moody's stressed DSCR is based on
Moody's net cash flow and a 9.25% stressed rate applied to the
loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple-notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool, excluding defeased loans and loans with underlying ratings,
has a Herf of 57, essentially the same as at last review.

The largest loan with an underlying rating is the Streets at
Southpoint Loan ($158.3 million -- 4.2% of the loan), which is
secured by a 1.3 million square foot regional mall located in
Durham, North Carolina.  The center is anchored by Macy's,
Nordstrom, Hudson Belk, JCPenney and Sears.  The loan sponsor is
General Growth Properties, Inc., which filed for Chapter 11
bankruptcy protection on April 16, 2009.  This property was not
included in the bankruptcy filing.  The in-line mall stores were
99% leased as of June 2009, the same as at last review.  In-line
mall sales for full year 2008 were $490 per square foot compared
to $539 in 2007 and $396 at securitization.  Property performance
has been stable; however, Moody's analysis reflects a downward
adjustment to the property's cash flow due to Moody's concerns
about the potential impact of GGP's bankruptcy on property
operations.  Moody's current underlying rating and stressed DSCR
are Baa3 and 1.35X compared to Baa3 and 1.41X last review.

The second largest loan with an underlying rating is the 200
Madison Avenue Loan ($45.0 million -- 1.2% of the pool), which is
secured by a 666,200 square foot office building located in the
Midtown South submarket of New York City.  The property was 98%
leased as of September 2009, essentially the same as at last
review.  The largest tenant is the Phillips Van Heusen Corporation
(Moody's senior unsecured rating Ba3, positive outlook), which
occupies 24% of the premises through October 2023.  Performance
has declined due to an increase in operating expenses.  While
revenues have remained flat, expenses have grown at an annual rate
of approximately 5% since 2005.  The loan is interest-only for its
entire term.  Moody's current underlying rating and stressed DSCR
are Aa3 and 1.59X, respectively, compared to Aa2 and 1.69X% at
last review.

The loan that previously had an underlying rating is the Cascade
Mall Loan ($38.2 million -- 1.0% of the pool), which is secured by
a 434,000 square foot regional mall located in Burlington,
Washington.  The center is anchored by Macy's, JCPenny and Sears.
The in-line mall stores were 81% leased compared to 85% at
securitization.  Property performance has declined since last
review due to a decline in revenue and an increase in operating
expenses.  The loan sponsor is Macerich.  Moody's LTV and DSCR are
97% and 0.97X, respectively, compared to 78% and 1.22X at last
review.

The three largest conduit loans represent 13% of the pool.  The
largest conduit loan is the Wells Fargo Center Loan
($200.0 million -- 5.2% of the pool), which is secured by a
1.2 million square foot Class A office building located in
downtown Denver, Colorado.  The property was 100% leased as of
June 2009 compared to 96% at last review.  The largest tenant is
Wells Fargo Bank, N.A.  (Moody's senior unsecured rating Aa2,
stable outlook), which occupies 30% of the premises through
December 2020.  The loan sponsor is Maguire.  Although performance
has been stable, Moody's is concerned about lease rollover
exposure and the associated costs within the next three years,
given the softness of the Denver office market and Maguire's
current financial issues.  The loan is interest-only for its
entire term.  Moody's LTV and stressed DSCR are 134% and 0.71X,
respectively, compared to 119% and 0.79X at last review.

The second largest conduit loan is the Mall at Wellington Green
Loan ($200.0 million -- 5.2% of the pool), which is secured by the
borrower's interest in a 1.3 million square foot regional mall
located in West Palm Beach, Florida.  The loan sponsor is the
Taubman Realty Group.  The mall is anchored by Dillard's, Macy's,
JCPenney and Nordstrom.  The center was 97% leased as of July 2009
compared to 95% last review.  Despite stable occupancy, mall sales
have declined since securitization.  For calendar year 2008, in-
line mall sales were $373 per square foot compared to $408 in 2007
and $414 at securitization.  Property performance declined in 2009
due to lower revenues and expense recoveries.  Moody's LTV and
stressed DSCR are 107% and 0.86X, respectively, compared to 96%
and 0.99X at last review.

The third largest conduit loan is the Latana Campus Loan
($98.0 million -- 2.5% of the pool), which is secured by three
office buildings located in Santa Monica, California.  The
buildings total 332,000 square feet and were 84% leased as of June
2009 compared to 64% at last review.  Tenancy is primarily
composed of post-production firms in the entertainment industry.
The loan sponsor is Maguire, which master-leases 27% of the
premises through December 2009.  Although the occupancy rate has
improved since Moody's last review, the property has significant
near-term rollover risk and its existing tenancy is susceptible to
the volatility inherent in the entertainment industry.  In
addition, Moody's is concerned about Maguire's ability to fund
potentially significant tenant costs given their current financial
issues.  The loan matures in January 2010.  The loan is on the
servicer's watchlist for upcoming maturity, sponsor issues and low
occupancy.  Moody's LTV and stressed DSCR is 140% and 0.73X,
respectively, compared to 117% and 0.88X at last review.

Moody's rating action is:

  -- Class A-1, $45,051,698, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class A-1P, $22,525,849, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class A-DP, $97,823,541, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class A-2, $349,848,000, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class A-3, $288,705,000, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class A-ABA, $207,259,000, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class A-ABB, $29,609,000, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class A-4, $500,000,000, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class A-4A, $1,171,595,000, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class A-4B, $167,371,000, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class A-1A, $167,992,574, affirmed at Aaa; previously on
     7/15/2005 assigned at Aaa

  -- Class X-P, Notional, affirmed at Aaa; previously on 7/15/2005
     assigned at Aaa

  -- Class X-C, Notional, affirmed at Aaa; previously on 7/15/2005
     assigned at Aaa

  -- Class A-J, $300,060,000, downgraded to A1; previously on
     8/11/2009 Aaa Placed Under Review for Possible Downgrade

  -- Class B, $65,013,000, downgraded to A2; previously on
     8/11/2009 Aa1 Placed Under Review for Possible Downgrade

  -- Class C, $35,007,000, downgraded to Baa2; previously on
     8/11/2009 Aa3 Placed Under Review for Possible Downgrade

  -- Class D, $75,015,000, downgraded to Ba2; previously on
     8/11/2009 A2 Placed Under Review for Possible Downgrade

  -- Class E, $40,008,000, downgraded to B2; previously on
     8/11/2009 A3 Placed Under Review for Possible Downgrade

  -- Class F, $55,011,000, downgraded to Caa1; previously on
     8/11/2009 Baa1 Placed Under Review for Possible Downgrade

  -- Class G, $45,009,000, downgraded to Caa2; previously on
     8/11/2009 Baa2 Placed Under Review for Possible Downgrade

  -- Class H, $40,008,000, downgraded to Ca; previously on
     8/11/2009 Ba2 Placed Under Review for Possible Downgrade

  -- Class J, $20,004,000, downgraded to C; previously on
     8/11/2009 B1 Placed Under Review for Possible Downgrade

  -- Class K, $20,004,000, downgraded to C; previously on
     8/11/2009 B2 Placed Under Review for Possible Downgrade

  -- Class L, $20,004,000, downgraded to C; previously on
     8/11/2009 B3 Placed Under Review for Possible Downgrade

  -- Class M, $10,002,000, downgraded to C; previously on
     8/11/2009 Caa1 Placed Under Review for Possible Downgrade

  -- Class N, $10,002,000, downgraded to C; previously on
     8/11/2009 Caa2 Placed Under Review for Possible Downgrade

  -- Class O, $10,002,000, downgraded to C; previously on
     8/11/2009 Caa3 Placed Under Review for Possible Downgrade


GS MORTGAGE: Moody's Affirms Ratings on Five 2007-GG10 Certs.
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings of five classes and
downgraded 17 classes of GS Mortgage Securities Corporation II,
Commercial Pass-Through Certificates, Series 2007-GG10.  The
downgrades are due to higher expected losses for the pool
resulting from anticipated losses from specially serviced and
highly leverage watchlisted loans.

The affirmations are due to key rating parameters, including
Moody's loan to value ratio, stressed debt service coverage ratio
and the Herfindahl Index, remaining within acceptable ranges.

Moody's placed two super-senior classes on review due to concerns
that potential losses could be significantly higher than currently
projected due to the poor performance of a large portion of the
pool.  Approximately 90% of the pool has a Moody's stressed DSCR
below 1.00X.  Classes A-4 and A-1A have the longest weighted
average life among the super senior Aaa classes with 30% initial
credit support.  Depending on the magnitude, severity, and timing
of losses from specially serviced loans and the balance of the
pool, along with any loan payoffs, sequential paydowns may not
reach these classes.  At the same time, losses are likely to erode
the credit enhancement cushion for the super senior classes
creating a potential differential in expected loss between those
super senior classes benefiting first from paydowns and those
classes receiving paydowns last.  Although Moody's believe that it
is unlikely that Classes A-4 and A-1A will actually experience
losses, the expected level of credit enhancement and their
priority in the cash flow waterfall may be insufficient for the
current ratings of these classes.  Moody's review will focus on
potential losses from specially serviced loans and the performance
of the overall pool.

On August 11, 2009, Moody's placed 17 classes on review for
possible downgrade due to the credit uncertainty surrounding
Maguire Properties Inc., the sponsor of six loans, representing
18% of the outstanding loan balance.  This action concludes that
review.  The rating action is the result of Moody's on-going
surveillance of commercial mortgage backed securities
transactions.

As of the October 13, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$7.557 billion from $7.562 billion at securitization.  The
Certificates are collateralized by 202 mortgage loans ranging in
size from less than 1% to 9% of the pool, with the top ten loans
representing 42% of the pool.

Thirty-nine loans, representing 32% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.

The pool has not experienced any losses since securitization.
Currently, eighteen loans, representing 12% of the pool, are in
special servicing.  Two of the specially serviced loans,
representing 4% of the pool, are secured by Californian properties
sponsored by Maguire.  The 550 South Hope Street Loan
($165.0 million -- 2% of the pool) is secured by a 566,000 square
foot office building located in Los Angeles.  The Maguire Anaheim
Portfolio Loan ($103.5 million -- 1% of the pool) is secured by
two office properties located in Orange County, California which
total 333,500 square feet.  Of the remaining 16 specially serviced
loans, 15 loans are either 90+days delinquent or in the process of
foreclosure.  Moody's estimates an aggregate $452.8 million loss
for all specially serviced loans (50% loss severity on average).
The servicer has recognized an aggregate $112.6 million appraisal
reduction for ten of the specially serviced loans.

Maguire is the sponsor for six loans in the pool.  Three of these
loans (Wells Fargo Tower -- 7% of the pool; Two California Plaza -
- 6% of the pool; 3800 Chapman - 0.6% of the pool) are on the
master servicer's watchlist due to low debt service coverage and
sponsor concerns.  Two of the loans (550 South Hope Street -- 2%
of the pool; Maguire Anaheim Portfolio -- 1% of the pool) are in
special servicing.  The fourth loan (Lincoln Town Center - 0.7% of
the pool) is not in special servicing or on the watchlist, but has
not achieved the cash flow projected at securitization.  The
servicer's reported DSCR for this loan for the first six months of
2009 was 1.11X.  Due to the high leverage of each of these loans,
the soft Los Angeles and Orange County office markets, and
concerns about the ability of Maguire to fund tenant costs due to
its current financial issues, Moody's believes that these loans
represent a high default risk and has estimated an aggregate
$304.5 million loss for the non specially serviced Maguire loans
(27% loss severity on average).

Moody's was provided with full-year 2008 operating results for 96%
of the pool.  Moody's weighted average LTV ratio, excluding the
specially serviced loans with estimated losses, is 140% compared
to 160% at Moody's prior review in February 2009.  Moody's prior
review was part of the first quarter 2009 ratings sweep of 2006-
2009 vintage CMBS transactions.

Moody's stressed DSCR is 0.78X compared to 0.68X at last review.
Moody's stressed DSCR is based on Moody's net cash flow and a
9.25% stressed rate applied to the loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple-notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 36, essentially the same as at last review.

The top three loans represent 23% of the pool.  The largest loan
is the Shorenstein Portland Portfolio Loan ($697.2 million -- 9.2%
of the pool), which is secured by 16 office properties located in
Portland, Oregon.  The portfolio totals 3.8 million square feet.
The portfolio's was 82% occupied as of June 2009 compared to 94%
at securitization.  Performance had been stable through 2008,
however, operating income declined in 2009 due to a drop in
occupancy.  The loan is interest-only for the entire term.
Moody's LTV and stressed DSCR are 132% and 0.74X, respectively,
compared to 138% and 0.71X at last review.

The second largest loan is the Wells Fargo Tower Loan
($550.0 million -- 7.3% of the pool), which is secured by a
1.4 million square foot Class A office building located in Los
Angeles, California.  The property was 93% occupied as of June
2009, essentially the same as at securitization.  The largest
tenant is Wells Fargo, which occupies 22% of the premises with
leases expiring on a staggered basis beginning in December 2009
through 2013.  The loan sponsor is Maguire.  Moody's is concerned
about near-term lease rollover exposure, given the softness of the
Los Angeles office market and concerns about Maguire's ability to
fund tenant costs due to its current financial issues.  The loan
is on the servicer's watchlist due to low debt service coverage
and sponsor concerns.  The servicer's reported actual DSCR for the
first six months of 2009 was 1.01X.  The loan is interest-only for
the entire term.  Moody's LTV and stressed DSCR are 161% and
0.57X, respectively, compared to 141% and 0.65X at last review.

The third largest loan is the Two California Plaza Loan
($470.0 million -- 6.2% of the pool), which is secured by a 1.3
million square foot class A office building located in downtown
Los Angeles, California.  The loan sponsor is Maguire.  The
property was 83% occupied as of August 2009 compared to 90% at
securitization.  The largest tenant is Deloitte & Touche, which
occupies 26% of the premises through March 2015.  Moody's is
concerned about near-term lease rollover exposure, given the
softness of the Los Angeles office market and concerns about
Maguire's ability to fund tenant costs due to its current
financial issues.  The loan is on the servicer's watchlist due to
low debt service coverage and sponsor concerns.  The servicer's
reported actual DSCR for the first six months of 2009 was 0.87X.
The loan is interest-only for the entire term.  Moody's LTV and
stressed DSCR are 185% and 0.50X, respectively, compared to 133%
and 0.69X at last review.

Moody's rating action is:

  -- Class A-1, $69,854,426, affirmed at Aaa; previously assigned
     at Aaa on 10/26/2007

  -- Class A-2, $725,300,000, affirmed at Aaa; previously assigned
     at Aaa on 10/26/2007

  -- Class A-3, $246,609,000, affirmed at Aaa; previously assigned
     at Aaa on 10/26/2007

  -- Class A-AB, $72,000,000, affirmed at Aaa; previously assigned
     at Aaa on 10/26/2007

  -- Class A-4, $3,661,032,000, currently rated Aaa; placed on
     review for possible downgrade; previously assigned at Aaa on
     10/26/2007

  -- Class A-1A, $514,000,000, currently rated Aaa; placed on
     review for possible downgrade; previously assigned at Aaa on
     10/26/2007

  -- Class A-M, $756,277,000, downgraded to A2 from Aaa;
     previously placed on review for possible downgrade on
     8/11/2007

  -- Class X, Notional, affirmed at Aaa; previously assigned at
     Aaa on 10/26/2007

  -- Class A-J, $519,941,000, downgraded to Ba2 from A2;
     previously placed on review for possible downgrade on
     8/11/2009

  -- Class B, $75,628,000, downgraded to Ba3 from A3; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class C, $94,535,000, downgraded to B2 from Baa1; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class D, $56,720,000, downgraded to B3 from Baa2; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class E, $56,721,000, downgraded to Caa3 from Baa3,
     previously placed on review for possible downgrade on
     8/11/2009

  -- Class F, $75,628,000, downgraded to Ca from Ba1, previously
     placed on review for possible downgrade on 8/11/2009

  -- Class G, $75,628,000, downgraded to Ca from Ba2; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class H, $103,988,000, downgraded to Ca from Ba3; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class J, $94,534,000, downgraded to C from B2; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class K, $75,628,000, downgraded to C from B3; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class L, $37,814,000, downgraded to C from Caa1; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class M, $18,907,000, downgraded to C from Caa1; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class N, $28,360,000, downgraded to C from Caa2; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class O, $18,907,000, downgraded to C from Caa2; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class P, $18,907,000, downgraded to C from Caa3; previously
     placed on review for possible downgrade on 8/11/2009

  -- Class Q, $18,907,000, downgraded to C from Caa3; previously
     placed on review for possible downgrade on 8/11/2009


GSMSC RESECURITIZATION: S&P Downgrades Rating on Class A Certs.
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
A certificates from GSMSC Resecuritization Mortgage Trust 2006-
OA1R, a U.S. residential mortgage-backed securities resecuritized
real estate mortgage investment conduit transaction, to 'B+' from
'AAA'.

The downgrade reflects significant deterioration in the
performance of the loans backing the underlying certificates.
This performance deterioration is so severe that the credit
enhancement for GSMR 2006-OA1R is insufficient to maintain the
previous rating on the re-REMIC class A tranche.

GSMR 2006-OA1R, which closed in March 2006, is secured by two
underlying classes.  The loans securing the underlying
certificates consist predominantly of fixed-rate and option
adjustable-rate Alternative-A mortgage loans.

Class A from GSMR 2006-OA1R is supported by class 1-X (currently
rated 'B+') and class P-1 (currently rated 'NR') from IndyMac INDX
Mortgage Loan Trust 2005-AR14.  The performance of the loans
securing this trust has declined precipitously in recent months.
This pool had experienced losses of 3.27% of the original pool
balance as of the October 2009 distribution date, and it has
approximately 42.11% of the current pool balance in delinquent
loans.  Based on the losses to date, the current pool factor of
0.3738 (37.38%), which represents the outstanding pool balance as
a proportion of the original balance, and the pipeline of
delinquent loans, S&P's current projected loss for this pool is
14.92%, which exceeds the level of credit enhancement available to
cover losses at the 'AAA' scenario level; however, S&P believes
the class can withstand losses associated with its base case
('B+') scenario.

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 Lowered

         GSMSC Resecuritization Mortgage Trust 2006-OA1R

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A          362334LZ5     B+                   AAA


HIGHLAND CREDIT: Moody's Upgrades Ratings on Two Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has upgraded its
ratings on two classes of notes issued by Highland Credit
Opportunities CDO Ltd.:

  -- US$225,000,000 Class A-1 First Priority Floating Rate
     Revolving Notes Due 2013 (current balance of $110,000,000),
     Upgraded to Ba2; previously on July 21, 2009 upgraded to B1;

  -- US$613,000,000 Class A-2 First Priority Floating Rate Term
     Notes Due 2013, Upgraded to Ba2; previously on July 21, 2009
     upgraded to B1.

Highland Credit Opportunities CDO Ltd. is a market value
collateralized loan obligation transaction backed primarily by
bank loans.  According to Moody's, the rating actions taken on the
above classes of notes, originally issued on November 2 2006,
result from the November 16, 2009 amendment to a forbearance
agreement originally entered into on December 14 2008 between the
issuer and the majority of the controlling class following on an
event of default which occurred in November 2008.

Pursuant to the amendment, the issuer agrees not to pay any
dividends to the holders of the issuer's preferred shares if the
market value of the transaction's underlying assets, discounted by
the Moody's advance rates applicable to the Class A Notes as set
forth in the transaction's documentation, is less than 110% of the
outstanding principal amount of the Class A Notes, both
immediately before and after giving pro forma effect to such
dividend distribution.  Prior to the amendment, the scope of the
limitation in the forbearance agreement against dividend
distributions had been unclear.

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


HOLYOKE HOSPITAL: Fitch Affirms 'BB' Rating on Series B Bonds
-------------------------------------------------------------
Fitch Ratings affirms the rating on the $8,300,000 Massachusetts
Health and Educational Facilities Authority, Holyoke Hospital
Issue, series B of 1994 at 'BB'.  The Rating Outlook remains
Negative.  Fitch analyzed the financial statements of Valley
Health System, Inc. and Affiliates, the parent and sole corporate
member of Holyoke Hospital.  Holyoke Hospital is the only
obligated entity for the series B bonds and accounted for 86% of
VHS's operating revenue in fiscal year 2008.

The rating and Negative Outlook reflect operating losses during
the past three years, limited liquidity, considerable debt plans,
and weak service area demographics that result in an unfavorable
payor mix.  The main factor precluding a lower rating at this time
is a modest debt position.

In FY08, VHS lost $1.6 million from operations, equating to an
operating margin of negative 1.2%.  The loss was largely driven by
reduced volumes and lower state reimbursement and contributions
from the Massachusetts's Health Safety Net and Essential Community
Provider Trust Fund programs.  For FY09, un-audited figures
through Aug. 31 indicate a $1.3 million operating loss or a
negative 1% operating margin.  FY09's ECPTF state grant payment to
Holyoke was $2.1 million, compared to $2.25 million a year earlier
and $3.25 million in FY07.  Also, FY08's and FY09's Health Safety
Net payments (reimbursement for care of the uninsured and
underinsured) were $1.1 million compared to $3.2 million in FY07.
The system also continues to experience significant losses on its
physician practices ($1.4 million in FY08 and $1.9 million through
the first 11 months of FY09) and expense pressures related to the
use of temporary staffing for nursing services.  Physician
practice losses were high in FY09 from staff turnover, lower
volumes, use of traveling doctors, and management changes.  The
FY10 budget projects a $0.9 million loss due to new management's
efforts to enhance productivity and monitor costs, and the
addition of several new physicians.  Regardless, Fitch remains
concerned about the subsidies since the hospital's profitability
is not robust enough to provide that level of support over the
long run.

As a result of the operating losses and some unrealized investment
losses, unrestricted cash and investments dropped to $13.6 million
or 39 days cash on hand as of Aug. 31, 2009, from $18.6 million or
55 DCOH in FY07.  With an average age of plant of 17.7 years,
Holyoke's capital needs are significant.  Tentative plans include
the construction of a new emergency department, and although
construction would not begin for about 12 months, the project is
likely to require debt to fund its expected $30 million cost.
Fitch believes that such a debt issuance would lead to a reduction
in VHS' creditworthiness.  Given the area's poor demographics,
Holyoke has a very large concentration of Medicaid (27% of gross
revenue in FY09) which limited operating flexibility.  The Hampden
County (which includes the city of Holyoke) unemployment rate is
typically above the state average and was 10.5% in September 2009,
versus 9.3% statewide.  Furthermore, wealth indicators are well
below state averages, with median household income only 73.5% of
the Massachusetts median.  Fitch views this negatively due to the
resulting high levels of charity care and Medicaid concentration,
exposing the hospital to potential adverse reimbursement changes
or program modifications.  VHS' debt position is modest, with only
$10.7 million of long-term debt outstanding as of Aug. 31, 2009;
bonded debt fully matures by July 1, 2015.  Furthermore, cash to
long-term debt was favorable at 126% and debt service as a
percentage of revenues and debt to capital were very light at 2.7%
and 25%, respectively.

Valley Health System is located in Holyoke, MA (approximately 10
miles north of Springfield, MA) and is comprised of Holyoke
Hospital (151 staffed beds) and other health care entities.  For
the 11 month period ending Aug. 31, 2009, VHS reported total
operating revenues of $127 million.  VHS agrees to provide
quarterly and annual financial information to the trustee and to
bondholders upon request.  However, the documents governing the
rated issue predate Rule 15c2-12 and VHS does not disclose any
financial information to the Municipal Securities Rulemaking
Board's EMMA system, which Fitch views negatively.


INDUSTRIAL DEVELOPMENT: Fitch Affirms 'D' Rating on $35 Mil. Bonds
------------------------------------------------------------------
Fitch Ratings affirms the 'D' rating on the $35 million convention
center facilities excise tax revenue bonds, series 2005 (taxable)
of the Industrial Development Authority of the County of Yavapai,
Arizona (the authority) and simultaneously withdraws it.

Fitch will no longer provide rating coverage of the authority.


JP MORGAN: Fitch Corrects Loss Severity Rating on Class X
---------------------------------------------------------
Fitch made a correction for a press release originally issued
October 5, 2009.  It removes the Loss Severity rating from the
interest-only class X.

Fitch Ratings has downgraded and removed from Rating Watch
Negative 15 classes of J.P. Morgan Chase Commercial Mortgage
Securities Corp., mortgage pass-through certificates.  In
addition, Fitch has assigned Loss Severity ratings.

The downgrades are the result of loss expectations for current
specially serviced loans and reflect Fitch's prospective views
regarding commercial real estate market value and cash flow
declines.  Fitch forecasts potential losses of 9.02% for this
transaction, should market conditions not recover.  The rating
actions are based on losses of 7.3% including 100% of the losses
associated with term defaults and any losses associated with
maturities within the next five years.  Given the significant term
to maturity, Fitch's actions only account for 25% of the losses
associated with maturities beyond five years.  The bonds with
Negative Rating Outlooks indicate classes that may be downgraded
in the future should full potential losses be realized.  Fitch
considers the Outlooks on the super-senior classes to be Stable
due to projected losses having limited impact on credit
enhancement when associated pay down is factored into the
analysis.

Fitch analyzed the transaction and calculated expected losses by
assuming cash flows on each of the properties decline 15% from
year-end 2007 and property values decline 35% from issuance.
These loss estimates were reviewed in more detail for loans
representing 55% of the pool and, in certain cases, revised based
on additional information and/or property characteristics.

Approximately 20.4% of the mortgages are scheduled to mature
within the next five years: 2.9% in 2011, and 17.5% in 2012.  In
2017, 66.8% is scheduled to mature.

Fitch identified 26 Loans of Concern (23%) within the pool, five
of which (1.9%) are specially serviced.  None of the specially
serviced loans are within the transaction's top 15 loans (42.3%).
Of the specially serviced loans, one (1% of the pool) is current.
Five (11.5%) of the transaction's top 15 loans are Fitch Loans of
Concern.

Based on its analysis, Fitch expects 14 of the top 15 loans
(40.9%) to default during the term or at maturity, with loss
severities ranging from approximately 1% to 11%.  The largest
contributors to loss on a pool level basis (by outstanding
balance) are: Overlook III (2.7%), Ten Penn Center (2.2%), and
Sheraton Gunter (1.6%).

Overlook II is a 438,709 square foot office building located in
Atlanta, Georgia.  The sponsor is Parameter Realty Fund III, Inc.
The major tenants at the property consist of Citicorp Credit
Services (14%), Club Management Enterprises, LLC (8%), and Nations
Builders Insurance (6%).  Performance has declined due to
increased expenses and a slight decline in occupancy since
issuance.  The servicer-reported debt-service coverage ratio as of
year-end December 2008 was 1.17 times down from 1.21x and 1.29x at
issuance.  Occupancy as of June 2009 was 76% and 85% including the
master lease.  Fitch's analysis of the loan resulted in a higher
probability of default at maturity based on the high loan to
value.

Ten Penn Center is a 670,857 square foot office property located
in Philadelphia, PA.  The sponsor is Ten Penn Center Associates,
L.P.  The major tenants at the property consist of Janney
Montgomery Scott, LLC (23%) and Sedgwick Claims Management
Services (7.5%).  At issuance, the property was 67% occupied and
projected to have negative cash flow for the first three years of
the loan term.  The property has not reached stabilization
expectations.  As of YE 2008, the servicer reported DSCR was
0.74x, and the Fitch stressed DSCR at issuance was 1.11x.  As of
June 2009, the property was 74.6% occupied down from 85% YE 2007
but up from 67% at issuance.  Fitch's analysis of the loan
resulted in a higher probability of default during the loan term
based on declining performance.

Sheraton Gunter is a full-service, 322 room hotel with meeting
space located in the heart of downtown San Antonio, Texas.  The
loan sponsor is Michael S. Gallegos.  Although 2008 income
increased, property performance continues to decline due to
current market conditions within the hotel sector combined with
increased expenses at the property.  As of YE 2008, the servicer
reported DSCR was 1.15x down from 1.47x YE 2007 and 1.61x at
issuance.  Per the July 2009 STR report, the property is currently
lagging it's competitive set with occupancy at 69% compared to
79%, average daily rate at $105 compared to $116 and revenue per
available room at $71 compared to $92.  Fitch's analysis of the
loan resulted in a higher probability of default during the loan
term based on declining performance.

Fitch downgrades, removes from Rating Watch Negative, and assigns
Loss Severity ratings to these classes:

  -- $197.2 million class A-J to 'BBB/LS4' from 'AAA'; Outlook
     Negative;

  -- $21.9 million class B to 'BBB-/LS5' from 'AA+'; Outlook
     Negative;

  -- $28.2 million class C to 'BB/LS5' from 'AA'; Outlook
     Negative;

  -- $21.9 million class D to 'BB/LS5' from 'AA-'; Outlook
     Negative;

  -- $12.5 million class E to 'BB/LS5' from 'A+'; Outlook
     Negative;

  -- $25 million class F to 'B/LS5' from 'A'; Outlook Negative;

  -- $28.2 million class G to 'B-/LS5' from 'A-'; Outlook
     Negative;

  -- $28.2 million class H to 'B-/LS5' from 'BBB+'; Outlook
     Negative;

  -- $28.2 million class J to 'B-/LS5' from 'BBB'; Outlook
     Negative;

  -- $28.2 million class K to 'B-/LS5' from 'BBB-'; Outlook
     Negative;

  -- $9.4 million class L to 'B-/LS5' from 'BB+'; Outlook
     Negative;

  -- $9.4 million class M to 'B-/LS5' from 'BB'; Outlook Negative;

  -- $6.3 million class N to 'B-/LS5' from 'BB-'; Outlook
     Negative;

  -- $6.3 million class P to 'B-/LS5' from 'B+'; Outlook Negative;

  -- $6.3 million class Q to 'B-/LS5' from 'B'; Outlook Negative.

In addition, Fitch affirms and assigns LS ratings to these
classes:

  -- $11.9 million class A-1 at 'AAA/LS2'; Outlook Stable;
  -- $444.9 million class A-2 at 'AAA/LS2'; Outlook Stable;
  -- $346.2 million class A-3 at 'AAA/LS2'; Outlook Stable;
  -- $601.7 million class A-4 at 'AAA/LS2''; Outlook Stable;
  -- $54.2 million class A-SB at 'AAA/LS2'; Outlook Stable;
  -- $286.5 million class A-1A at 'AAA/LS2'; Outlook Stable;
  -- Interest-only class X at 'AAA'; Outlook Stable;
  -- $250.5 million class A-M at 'AAA'/LS3; Outlook Stable;
  -- $3.1 million class T at 'B-/LS5'; Outlook Negative.

Fitch does not rate the $40.7 million class NR.


JP MORGAN: Fitch Takes Various Rating Actions on 2005 LDP1 Certs.
-----------------------------------------------------------------
Fitch Ratings takes various rating actions on JP Morgan 2005 LDP1,
commercial mortgage pass-through certificates.  A detailed list of
rating actions follows at the end of this press release.

The downgrades are the result of Fitch's loss expectations and its
prospective views regarding cash flow declines and commercial real
estate market values.  Fitch forecasts potential losses of 3.3%
for this transaction, should market conditions not recover.  The
rating actions are based on the full losses of 3.3% as a majority
of loans mature in the next five years.  The bonds with Negative
Outlooks indicate classes that may be downgraded in the future.

To determine potential defaults for each loan, Fitch assumed cash
flow would decline by 10% from year-end 2008.  That is consistent
with the analysis used in its review of recent vintage
transactions whereby cash flow was assumed to decline 15% from
year-end 2007 projected over a three year period.  If the stressed
cash flow would cause the loan to fall below 0.95 times debt
service coverage ratio, Fitch assumed the loan would default
during the term.  To determine losses, Fitch used the above
stressed cash flow and applied a market cap rate by property type,
ranging between 7.5% and 9.5%, to derive a value.  If the loan
balance at default is less than Fitch's derived value, the loan
would realize that amount of loss.  These loss estimates were
reviewed in more detail for loans representing 47.8% of the pool
and, in certain cases, revised based on additional information
and/or property characteristics.  Loss expectations attributed to
loans reviewed in detail represent approximately 42.7% of the
2.6%.

Approximately 79.7% of the mortgages mature within the next five
years: 10.8% in 2009, 16.5% in 2010, 2.4% in 2011 and 9.2% in
2014, and 40.7% in 2015.

Fitch identified 36 Loans of Concern (18.3%) within the pool, 15
of which (12.5%) are specially serviced.  Of the specially
serviced loans, eight (9.8% of the pool) are current.  One of the
Fitch Loans of Concern (7.8%) is within the transaction's top 15
loans.

Fitch's analysis resulted in loss expectations for two of the top
15 loans.  However, none of the top 15 loans are assumed to
default during the loan term, as the stressed cash flow for each
loan exceeds 0.95x DSCR.  Fitch expects that 14 of the top 15
loans may default at maturity based on an insufficient accrued
equity position as calculated in Fitch's refinance test.  However,
Fitch's analysis resulted in losses on two of these loans based on
their derived values, while the remaining 12 loans resulted in no
losses.  A loan would pass the refinance test if the stressed cash
flow would achieve a 1.25x DSCR as calculated based on a 30 year
amortization schedule and an 8% coupon.

The largest contributors to loss are: Water's Edge (2.9%), Harbor
Court (1%), and Indian River Office Building (0.4%),

The Water's Edge loan is secured by a 243,433 square foot single
tenant office property located in Playa Vista, CA built in 2002.
The property continues to be 100% occupied by Electronic Arts Inc.
which develops, publishes, and distributes interactive software
worldwide for video game systems, personal computers, cellular
handsets and the Internet.  Their lease expires in September of
2013.  Given the high leverage of the loan at issuance, Fitch
expects a default and losses at maturity.

The Harbor Court loan is secured by a 57,673 mixed use property
located in Honolulu, Hawaii.  As of year-end 2008, the servicer
reported DSCR was 1.21x and occupancy remained strong at 100%
occupied.  Given the high leverage nature of the loan, Fitch
expects a default at maturity, and the loan to incur losses.

The Indian River Office Building transferred to the special
servicer in July 2009 due to monetary default.  The loan is
secured by a four building medical office complex totaling 94,706
sf built in 1980.  The current borrower purchased the complex in
August 2004.  Three days later three hurricanes struck Vero Beach
and damage to the building was over $6 million.  Building
sustained severe damage and loss of tenants.  Current occupancy is
66% occupied in a market of declining rentals and vacancies of
25%.  The borrower has been supporting the property out of pocket
and has requested a loan modification.  The year-end servicer
reported DSCR was 0.75x.

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

  -- $68.4 million class B to 'AA/LS4' from 'AA+'; Outlook Stable;

  -- $25.2 million class C to 'A/LS4' from 'AA'; Outlook Stable;

  -- $54 million class D to 'A/LS5' from 'A+'; Outlook Stable;

  -- $28.8 million class E to 'BBB/LS5' from 'A-'; Outlook Stable;

  -- $46.8 million class F to 'BB/LS4' from 'BBB+'; Outlook
     Stable;

  -- $28.8 million class G to 'BB/LS5' from 'BBB'; Outlook Stable.

  -- $32.4 million class H to 'B-/LS5' from 'BB+'; Outlook Stable;

  -- $10.8 million class J to 'B-/LS5' from 'BB'; Outlook
     Negative;

  -- $14.4 million class K to 'B-/LS5' from 'B+'; Outlook
     Negative;

  -- $10.8 million class L to 'B-/LS5' from 'B'; Outlook Negative;

  -- $7.2 million class M to 'B-/LS5' from 'B-'; Outlook Negative;

  -- $7.2 million class N to 'B-/LS5' from 'B-'; Outlook Negative;

  -- $10.8 million class P to 'CCC/RR6' from 'CCC/DR1'.

In addition, Fitch affirms, assigns LS ratings and assigns Rating
Outlooks to these classes:

  -- $311.1 million class A-1A at 'AAA/LS1'; Outlook Stable;
  -- $903.8 million class A-2 at 'AAA/LS1'; Outlook Stable;
  -- $157.5 million class A-3 at 'AAA/LS1'; Outlook Stable;
  -- $601.5 million class A-4 at 'AAA/LS1'; Outlook Stable;
  -- $110.7 million class A-SB at 'AAA/LS1'; Outlook Stable;
  -- $94.3 million class A-J at 'AAA/LS3'; Outlook Stable;
  -- $100 million class A-JFL at 'AAA/LS3'; Outlook Stable;
  -- Interest only class X-1 at 'AAA'; Outlook Stable;
  -- Interest only class X-2 at 'AAA'; Outlook Stable;

The class A-1 has been paid off in full.  Fitch does not rate the
$15.9 million class NR.


JP MORGAN: Moody's Reviews Ratings on 25 2007-LPD10 Certificates
----------------------------------------------------------------
Moody's Investors Service placed 25 classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp., Commercial Mortgage Pass-
Through Certificates, Series 2007-LPD10 on review for possible
downgrade due to higher expected losses for the pool resulting
from anticipated losses from specially serviced and highly
leveraged watchlisted loans and interest shortfalls.

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

As of the November 16, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$5.31 billion from $5.33 billion at securitization.  The
Certificates are collateralized by 219 mortgage loans ranging in
size from less than 1% to 4% of the pool, with the top ten loans
representing 32% of the pool.

Currently 17 loans, representing 14% of the pool, are in special
servicing.  The largest specially serviced loan is the Augusta
Mall Loan ($175.0 million -- 3% of the pool), which is a 512,800
square foot regional mall owned by an affiliate of General Growth
Properties, Inc.  The loan is performing but was transferred to
special servicing in April 2009 because it was included in the GGP
bankruptcy filing.

Fifty-eight loans, representing 21% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.  Not all loans on the
watchlist are delinquent or have significant issues.

As of the most recent distribution date, Classes A-JS through the
non-rated class have experienced interest shortfalls totaling
$5.7 million.  Moody's expects that the transaction will continue
to experience interest shortfalls due to special servicing fees
and other trust expenses associated with specially serviced loans
as well as appraisal reductions.  The servicer has recognized
$129.1 million in appraisal reductions from 11 loans.

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

Moody's rating action is:

  -- Class A-M, $359,038,000, currently rated Aaa, on review for
     possible downgrade; previously assigned Aaa on 4/10/2007

  -- Class A-MS, $174,114,000, currently rated Aaa, on review for
     possible downgrade; previously assigned Aaa on 4/10/2007

  -- Class A-J, $200,694,000, currently rated A1, on review for
     possible downgrade; previously downgraded to A1 from Aaa on
     2/10/2009

  -- Class A-JFL, $100,000,000, currently rated A1, on review for
     possible downgrade; previously downgraded to A1 from Aaa on
     2/10/2009

  -- Class A-JS, $145,820,000, currently rated A1, on review for
     possible downgrade; previously downgraded to A1 from Aaa on
     2/10/2009

  -- Class B, $71,808,000, currently rated A3, on review for
     possible downgrade; previously downgraded to A3 from Aa2 on
     2/10/2009

  -- Class B-S, $34,823,000, currently rated A3, on review for
     possible downgrade; previously downgraded to A3 from Aa2 on
     2/10/2009

  -- Class C, $26,928,000, currently rated Baa1, on review for
     possible downgrade; previously downgraded to Baa1 from Aa3 on
     2/10/2009

  -- Class C-S, $13,058,000, currently rated Baa1, on review for
     possible downgrade; previously downgraded to Baa1 from Aa3 on
     2/10/2009

  -- Class D, $49,367,000, currently rated Baa3, on review for
     possible downgrade; previously downgraded to Baa3 from A2 on
     2/10/2009

  -- Class D-S, $23,941,000, currently rated Baa3, on review for
     possible downgrade; previously downgraded to Baa3 from A2 on
     2/10/2009

  -- Class E, $40,392,000, currently rated Ba1, on review for
     possible downgrade; previously downgraded to Ba1 from A3 on
     2/10/2009

  -- Class E-S, $19,588,000, currently rated Ba1, on review for
     possible downgrade; previously downgraded to Ba1 from A3 on
     2/10/2009

  -- Class F, $44,880,000, currently rated Ba2, on review for
     possible downgrade; previously downgraded to Ba2 from Baa1 on
     2/10/2009

  -- Class F-S, $21,764,000, currently rated Ba2, on review for
     possible downgrade; previously downgraded to Ba2 from Baa1on
     2/10/2009

  -- Class G, $44,880,000, currently rated B1, on review for
     possible downgrade; previously downgraded to B1 from Baa2 on
     2/10/2009

  -- Class G-S, $21,764,000, currently rated B1, on review for
     possible downgrade; previously downgraded to B1 from Baa2 on
     2/10/2009

  -- Class H, $40,392,000, currently rated B3, on review for
     possible downgrade; previously downgraded to B3 from Baa3 on
     2/10/2009

  -- Class H-S, $19,588,000, currently rated B3, on review for
     possible downgrade; previously downgraded to B3 from Baa3 on
     2/10/2009

  -- Class J, $19,993,000, currently rated Caa2, on review for
     possible downgrade; previously downgraded to Caa2 from Ba1 on
     2/10/2009

  -- Class K, $19,993,000, currently rated Caa2, on review for
     possible downgrade; previously downgraded to Caa2 from Ba2 on
     2/10/2009

  -- Class L, $13,329,000, currently rated Caa3, on review for
     possible downgrade; previously downgraded to Caa3 from Ba3 on
     2/10/2009

  -- Class M, $6,665,000, currently rated Caa3, on review for
     possible downgrade; previously downgraded to Caa3 from B1 on
     2/10/2009

  -- Class N, $6,664,000, currently rated Caa3, on review for
     possible downgrade; previously downgraded to Caa3 from B2 on
     2/10/2009

  -- Class P, $13,329,000, currently rated Caa3, on review for
     possible downgrade; previously downgraded to Caa3 from B3 on
     2/10/2009


JP MORGAN: Moody's Takes Rating Actions on 2004-CIBC10 Certs.
-------------------------------------------------------------
Moody's Investors Service confirmed the rating of one class,
affirmed seven classes and downgraded fourteen classes of J.P.
Morgan Chase Commercial Mortgage Securities Corp., Commercial
Mortgage Pass-Through Certificates, Series 2004-CIBC10.  The
downgrades are due to higher expected losses for the pool
resulting from anticipated losses from loans in special servicing,
increased credit quality dispersion and concerns about refinancing
risk associated with loans approaching maturity in an adverse
environment.  Five loans, representing 10% of the pool, mature
within the next 24 months and have a Moody's stressed debt service
below 1.00X.

The confirmation and the affirmations are primarily due to key
rating parameters, including Moody's loan to value ratio, stressed
debt service coverage ratio and the Herfindahl Index, remaining
within acceptable ranges.  The transaction also benefits from
increased credit subordination due to loan payoffs and
amortization as well as increased defeasance.  Approximately 19%
of the pool has defeased compared to 3% at last review.

On October 29, 2009, Moody's placed 14 classes on review for
possible downgrade due to higher than expected losses for the pool
due to losses from the loans in special servicing and loans with
near-term refinancing risk.  On November 17, 2009, Moody's placed
the junior Aaa-rated class (Class A-J) on review for possible
downgrade because anticipated losses were higher than originally
projected.  Based on additional information about the specially
serviced loans, Moody's is confirming the rating of Class A-J.
The action concludes the review of the transaction.  The rating
action is the result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.

As of the November 13, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 14%
to $1.69 billion from $1.96 billion at securitization.  The
Certificates are collateralized by 194 mortgage loans ranging in
size from less than 1% to 5% of the pool, with the top ten loans
representing 27% of the pool.  Twenty one loans, including two
loans that previously had underlying ratings, have defeased and
are collateralized with U.S. Government securities.  The defeased
loans represent 19% of the pool.

Fifty loans, representing 20% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.  Not all loans on the
watchlist are delinquent or have significant issues.

The pool has not experienced any losses to date.  Currently, there
are eight loans in special servicing, representing 10% of the
pool.  The largest specially serviced loan is the Continental
Plaza Loan ($88.0 million -- 5% of the pool), which is the largest
loan in the pool.  The loan is secured by three Class A/B+ office
buildings and a single-story retail building, totaling 640,000
square feet, located along Route 4 in Hackensack, New Jersey.  The
loan was transferred to special servicing April 2009 for imminent
default when the borrower indicated that would not be able to pay
off the loan balance by the September 2009 maturity date.  The
properties were 74% occupied as of September 2009 compared to 81%
at last review and 91% at securitization.

The second largest specially serviced loan is the ABB Building
Loan ($50.0 million -- 3% of the pool); the pool's second largest
loan.  The loan is secured by a build-to-suit 469,000 square foot
Class A office building in the Westchase sub-market of Houston,
Texas.  The loan was transferred to special servicing in October
2009 for imminent default.  The property is 100% occupied by ABB,
Inc., whose lease expires in December 2009.  ABB plans to vacate
the premise at its lease expiration.  The loan matures in November
2009.

For the remaining six specially serviced loans, three loans are
real estate owned or in the process of foreclosure, one loan is
60+ days delinquent and two loans are 90+ days delinquent.
Moody's estimates an aggregate $47.2 million loss (29% loss
severity on average) from the specially serviced loans.

Moody's was provided with full-year 2008 and partial-year 2009
operating results for 98% and 58% of the pool, respectively.
Moody's weighted average LTV ratio, excluding the specially
serviced loans, is 93%, essentially the same as at last review.
Although the overall pool LTV has remained stable, the pool has
experienced increased credit quality dispersion.  Based on Moody's
analysis, 37% of the pool has a LTV ratio in excess of 100%
compared to 32% at last review.  Additionally, 8% of the pool has
a LTV ratio in excess of 120% compared to 2% at last review.

Moody's stressed DSCR is 1.34X compared to 1.45X at last review.
Moody's stressed DSCR is based on Moody's net cash flow and a
9.25% stressed rate applied to the loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple-notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool, excluding defeased loans, has a Herf of 68 compared to 87 at
last review.

The three largest performing loans represent 6% of the pool.  The
largest conduit loan is Walden Pond at East Moriches Loan
($36.4 million -- 2% of the pool), which is secured by a 324-unit,
luxury garden-style apartment complex constructed in 2004 in East
Moriches (Suffolk County), New York.  The property was 94%
occupied as of March 2009 compared to 96% at last review and 83%
at securitization.  The property has achieved a stabilized
occupancy and the loan is benefiting from amortization.  The loan
has amortized 4% since last review.  Moody's LTV and stressed DSCR
are 103% and 0.89X, respectively, compared to 117% and 0.79X at
last review.

The second largest performing loan is the Sherman Town Center Loan
($36.3 million -- 2% of the pool), which is secured by a 285,000
square foot anchored retailing shopping center located in Sherman,
Texas.  The center is part of a larger 678,000 square foot retail
center.  The center is anchored by Target, Home Depot and Wal-
Mart.  The collateral's main tenants are Hobby Land (23% of NRA;
lease expiration 4/2019), Cinemark Theaters (14% of NRA; lease
expiration 12/2023) and Ross Dress for Less (11% of NRA; lease
expiration 1/2015).  The in-line mall shops have maintained a 100%
occupancy rate since securitization.  Although occupancy has been
stable, performance has been impacted by increased operating
expenses which have increased by approximately 17% since 2005.
The increased expenses have been partially offset by amortization.
The loan has amortized 5% since last review.  Moody's LTV and
stressed DSCR are 99% and 0.98X, respectively, compared to 103%
and 0.92X at last review.

The third largest performing loan is the Fountain Square Loan
($34.8 million -- 2% of the pool), which is secured by three
office buildings in Boca Raton, Florida.  The buildings total
242,100 square feet.  The properties were 80% occupied as of March
2009, the same as at last review.  Performance has been impacted
by increased operating expenses.  Moody's LTV and stressed DSCR is
110% and 0.88X, respectively, compared to 103% and 0.80X at last
review.

Moody's rating action is:

  -- Class A-3, $180,191,853, affirmed at Aaa; previously on
     12/07/2004 assigned at Aaa

  -- Class A-4, $180,896,000, affirmed at Aaa; previously on
     12/07/2004 assigned at Aaa

  -- Class A-5, $174,874,000, affirmed at Aaa; previously on
     12/07/2004 assigned at Aaa

  -- Class A-6, $384,868,000, affirmed at Aaa; previously on
     12/07/2004 assigned at Aaa

  -- Class A-1A, $380,953,235, affirmed at Aaa; previously on
     12/07/2004 assigned at Aaa

  -- Class X-1, Notional, affirmed at Aaa; previously on
     12/07/2004 assigned at Aaa

  -- Class X-2, Notional, affirmed at Aaa; previously on
     12/07/2004 assigned at Aaa

  -- Class A-J, $117,739,000, confirmed at Aaa; previously on
     11/17/2009 Aaa Placed Under Review for Possible Downgrade

  -- Class B, $61,323,000, downgraded toAa3; previously on
     10/29/2009 Aa2 Placed Under Review for Possible Downgrade

  -- Class C, $17,170,000, downgraded to A1; previously on
     10/29/2009 Aa3 Placed Under Review for Possible Downgrade

  -- Class D, $14,717,000, downgraded to A2; previously on
     10/29/2009 A1 Placed Under Review for Possible Downgrade

  -- Class E, $17,171,000, downgraded to A3; previously on
     10/29/2009 A2 Placed Under Review for Possible Downgrade

  -- Class F, $22,076,000, downgraded to Baa2; previously on
     10/29/2009 A3 Placed Under Review for Possible Downgrade

  -- Class G, $26,982,000, downgraded to Ba1; previously on
     10/29/2009 Baa1 Placed Under Review for Possible Downgrade

  -- Class H, $22,076,000, downgraded to Ba3; previously on
     10/29/2009 Baa2 Placed Under Review for Possible Downgrade;

  -- Class J, $26,982,000, downgraded to B3; previously on
     10/29/2009 Baa3 Placed Under Review for Possible Downgrade

  -- Class K, $4,905,000, downgraded to Caa1; previously on
     10/29/2009 Ba1 Placed Under Review for Possible Downgrade

  -- Class L, $7,359,000, downgraded to Caa3; previously on
     10/29/2009 Ba2 Placed Under Review for Possible Downgrade

  -- Class M, $12,265,000, downgraded to Ca; previously on
     10/29/2009 Ba3 Placed Under Review for Possible Downgrade

  -- Class N, $4,905,000, downgraded to C; previously on
     10/29/2009 B1 Placed Under Review for Possible Downgrade

  -- Class P, $7,359,000, downgraded to C; previously on
     10/29/2009 B2 Placed Under Review for Possible Downgrade

  -- Class Q, $2,453,000, downgraded to C; previously on
     10/29/2009 B Placed Under Review for Possible Downgrade


JP MORGAN: Fitch Takes Rating Actions on 2005-CIBC12 Certificates
-----------------------------------------------------------------
Fitch Ratings has taken various rating actions on J.P. Morgan
Chase Commercial Mortgage Securities Corp., Series 2005-CIBC12,
commercial mortgage pass-through certificates.  A detailed list of
rating actions follows at the end of this press release.

The downgrades are the result of Fitch's loss expectations and its
prospective views regarding cash flow declines and commercial real
estate market values.  Fitch forecasts potential losses of 5.2%
for this transaction, should market conditions not recover.  The
rating actions are based on the full losses of 5.2% as a majority
of loans mature in the next five years.  The bonds with Negative
Outlooks indicate classes that may be downgraded in the future.

To determine potential defaults for each loan, Fitch assumed cash
flow would decline by 10% from year-end 2008.  That is consistent
with the analysis used in its review of recent vintage
transactions whereby cash flow was assumed to decline 15% from
year-end 2007 projected over a three-year period.  If the stressed
cash flow would cause the loan to fall below 0.95 times (x) debt
service coverage ratio, Fitch assumed the loan would default
during the term.  To determine losses, Fitch used the above
stressed cash flow and applied a market cap rate by property type,
ranging between 7.5% and 10%, to derive a value.  If the loan
balance at default is less than Fitch's derived value, the loan
would realize that amount of loss.  These loss estimates were
reviewed in more detail for loans representing 49.6% of the pool
and, in certain cases, revised based on additional information
and/or property characteristics.

Approximately 89% of the mortgages mature within the next five
years: 8.3% in 2010, 9.3% in 2011 and 7.8% in 2012, 4.7% in 2013,
1.2% in 2014 and 57.7% in 2015.

Fitch identified 48 Loans of Concern (19.5%) within the pool, 13
of which (5.5%) are specially serviced.  One of the Fitch Loans of
Concern (2.1%) is within the transaction's top 15 loans.

Fitch expects that 14 of the top 15 loans may default at maturity
based on an insufficient accrued equity position as calculated in
Fitch's refinance test.  While defaults are expected, additional
losses are not anticipated based on derived values being higher
than the current loan amounts.  A loan would pass the refinance
test if the stressed cash flow would achieve a 1.25x DSCR as
calculated based on a 30-year amortization schedule and an 8%
coupon.  One loan within the top 15 is expected to incur a loss at
maturity, Fort Steuben Mall.

The largest contributors to loss are: Fort Steuben Mall (2.1%),
Phillips Ranch Industrial Center (0.9%), International Plaza
(0.7%), and LXP - The Dial Corporation (0.7%).

The Fort Steuben Mall loan is secured by 685,585 square feet of an
813,165 sf regional mall in Steubenville, OH, approximately 35
miles west of Pittsburgh, PA.  Major tenants at the center include
Wal-Mart (30.6% of net rentable area), Sears (17.7%), J.C.  Penney
(8.1%), and Dick's Sporting Goods (7.5%).  The mall has
experienced a steady decline in performance over the last two
years, mainly due to an increase in vacancy and the negative
effects the weak economy has had on the subject's local market.
The DSCR and occupancy as of first quarter 2009 were 1.02x and
86%, compared with 1.16x and 90% at year-end 2008 and 1.39x and
86% at issuance.  Fitch expects the loan will default at maturity,
and losses are likely.

The largest specially serviced loan (0.9%) is a 124,894 square
foot retail property in Pomona, California.  The loan transferred
to special servicing in March 2009 after a significant increase in
vacancy limited the borrower's ability to pay the debt service
obligations.  The property remains 35% occupied and based on an
updated appraisal, losses are expected.

The second largest specially serviced loan (0.7%) is a 34,938 sf
retail property in St. Thomas, Virgin Islands.  The asset has been
real estate owned since August 2008.  The property has suffered
from a deteriorating retail environment stemming from reduced
vacation travel.  The most recent appraisal value indicates losses
upon disposition.

The third largest specially serviced loan (0.7%) is secured by a
129,689 sf office building located in Scottsdale, AZ.  The loan
transferred to special servicing in November 2008 when its sole
tenant notified the borrower that it intended to vacate at the end
of its lease in December 2008.  The property is currently 100%
vacant.  The property is in foreclosure.  Updated appraisal
valuation indicates losses are likely.

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

  -- $162.5 million Class A-J to 'AA/LS5' from 'AAA'; Outlook
     Stable;

  -- $43.3 million Class B to 'BBB/LS5' from 'AA-'; Outlook
     Stable;

  -- $19 million Class C to 'BBB-/LS5' from 'A'; Outlook Stable;

  -- $32.5 million Class D to 'BB/LS5' from 'BBB'; Outlook Stable;

  -- $27.1 million Class E to 'BB/LS5' from 'BBB-'; Outlook
     Stable;

  -- $24.4 million Class F to 'B/LS5' from 'BBB-'; Outlook Stable;

  -- $24.4 million Class G to 'B-/LS5' from 'BB'; Outlook
     Negative.

In addition, Fitch affirms and removes this class from Rating
Watch Negative, and assigns an LS Rating and Outlook:

  -- $29.8 million Class H at 'B-/LS5'; Outlook Negative.

In addition, Fitch affirms this non-pooled class and revises the
Outlook as indicated:

  -- $50 million Class UHP at 'B-/LS5'; Outlook to Negative from
     Stable.

Fitch also affirms these classes and assigns LS ratings,
Outlooks and Recovery Ratings as indicated:

  -- $131.4 million Class A-2 at 'AAA/LS1'; Outlook Stable;
  -- $163.6 million Class A-3A1 at 'AAA/LS1'; Outlook Stable;
  -- $122.9 million Class A-3A2 at 'AAA/LS1'; Outlook Stable;
  -- $200 million Class A-3B at 'AAA/LS1'; Outlook Stable;
  -- $649.3 million Class A-4 at 'AAA/LS1'; Outlook Stable;
  -- $137.4 million Class A-SB at 'AAA/LS1'; Outlook Stable;
  -- $216.7 million Class A-M at 'AAA/LS3'; Outlook Stable;
  -- Interest only Class X-1 at 'AAA'; Outlook Stable;
  -- Interest only Class X-2 at 'AAA'; Outlook Stable;
  -- $8.1 million Class J at 'CC/RR3';
  -- $8.1 million Class K at 'C/RR6';
  -- $8.1 million Class L at 'C/RR6';
  -- $5.4 million Class M at 'C/RR6';
  -- $8.1 million Class N at 'C/RR6';
  -- $5.4 million Class P at 'C/RR6'.

Fitch does not rate the $26.8 million NR class.  Class A-1 has
paid in full.


JPMORGAN CHASE: S&P Downgrades Ratings on Two 2001-A Certificates
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on two
classes of commercial mortgage pass-through certificates from
JPMorgan Chase Commercial Mortgage Securities Corp.'s series 2001-
A.  S&P placed these ratings and the ratings on two additional
classes on CreditWatch with negative implications.  The
transaction collateral consists of seven commercial real estate
assets, including four assets with the special servicer, Capmark
Finance Inc.

The CreditWatch placements reflect liquidity considerations that
are associated with three of the four specially serviced assets,
which constitute 64% of the pool, including the largest loan in
the pool.  The downgrades of classes F and G reflect interest
shortfalls to these classes resulting primarily from the lack of
advancing of trust expenses related to one real estate owned
asset, as well as appraisal subordinate entitlement reductions for
two other specially serviced assets.  The lack of advancing on the
REO asset follows a nonrecoverable advance declaration by the
master servicer, also Capmark.  S&P anticipate that the trust may
experience additional shortfalls related to trust expenses, which
include property operating expenses, property taxes, and insurance
payments.  These shortfalls could potentially affect classes D and
E.  Standard & Poor's will resolve and/or update the CreditWatch
placements after S&P has further dialogue with Capmark and perform
a full analysis of the waterfall.  Classes F and G have shorted
for two and three months, respectively.  If S&P deem that the
classes will continue to experience shortfalls on an ongoing
basis, S&P will downgrade the classes again, potentially to 'D'.
Details concerning the four specially serviced assets are:

The Crossing Center Portfolio loan ($6.3 million, 12.7%) was
transferred to the special servicer on May 22, 2008, due to
maturity default and is now REO.  The portfolio consists of two
suburban office buildings totaling 160,775 sq. ft in Norcross, Ga.
The master servicer declared future advances nonrecoverable on
Sept. 16, 2009.  Ongoing interest shortfalls due to the lack of
interest advances will be approximately $45,000.  There are
considerable trust expenses that may also affect the trust, such
as insurance, property taxes, and general operating expenses.  As
of the Nov. 16, 2009, remittance report, $1.39 million of total
advances were outstanding for this asset.

The Southgate USA Loan ($21.4 million, 42.8%) is the largest loan
in the pool and is secured by a 795,517-sq.-ft. anchored retail
center in Maple Heights, Ohio.  The loan was transferred to
Capmark in December 2008 due to maturity default after the special
servicer had extended the maturity date from December 2007.  An
ARA totaling $2.69 million is in effect for this loan.  The
related ASER amount could total approximately $19,000 on a monthly
basis if the property does not have sufficient cash flow.   The 33
Riverside Drive loan ($4.1 million, 8.2%) is secured by a two-
story, 52,927-sq.-ft. class B office building constructed in 1988
in Pembroke, Mass.  The loan was transferred to special servicing
due to imminent default.  An ARA totaling $1.23 million is in
effect for this asset.  The ASER amount could total approximately
$8,000 on a monthly basis if the property does not have sufficient
cash flow.   The second-largest loan, the County Fair Mall loan
($10.9 million), was transferred to the special servicer due to a
pending maturity default on Oct. 30, 2009.  The maturity date for
this loan is Jan. 1, 2010, and the borrower has indicated that it
will not be able to pay off the loan at maturity.  As of the six
months ended June 30, 2009, the debt service coverage was 1.42x
and occupancy was 77%.

        Ratings Lowered And Placed On Creditwatch Negative

        JPMorgan Chase Commercial Mortgage Securities Corp.
    Commercial mortgage pass-through certificates series 2001-A

                     Rating
                     ------
     Class    To               From    Credit enhancement (%)
     -----    --               ----    ----------------------
     F        CCC/Watch Neg    BB                       33.31
     G        CCC-/Watch Neg   B-                       17.64

              Ratings Placed On Creditwatch Negative

        JPMorgan Chase Commercial Mortgage Securities Corp.
   Commercial mortgage pass-through certificates series 2001-A

                     Rating
                     ------
     Class    To               From    Credit enhancement (%)
     -----    --               ----    ----------------------
     D        BBB/Watch Neg    BBB                      50.41
     E        BBB-/Watch Neg   BBB-                     43.57


KIMBERLITE CDO: S&P Downgrades Ratings on Hybrid CDO CMBS Deal
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on
Kimberlite CDO I Ltd., a hybrid collateralized debt obligation of
commercial mortgage-backed securities transaction.  The ratings
remain on CreditWatch with negative implications, where they were
placed on Aug. 25, 2009.

The rating actions are consistent with S&P's criteria for CDO
transactions that have triggered an event of default and which may
be subject to acceleration or liquidation.

According to the trustee for the transaction, Kimberlite CDO I
triggered an EOD on Oct. 27, 2009, under section 5.1.(d) of its
indenture when the ratio of (1) the "par value coverage amount"
less the "total par value haircut amount" to (2) an amount equal
to the sum of the super-senior notional amount and the class A
aggregate outstanding amount was less than 100%.  Because, based
on S&P's understanding of the transaction, the super-senior
counterparty can now direct the sale or liquidation of the
collateral, S&P applied its applicable criteria and lowered the
ratings accordingly.

The ratings remain on CreditWatch negative as S&P finalizes its
analysis of the impact of the EOD, if any, on the existing
liquidity and swap agreements for this transaction.

      Ratings Lowered And Remaining On Creditwatch Negative

                      Kimberlite CDO I Ltd.

                                  Rating
                                  ------
       Tranche             To               From
       -------             --               ----
       Super senior        BB/Watch Neg     AAA/Watch Neg
       A                   CCC/Watch Neg    AAA/Watch Neg
       B                   CCC/Watch Neg    AA/Watch Neg
       C                   CCC/Watch Neg    A+/Watch Neg
       D                   CCC/Watch Neg    A/Watch Neg
       E                   CCC/Watch Neg    A-/Watch Neg
       F                   CCC/Watch Neg    BBB+/Watch Neg
       G                   CCC/Watch Neg    BBB-/Watch Neg
       H                   CCC/Watch Neg    BB/Watch Neg
       Combo notes         CCC/Watch Neg    BBB/Watch Neg

  Transaction Information
  -----------------------
Issuer:                 Kimberlite CDO I Ltd.
Co-issuer:              Kimberlite CDO I LLC
Collateral Manager:     BlackRock Financial Management Inc.
Transaction type:       Hybrid CDO of CMBS


LB-UBS COMMERCIAL: S&P Downgrades Ratings on 20 2007-C6 Securities
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 20
classes of commercial mortgage-backed securities from LB-UBS
Commercial Mortgage Trust 2007-C6 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 these classes from CreditWatch negative.

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 the credit support erosion S&P anticipate
will occur upon the eventual resolution of four specially serviced
loans, as well as S&P's analysis of one loan that S&P consider 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 1.20x and a loan-to-value ratio
of 125.6%.  S&P further stressed the loans' cash flows under its
'AAA' scenario to yield a weighted average DSC of 0.72x and an LTV
of 180.3%.  The implied defaults and loss severity under the 'AAA'
scenario were 96.6% and 49.4%, respectively.  The weighted average
DSC and LTV calculations exclude four specially serviced loans
($32.8 million; 1.1%) and one loan that S&P deemed to be credit-
impaired ($32.0 million; 1.1%).  S&P separately estimated losses
for the specially serviced and credit-impaired loans, which S&P
included in its implied default and loss severity figures.

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

                      Credit Considerations

As of the Oct. 19, 2009, remittance date, eight assets
($82.4 million; 2.8%) in the pool were with the special servicer,
Midland Loan Services Inc.   The payment status of the assets is:
three are 90-plus days delinquent ($19.3 million, 0.7%), three are
60 days delinquent ($36.9 million, 1.2%), one is 30 days
delinquent ($23.4 million, 0.8%), and one is less than 30 days
delinquent ($2.6 million, 0.1%).  Six of the specially serviced
assets have appraisal reduction amounts in effect totaling
$17.0 million.  One specially serviced loan ($9.0 million; 0.3%)
will be returned to the master servicer, and discussions regarding
modifications are in progress for another specially serviced loan
($2.7 million; 0.1%).  S&P estimated losses on four of the
specially serviced assets ($32.8 million; 1.1%), and the losses
ranged from 22% to 74%.

In addition to the specially serviced assets, S&P deemed one loan,
the Irish Hills Plaza loan ($32.0 million; 1.1%), to be credit-
impaired.  The loan is secured by the fee interest in a 139,856-
sq.-ft. anchored retail center built in 2007 in San Luis Obispo,
Calif.  In S&P's view, the loan is at increased risk of default
over its term due to low occupancy and DSC resulting from tenant
vacancies.  The loan appears on the master servicer's watchlist
due to bankrupt tenants.  Circuit City (31,406 sq. ft., 22% of net
rentable area {NRA}) filed for bankruptcy and vacated the property
in February 2009.  Furthermore, Linens 'n Things (28,000 sq. ft.,
20% of NRA) filed for bankruptcy and vacated in December 2008.
The borrower has been working with TJ Maxx to lease this space.
In addition, Old Navy's lease (15,130 sq. ft.; 10.8%) contains co-
tenancy language that gives Old Navy the ability to terminate the
lease.  For year-end 2008, the DSC and occupancy were 1.10x and
100%, respectively.  Excluding lease payments from Circuit City
and Linens 'n Things, S&P estimate a DSC of 0.29x based on 57%
occupancy, according to the Oct. 1, 2009, rent roll.  The payment
status of this loan is current.

                       Transaction Summary

As of the October 2009 remittance report, the aggregate trust
balance was $2.98 billion (181 loans), which is unchanged since
issuance.  Wachovia Bank N.A., the master servicer, reported
financial information for 99% of the pool.  Ninety-nine percent of
the financial information was either full-year 2008 or partial-
year 2009 data.  S&P calculated a weighted average DSC of 1.22x
for the pool based on the master servicer's reported figures.
S&P's adjusted DSC and LTV were 1.20x and 125.6%, respectively.
Standard & Poor's adjusted DSC and LTV calculations exclude four
specially serviced loans ($32.8 million; 1.1%) and one loan that
S&P deem to be credit-impaired ($32.0 million; 1.1%).  S&P
separately estimated losses for these loans in S&P's analysis.
Year-end 2008 data was available for four of the five loans, from
which S&P calculated a weighted average DSC of 1.0x.  The
transaction has not experienced any principal losses to date.
Forty-three loans are on the servicer's watchlist ($1.3 billion;
42.6%), including five of the top 10 loans, which S&P discuss
below.  Thirteen loans ($357.9 million, 12.0%) have a reported DSC
between 1.0x and 1.1x, and 17 loans ($261.1 million, 8.8%) have a
reported DSC of less than 1.0x.

                     Summary Of Top 10 Loans

The top 10 loans have an aggregate outstanding balance of
$1.7 billion (58.4%).  Using servicer-reported information, S&P
calculated a weighted average DSC of 1.20x.  S&P's adjusted DSC
and LTV figures for the top 10 loans were 1.16x and 127.6%,
respectively.  Details of the five top 10 loans that appear on the
master servicer's watchlist are:

The PECO Portfolio loan, the largest loan in the pool, has a
$323.9 million (10.9% of the pool balance) trust and whole-loan
balance.  The loan is secured by 39 cross-collateralized and
cross-defaulted notes encumbering the fee interests in 37 retail
properties and the leasehold interests in two retail properties.
The subject centers total 4,250,370 sq. ft. and are primarily
anchored by national retailers, including Tops, Bi-Lo, Food Lion,
Publix, Staples, and Dollar Tree.  Built between 1960 and 2004,
the properties are dispersed throughout 13 states, with major
concentrations in New York (representing 28.0% of total portfolio
NRA), North Carolina (13.3% of NRA), and Florida (11.6% of NRA).
No other state represents more than 8.0% of total NRA.  The loan
was placed on the master servicer's watchlist due to the
bankruptcy filings of Goody's, a department store chain selling
clothing and a tenant at three properties, and Bi-Lo, a grocery
store chain and tenant at seven properties.  Goody's has rejected
all three leases as part of the bankruptcy proceeding, and Bi-Lo
will reject or affirm its leases in a hearing scheduled for March
2010.  The occupancy and DSC for year-end 2008 were 94% and 1.36x,
respectively.  Considering the 10 spaces affected by the two
tenant bankruptcies, S&P estimate a DSC of 1.28x.

The fifth-, sixth-, and eighth-largest loans were originally added
to the watchlist due to the respective borrowers' failure to repay
their mezzanine loans at their maturity dates.  Details of these
loans are:

The One Sansome Street loan, the fifth-largest loan in the pool,
has a $139.6 million (2.5%) trust and whole-loan balance.  The
loan is secured by a 562,010-sq.-ft., 41-story class A office
building built in 1983 in downtown San Francisco.  The property
financing also includes three mezzanine loans that are held
outside of the trust.  One of the mezzanine debtholders is in the
process of pursuing its rights for a collateral enforcement
action, which could include a foreclosure on its interests.  The
other two loans experienced maturity defaults, and the maturity
dates were extended to be coterminous with the in-trust debt.  The
occupancy and in-trust DSC for year-end 2008 were 94% and 1.37x,
respectively.  The property was 92% occupied as of the July 31,
2009, rent roll.  Based on this rent roll and other leasing
updates, S&P estimate an in-trust DSC of 1.13x.

The 100 Wall Street loan, the 6th-largest loan in the pool, has a
$117.4 million (3.9%) trust and whole-loan balance.  The loan is
secured by a 482,404-sq.-ft., 29-story, class A New York City
office building built in 1969 and renovated in 2004.  The property
financing also includes three mezzanine loans that are held
outside of the trust.  The borrower for two mezzanine loans failed
to repay the loans at maturity, and the maturity dates were
extended to be coterminous with the in-trust debt.  The occupancy
and in-trust DSC for year-end 2008 were 85% and 1.01x,
respectively.

The Greensboro Park loan, the eighth-largest loan in the pool, has
a $108.9 million (3.7%) trust and whole-loan balance.  The loan is
secured by two class A office buildings totaling 485,047 sq. ft.
built in 1980 and 1987 in McLean, Va.  The property financing also
includes three mezzanine loans that are held outside of the trust.
The borrower for two mezzanine loans failed to repay the loans at
maturity, and the maturity dates were extended to be coterminous
with the in-trust debt.  The occupancy and in-trust DSC for year-
end 2008 were 91% and 1.15x, respectively.

The remaining top 10 loan that appears on the watchlist, the
McCandless Tower loan, is the seventh-largest loan in the pool and
has a $116.4 million (3.9%) trust and whole-loan balance.  The
loan is secured by twin 11-story, class A office buildings located
in Santa Clara, Calif., totaling 418,003 sq. ft. Constructed in
1986 and 1998, the properties together consist of 410,344 sq. ft.
of office space and 7,659 sq. ft. of retail space and offer a 711-
space underground parking facility.  The loan appears on the
watchlist due to a low DSC.  The DSC and occupancy for year-end
2008 were 1.02x and 88.7%, respectively.

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

      Ratings Lowered And Removed From Creditwatch Negative

             LB-UBS Commercial Mortgage Trust 2007-C6
   Commercial mortgage pass-through certificates series 2007-C6

                    Rating
                    ------
       Class      To      From       Credit enhancement (%)
       -----      --      ----       ----------------------
       A-4        A-      AAA/Watch Neg               30.04
       A-1A       A-      AAA/Watch Neg               30.04
       A-M        BBB-    AAA/Watch Neg               20.02
       A-MFL      BBB-    AAA/Watch Neg               20.02
       A-J        BB      AAA/Watch Neg               14.77
       B          BB-     AA+/Watch Neg               13.64
       C          B+      AA/Watch Neg                12.39
       D          B+      AA-/Watch Neg               11.26
       E          B+      A+/Watch Neg                10.26
       F          B+      A/Watch Neg                  9.26
       G          B       A-/Watch Neg                 8.13
       H          B       BBB+/Watch Neg               6.88
       J          B       BBB/Watch Neg                5.51
       K          B-      BBB-/Watch Neg               4.51
       L          B-      BB+/Watch Neg                3.00
       M          B-      BB/Watch Neg                 2.50
       N          CCC+    BB-/Watch Neg                2.13
       P          CCC     B+/Watch Neg                 2.00
       Q          CCC     B/Watch Neg                  1.75
       S          CCC-    B-/Watch Neg                 1.50

      Rating Affirmed And Removed From Creditwatch Negative

             LB-UBS Commercial Mortgage Trust 2007-C6
   Commercial mortgage pass-through certificates series 2007-C6

                  Rating
                  ------
     Class      To      From           Credit enhancement (%)
     -----      --      ----           ----------------------
     A-AB       AAA     AAA/Watch Neg                   30.04

                        Ratings Affirmed

             LB-UBS Commercial Mortgage Trust 2007-C6
   Commercial mortgage pass-through certificates series 2007-C6

            Class     Rating   Credit enhancement (%)
            -----     ------   ----------------------
            A-1       AAA                       30.04
            A-2       AAA                       30.04
            A-2FL     AAA                       30.04
            A-3       AAA                       30.04
            X         AAA                         N/A

                      N/A - Not applicable.


MAGI FUNDING: Moody's Takes Rating Actions on Various Classes
-------------------------------------------------------------
Moody's Investors Service announced these rating actions on notes
issued by Magi Funding I plc.:

  -- EUR212,600,000 Class A Floating Rate Notes due 2021,
     Downgraded to Aa2; previously on February 23, 2006 Assigned
     Aaa;

  -- EUR5,000,000 Class L Combination Notes due 2021, Downgraded
     to Aa2; previously on February 23, 2006 Assigned Aaa;

  -- EUR33,800,000 Class B Deferrable Floating Rate Notes due
     2021, Confirmed at Ba3; previously on March 19, 2009
     Downgraded to Ba3 and Placed Under Review for Possible
     Downgrade;

  -- EUR7,500,000 Class C Deferrable Floating Rate Notes due
     2021, Confirmed at B3; previously on March 19, 2009
     Downgraded to B3 and Placed Under Review for Possible
     Downgrade;

  -- EUR11,760,000 Subordinated Notes II A due 2021, Confirmed at
     Caa3; previously on March 19, 2009 Downgraded to Caa3 and
     Placed Under Review for Possible Downgrade.

This transaction is a managed cash leveraged loan collateralized
loan obligation with exposure to predominantly European senior
secured loans.

The rating actions reflect Moody's revised assumptions with
respect to default probability and the calculation of the
diversity score as described in the press release dated
February 4, 2009, titled "Moody's updates key assumptions for
rating CLOs."  These revised assumptions have been applied to all
corporate credits in the underlying portfolio, the revised
assumptions for the treatment of ratings on "Review for Possible
Downgrade", "Review for Possible Upgrade", or with a "Negative
Outlook" being applied to those corporate credits that are
publicly rated.

Moody's also notes that a material proportion of the collateral
pool consists of debt obligations whose credit quality has been
assessed through Moody's credit estimates.  As credit estimates do
not carry credit indicators such as ratings reviews and outlooks,
a stress of a quarter notch-equivalent assumed downgrade was
applied to each of these estimates.

According to Moody's, the rating actions taken on the notes are
also a result of credit deterioration of the underlying portfolio.
This is observed through a decline in the average credit rating as
measured through the portfolio weighted average rating factor
'WARF' (currently 2778), an increase in the amount of defaulted
securities (currently 2.3% of the portfolio), an increase in the
proportion of securities from issuers rated Caa/CCC or lower
(currently 13.0% of the portfolio), and a failure of all par value
tests (including a deterioration of the Class A par value test
ratio from 131.18% in February 2009 to 127.62% in October 2009).
These measures were taken from the recent trustee report dated 5
October 2009.  Moody's also performed a number of sensitivity
analyses, including consideration of a further decline in
portfolio WARF quality.  Due to the impact of all the
aforementioned stresses, key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, and
weighted average recovery rate, may be different from trustee's
reported numbers.


MARATHON CLO: Moody's Takes Rating Actions on Various Classes
-------------------------------------------------------------
Moody's Investors Service announced that it has both upgraded and
downgraded the ratings of notes issued by Marathon CLO I Ltd.:

  -- US$221,000,000 Class A-1 Floating Rate Senior Secured Notes
     Due 2019 (Current Balance $33,357,306), Upgraded to Aaa;
     previously on June 18, 2009 Downgraded to A1;

  -- US$30,000,000 Class A-2 Floating Rate Senior Secured
     Revolving Notes Due 2019 (Current Balance $4,528,141),
     Upgraded to Aaa; previously on June 18, 2009 Downgraded to
     A1;

  -- US$8,100,000 Class B Floating Rate Senior Secured Notes Due
     2019, Upgraded to Aa2; previously on June 18, 2009 Downgraded
     to A3.

  -- US$19,200,000 Class C Floating Rate Senior Subordinate
     Deferrable Interest Notes Due 2019, Upgraded to Baa3;
     previously on June 18, 2009 Confirmed at Ba1.

  -- US$19,000,000 Class D Floating Rate Subordinate Deferrable
     Interest Notes Due 2019, Downgraded to B2; previously on
     November 10, 2009 B1 Placed Under Review for Possible
     Downgrade;

  -- US$8,000,000 Class E Floating Rate Junior Subordinate
     Deferrable Interest Notes Due 2019 (current balance
     $2,340,671), Downgraded to Ca; previously on November 10,
     2009 Caa3 Placed Under Review for Possible Downgrade.

According to Moody's, the upgrade action of the Class A-1, A-2, B,
and C notes primarily reflects the significant improvement in
overcollateralization for the notes following the recent sales by
the issuer of $217.5 million in par amount of collateral.
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 at a weighted average price of 90.7%.  The
sales, primarily characterized as sales of Credit Risk Obligations
as defined by the indenture dated April 28, 2005, with a small
number of "discretionary" and "credit improved" sales, comprised
approximately two-thirds of the outstanding portfolio par in
September.

The sale 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.  Specifically the Class A-1 and
Class A-2 notes were reduced by 85%, significantly improving the
overcollateralization coverage for the Class A, B, and C Notes.
The pro forma Class A/B OC ratio after the asset sales (based on
an interim report provided by the manager on November 6, 2009) is
estimated at 189.58% versus 116.80% reported in the September 18,
2009 trustee report (immediately prior to the above sales).
Similarly, the pro forma Class C OC ratio is estimated at 133.74%
versus 108.56% reported in the September report.

The downgrade of the Class D and E notes reflects the resolution
of the review for downgrade placed on the notes on November 10,
2009.  The downgrade action is a result of credit deterioration of
the portfolio after the asset sales, which is reflected through an
increase in the weighted average rating factor and an increase in
exposure to obligations rated Caa1 or below by Moody's or CCC+ or
below by S&P.  The pro forma weighted average rating factor of the
pool is 3915, an increase of 15% over the WARF level of 3400
reported in September 2009.  The pro forma exposure to CCC or Caa-
rated assets has increased to 28.5% of the underlying portfolio
versus 21.5% in September.  The increase in CCC/Caa asset exposure
has also increased the excess CCC or Caa haircut percentage
applied to the OC ratios.  In contrast to the improvement of the
Class A/B OC and C OC ratios, the haircut is large enough to more
than offset the benefits from delevering caused by the collateral
sales.  On a pro forma basis, the D OC and E OC ratios continue to
fail their respective OC triggers, despite slight improvement
versus OC levels prior to the asset sales.

The rating actions across the entire capital structure also
consider the deterioration of the diversity score and potential
impact from future collateral sales.  The pro forma diversity
score is 24, a decline of 56% from the level of 55 reported in
September, indicative of increased concentration risks for the
pool.  The rating actions consider the ability of the manager to
continue to conduct sales in order to cure the Class D and E OC
test failures.  This consideration includes the potential for the
weighted average rating factor and/or diversity score to further
decline in the event additional sales of higher-rated assets
occur, resulting in the remaining notes being collateralized by a
smaller, deteriorated portfolio.

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


MARICOPA COUNTY: Fitch Assigns 'BB+' Rating on $36 Mil. Bonds
-------------------------------------------------------------
Fitch Ratings has assigned a 'BB+' rating to the $36 million 6.25%
Maricopa County, Arizona Pollution Control Corporation pollution
control revenue refunding bonds, 2003 series A (Public Service
Company of New Mexico Palo Verde Project), due Jan. 1, 2038.  The
transaction was priced Nov. 24, 2009, and is expected to close on
Dec. 1, 2009.  The Rating Outlook is Stable.

The rating reflects Public Service Company of New Mexico's high
debt leverage relative to EBITDA, low earned returns and weak
credit metrics.  The ratings also consider management efforts to
work diligently with New Mexico Public Regulation Commission to
timely recover its invested capital with a reasonable return on
investment.  Regulatory lag is a primary concern for PNM
investors.  Importantly, legislation was enacted in New Mexico in
2009 allowing use of a forward test year in general rate case
proceedings, which should benefit future rate cases.

The ability of the company to meet its secular infrastructure
investment requirements and earn a reasonable return on investment
is expected to be a key driver of the company's future
creditworthiness.

PNM filed a GRC proceeding with the PRC in September 2008
requesting a $123 million rate increase, based on a test year
ending March 2008, and authorization of a fuel and purchase power
adjustment clause.  In March 2009, the company and most
intervening parties to the GRC entered into a stipulated agreement
that proposed a $77 million rate increase to be implemented in two
steps: $50 million on July 1, 2009, and the remainder on April 1,
2010.

The proposed stipulation was approved by the PRC with slight
modifications.  Most important, the PRC-approved settlement
authorized a revised FPPAC which provides for the deferral and
recovery of 100% of fuel and purchase power costs from ratepayers.
Adoption of the FPPAC significantly improves PNM's business risk
profile in Fitch's opinion and is supportive of the utility's
creditworthiness.

The rating also recognized PNM's status as the largest of
corporate parent PNM Resources' two core electric operating
utility subsidiaries.  There are no inter-company guarantees or
cross defaults between PNM and PNMR or its operating affiliates.


MAX CMBS: S&P Downgrades Ratings on 22 Classes of Notes
-------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 22
classes from MAX CMBS I Ltd.'s series 2007-1 and 2008-1 and from
COMM 2008-RS3.  S&P removed 12 of the lowered ratings from
CreditWatch negative, and 10 of the lowered ratings remain on
CreditWatch negative.  In addition, S&P affirmed its ratings on
two classes from two of these transactions.

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

The downgrades reflect S&P's analysis of the transactions
following its downgrades of 49 commercial mortgage-backed
securities certificates that serve as collateral for MAX 2007-1
and MAX 2008-1.  The certificates are from 31 transactions
totaling $2.587 billion (32.8% of the pool balance for these
transactions).  The 10 ratings remaining on CreditWatch negative
reflect the transactions' exposure to CMBS collateral with ratings
on CreditWatch negative ($1.01 billion, 12.8%).

According to the Oct. 19, 2009, trustee report, MAX 2008-1 and
MAX 2007-1 were collateralized by 156 CMBS certificates
($7.114 billion, 90% of the combined transaction balances) from
99 distinct transactions issued between 2005 and 2007.  The
collateral also includes 12 collateralized debt obligation classes
($776.6 million, 10%) from 12 distinct transactions.  MAX 2007-1
and MAX 2008-1 have significant exposure to Standard & Poor's
downgraded CMBS, including these:

* JPMorgan Chase Commercial Mortgage Securities Trust 2007-LDP11
  (classes A-4, A-M, and A-J; $320.6 million, 4.1%);

* JPMorgan Chase Commercial Mortgage Securities Trust 2007-CIBC18
  (classes A-4, A-M, and A-J; $290 million, 3.7%);

* Wachovia Bank Commercial Mortgage Trust's series 2007-C33
  (classes A-4 and A-J; $181 million, 2.3%);

* Wachovia Bank Commercial Mortgage Trust's series 2007-C31
  (classes A-M and A-J; $174 million, 2.2%); and

* LB-UBS Commercial Mortgage Trust 2007-C2 (class A-3, A-M, and A-
  J; $171.2 million, 2.2%).

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

The distribution of interest proceeds to the interest-only (IO)
classes X-B and X-W from MAX 2008-1 are made pro rata to classes
A-2A and A-2B, which S&P downgraded accordingly.  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 IO certificates S&P lowered.

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

      Ratings Lowered And Remaining On Creditwatch Negative

                     MAX CMBS I 2007-1 Ltd.

                                Rating
                                ------
         Class            To               From
         -----            --               -----
         A-1              BB+/Watch Neg    A+/Watch Neg

                      MAX CMBS I 2008-1 Ltd.

                                Rating
                                ------
         Class            To               From
         -----            --               -----
         A-1              BB+/Watch Neg    A+/Watch Neg
         A-2A             B/Watch Neg      BBB-/Watch Neg
         A-2B             B/Watch Neg      BBB-/Watch Neg
         X-B              B/Watch Neg      BBB-/Watch Neg
         X-W              B/Watch Neg      BBB-/Watch Neg

                          COMM 2008-RS3

                                Rating
                                ------
         Class            To               From
         -----            --               -----
         A-2A             B/Watch Neg      BBB-/Watch Neg
         A-2B             B/Watch Neg      BBB-/Watch Neg
         X-B              B/Watch Neg      BBB-/Watch Neg
         X-W              B/Watch Neg      BBB-/Watch Neg

      Ratings Lowered And Removed From Creditwatch Negative

                      MAX CMBS I 2008-1 Ltd.

                                Rating
                                ------
         Class            To               From
         -----            --               -----
         C                CCC-             BB-/Watch Neg
         E                CCC-             BB-/Watch Neg
         F                CCC-             B/Watch Neg
         G                CCC-             B/Watch Neg
         H                CCC-             B-/Watch Neg
         J                CCC-             CCC+/Watch Neg

                          COMM 2008-RS3

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

                        Ratings Affirmed

                      MAX CMBS I 2008-1 Ltd.

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

                          COMM 2008-RS3

                     Class            Rating
                     -----            ------
                     H                CCC-


MORGAN STANLEY: S&P Downgrades Ratings on 16 2007-IQ13 Securities
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 16
classes of commercial mortgage-backed securities from Morgan
Stanley Capital I Trust 2007-IQ13 and removed them from
CreditWatch with negative implications.  In addition, S&P affirmed
its ratings on five classes from the same transaction.

The ratings 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 the specially serviced
loans, as well as S&P's analysis of one loan that 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, Standard &
Poor's calculated an adjusted debt service coverage of 1.18x and a
loan-to-value ratio of 140.0%.  S&P further stressed the loans'
cash flows under its 'AAA' scenario to yield a weighted average
DSC of 0.74x and an LTV of 185.4%.  The implied defaults and loss
severity under the 'AAA' scenario were 85.9% and 50.0%,
respectively.  All of the above DSC and LTV calculations excluded
two specially serviced loans ($26.9 million, 1.7%) and one credit-
impaired loan ($4.5 million, 0.3%).  S&P separately estimated
losses for these loans, which are included in the 'AAA' scenario
implied default and loss figures.  S&P also excluded 38
cooperative apartment loans ($125.9 million, 7.8%) from all of the
DSC and LTV calculations.  These loans 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
outstanding ratings.  S&P affirmed the 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 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

Seven loans ($53.1 million, 3.3%) in the pool are with the special
servicer, LNR Partners Inc.  One of these loans ($15.3 million,
0.95%) is in foreclosure; one ($11.6 million, 0.7%) is more than
90 days delinquent; two ($3.8 million, 0.2%) are 60 days
delinquent; one ($6.3 million, 0.4%) is 30 days delinquent; and
two ($16.0 million, 1.0%) are within their respective grace
periods.  The specially serviced loans have balances that
individually represent less than 0.95% of the pool balance.  S&P
estimated losses on two loans ($26.9 million, 1.7%) ranging from
23.2% to 54.3%.  Several of the remaining specially serviced loans
may be candidates for loan modifications and may eventually be
returned to the master servicer.

There is also one loan ($4.5 million, 0.3%) that S&P determined to
be credit-impaired.  The 15125 Washington Street loan is secured
by an 18,000-sq.-ft. unanchored retail center in Haymarket, Va.
As of Dec. 31, 2008, the property was 73% occupied with a 0.44x
DSC.  The DSC for the property has been below 1.0x for over 2.5
years, and occupancy has been low.  Consequently, S&P has
determined this loan to be at an increased risk of default.

                        Transaction Summary

As of the November 2009 remittance report, the aggregate trust
balance was $1.62 billion, which represents 98.7% of the aggregate
trust balance at issuance.  There are 174 loans in the pool, which
is unchanged since at issuance.  The master servicer for the
transaction is Wells Fargo Bank N.A., except with respect to the
cooperative apartment loans for which the master servicer is NCB
FSB.  The master servicers provided financial information for
97.7% of the pool, and 84.2% 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 1.22x for the pool based on the reported figures.  S&P's
adjusted DSC and LTV were 1.18x and 140.0%, respectively.  S&P's
adjusted figures exclude two 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 1.44x for two of the three loans.  Data
was not reported for one loan.

To date, the transaction has not realized any principal losses.
Nineteen loans ($577.3 million, 35.7%) are on the master
servicer's watchlist, including four of the top 10 loans.  Twenty-
three loans ($532.6 million, 32.9%) have a reported DSC of less
than 1.10x, and 16 of these loans ($438.1 million, 27.1%) have a
reported DSC of less than 1.0x.

                     Summary of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$758.4 million (46.9%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.05x for the top 10 loans.
S&P's adjusted DSC and LTV for the top 10 loans were 0.98x and
162.0%, respectively.  The largest, second-, fifth-, and ninth-
largest loans in the pool ($449.4 million, 27.8%) appear on the
master servicer's watchlist.

The 75-101 Federal Street loan ($210.0 million, 13.0%) is the
largest loan in the pool and is secured by two office buildings
that constitute 811,687-sq.-ft. of office space in Boston.  The
loan appears on the master servicer's watchlist due to low DSC.
Occupancy was 79.8% as of July 31, 2009, and DSC was 0.64x as of
Dec. 31, 2008.  DSC has since improved slightly to 0.83x as of the
six months ended June 30, 2009.

The RREEF Portfolio Roll-Up ($147.0 million, 9.1%) is the second-
largest loan in the pool and is secured by an eight-property,
2,580-unit multifamily portfolio with six properties in northern
Virginia and two properties in suburban Maryland.  The loan
appears on the master servicer's watchlist due to low DSC.
Occupancy was 95.4% as of June 30, 2009, and DSC was 1.05x as of
the nine months ended Sept. 30, 2008.

The AT&T Tower loan ($65.0 million, 4.0%) is the fifth-largest
loan in the pool and is secured by a 606,579-sq.-ft. office
building in Minneapolis.  The loan appears on the master
servicer's watchlist due to low DSC and a decline in occupancy.
As of June 30, 2009, occupancy was 72.8% and DSC was 1.01x.

The Northridge I loan ($27.4 million, 1.6%) is the ninth-largest
loan in the pool and is secured by a 123,208-sq.-ft. office
building in Herndon, Va.  The loan appears on the master
servicer's watchlist due to a decline in DSC caused by decreased
rents and increased expenses.  In addition, recent tenant
departures have lowered occupancy to 65.8% as of June 30, 2009.
DSC was 0.92x as of June 30, 2009.  One tenant, comprising 33.7%
of the net rentable area, vacated the premises on June 30, 2009.
Efforts to find a new tenant are ongoing.

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 2007-IQ13
          Commercial mortgage pass-through certificates

                 Rating
                 ------
    Class  To              From          Credit enhancement (%)
    -----  --              ----          ----------------------
    A-1A   A-              AAA/Watch Neg                  30.40
    A-4    A-              AAA/Watch Neg                  30.40
    A-M    BB+             AAA/Watch Neg                  20.27
    A-J    B+              AAA/Watch Neg                  11.02
    B      B+              AA/Watch Neg                    8.99
    C      B               AA-/Watch Neg                   7.98
    D      B               A/Watch Neg                     6.97
    E      B               A-/Watch Neg                    6.08
    F      B-              BBB+/Watch Neg                  4.94
    G      B-              BBB/Watch Neg                   4.05
    H      B-              BBB-/Watch Neg                  2.91
    J      B-              BB+/Watch Neg                   2.41
    K      CCC+            BB/Watch Neg                    2.28
    L      CCC+            BB-/Watch Neg                   2.03
    N      CCC             B/Watch Neg                     1.52
    O      CCC-            B-/Watch Neg                    1.14

                         Ratings Affirmed

             Morgan Stanley Capital I Trust 2007-IQ13
          Commercial mortgage pass-through certificates

            Class  Rating        Credit enhancement (%)
            -----  ------        ----------------------
            A-1    AAA                            30.40
            A-2    AAA                            30.40
            A-3    AAA                            30.40
            X      AAA                              N/A
            X-Y    AAA                              N/A


MORGAN STANLEY: S&P Puts 'BB+' Rating on CreditWatch Positive
-------------------------------------------------------------
Standard & Poor's Ratings Services placed its 'BB+' rating on the
$3 million class A-11 notes from Morgan Stanley ACES SPC's secured
fixed-rate notes series 2006-8 on CreditWatch with positive
implications.

The rating on the class A-11 notes is dependent on the lowest of
the ratings on (i) the reference obligation, Rock-Tenn Co.'s
$250 million 8.2% senior secured notes due Aug. 15, 2011
('BB+/Watch Pos'); (ii) the rating on Morgan Stanley ('A'), which
is the swap payments guarantor; and (iii) the rating on the
underlying security, BA Master Credit Card Trust II's class A
floating-rate asset-backed certificates series 2001-B due Aug. 15,
2013 ('AAA').

The CreditWatch placement follows the Nov. 12, 2009, placement of
S&P's rating on Rock-Tenn Co.'s $250 million 8.2% senior secured
notes due Aug. 15, 2011, on CreditWatch with positive
implications.


MORGAN STANLEY: S&P Withdraws 'CCC-' Rating on Class IA Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its rating on the
class IA notes issued by Morgan Stanley ACES SPC's series 2007-17,
a synthetic corporate investment-grade collateralized debt
obligation transaction.  The rating was previously on CreditWatch
with negative implications.

The rating withdrawal follows the complete redemption and
cancellation of the notes pursuant to the notice dated Sept. 29,
2009.

                         Rating Withdrawn

                     Morgan Stanley ACES SPC
                          Series 2007-17

                Rating                   Balance (mil. $)
                ------                   ----------------
     Class    To      From             Current      Previous
     -----    --      ----             -------      --------
     IA       NR      CCC-/Watch Neg     0.000        25.000

                          NR - Not rated.


MORGAN STANLEY: S&P Withdraws 'CCC-' Rating on Class IIA Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its 'CCC-' rating on
the class IIA notes issued by Morgan Stanley ACES SPC's series
2007-8, a synthetic corporate investment-grade collateralized debt
obligation transaction.  The rating was previously on CreditWatch
with negative implications.

The rating withdrawal follows the repurchase and unwinding of the
notes by the issuer.

                         Rating Withdrawn

                     Morgan Stanley ACES SPC
                          Series 2007-8

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


NELSON RE: Moody's Takes Rating Actions on Catastrophe Bonds
------------------------------------------------------------
Moody's Investors Service has taken these rating actions on the
Class G, H and I catastrophe bonds of Nelson Re Ltd.:

  -- Class G ($67.5 million) catastrophe bonds downgraded to Ca
     from B3 with developing outlook;

  -- Class H ($45.0 million) catastrophe bonds, rated B3, placed
     on review for possible downgrade;

  -- Class I ($67.5 million) catastrophe bonds, rated B1, placed
     on review for possible downgrade.

Moody's has downgraded the Class G notes to Ca from B3 and
assigned a developing outlook.  This follows a recent announcement
by Glacier Reinsurance AG, the sponsor of Nelson Re, that it
expects the Class G notes to attach in the near future as a result
of losses from Hurricane Ike which hit the Gulf of Mexico last
Fall.

The Ca rating on the Class G securities assumes that the notes
will attach and that recovery of promised principal and interest
will be less than 60%.  The developing outlook reflects the
possibility that ultimate recoveries could be significantly better
or worse than contemplated.  The extent of ultimate recoveries
remains very uncertain at this point as ceding companies continue
to report losses to Glacier and Glacier continues to pay out
losses.

In the same action, Moody's has placed the Class H and Class I
notes on review for possible downgrade due to recent
organizational changes at Glacier Re (and not because of incurred
losses).  Glacier's CEO recently resigned and was replaced by a
non-executive director, who comes from hedge fund HBK Capital
Management, one of Glacier's founding shareholders.

Although Glacier announced in a public statement that it remains
committed to the European reinsurance market, it is unclear how
Glacier's clients will interpret recent management changes heading
into January 1 renewals and what impact this may have on the
quality of business ceded to Nelson Re.  Moody's expects to speak
with management after January renewals to assess the
characteristics and quality of the bound portfolio.  If the
portfolio remains largely consistent with that contemplated when
the ratings were originally assigned, Moody's would likely confirm
the Class H and Class I ratings at their current levels.

Nelson Re issued the Class G, H and I notes in June 2008 as a way
for note holders to provide per occurrence excess-of-loss
reinsurance to Glacier Re for U.S. hurricane/earthquake events
(Class G) and European windstorm events (Class H and I).

This security has been downgraded and assigned a developing
outlook:

* Nelson Re Ltd. -- $67.5 million Class G Series 2008-I Principal-
  at-Risk Variable Rate Notes due June 2011 downgraded to Ca from
  B3; outlook developing

These securities have been placed under review for possible
downgrade:

* Nelson Re Ltd. -- $45.0 million Class H Series 2008-I Principal-
  at-Risk Variable Rate Notes due June 2011 at B3;

* Nelson Re Ltd. -- $67.5 million Class I Series 2008-I Principal-
  at-Risk Variable Rate Notes due June 2011 at B1.

The last rating action occurred on August 27, 2009, when Moody's
continued its review for possible downgrade of the Class G bonds.


NEPTUNO CLO: Moody's Takes Rating Actions on Various Notes
----------------------------------------------------------
Moody's Investors Service announced these rating actions on notes
issued by Neptuno CLO II B.V.

  -- EUR308.5M Class A Senior Secured Floating Rate Notes due
     2023 (currently EUR 306,789,769 outstanding), Downgraded to
     A1; previously on March 18, 2009 Aaa Placed Under Review for
     Possible Downgrade;

  -- EUR28M Class B Senior Secured Floating Rate Notes due 2023
     Notes, Downgraded to Ba1; previously on March 4, 2009 Aa2
     Placed Under Review for Possible Downgrade;

  -- EUR23M Class C Senior Secured Deferrable Floating Rate Notes
     due 2023 (currently EUR 23,570,215 outstanding), Downgraded
     to B1; previously on March 18, 2009 Downgraded to Ba3 and
     Placed Under Review for Possible Downgrade;

  -- EUR23M Class D Senior Secured Deferrable Floating Rate Notes
     due 2023 (currently EUR 23,766,801 outstanding), Downgraded
     to Caa3; previously on March 18, 2009 Downgraded to Caa1 and
     Placed Under Review for Possible Downgrade;

  -- EUR19M Class E Senior Secured Deferrable Floating Rate Notes
     due 2023 (currently EUR 19,920,028 outstanding), Downgraded
     to Ca; previously on March 18, 2009 Downgraded to Caa3 and
     Placed Under Review for Possible Downgrade.

This transaction is a managed cash leveraged loan collateralized
loan obligation with exposure to predominantly European senior
secured loans, as well as some mezzanine loan exposure (12.6%).

The rating actions reflect Moody's revised assumptions with
respect to default probability and the calculation of the
diversity score as described in the press release dated
February 4, 2009, titled "Moody's updates key assumptions for
rating CLOs." These revised assumptions have been applied to all
corporate credits in the underlying portfolio, the revised
assumptions for the treatment of ratings on "Review for Possible
Downgrade", "Review for Possible Upgrade", or with a "Negative
Outlook" being applied to those corporate credits that are
publicly rated.

Moody's also notes that a material proportion of the collateral
pool consists of debt obligations whose credit quality has been
assessed through Moody's credit estimates.  As credit estimates do
not carry credit indicators such as ratings reviews and outlooks,
a stress of a quarter notch-equivalent assumed downgrade was
applied to each of these estimates.

According to Moody's, the rating actions taken on the notes are
also a result of credit deterioration of the underlying portfolio.
This is observed through a decline in the average credit rating as
measured through the portfolio weighted average rating factor
'WARF' (currently 3054), an increase in the amount of defaulted
securities (currently 2.6% of the portfolio), an increase in the
proportion of securities from issuers rated Caa1 and below
(currently 9.6% of the portfolio), and a failure of all par value
tests (including a deterioration of the Class A/B par value test
from 121.2% in June 2009 to 118.96% in October 2009).  As a result
of such OC tests failures, interest is currently deferring on
classes C, D and E.  These measures were taken from the recent
trustee report dated 15 October 2009.  Moody's also performed a
number of sensitivity analyses, including consideration of a
further decline in portfolio WARF quality.  Due to the impact of
all the aforementioned stresses, key model inputs used by Moody's
in its analysis, such as par, weighted average rating factor, and
weighted average recovery rate, may be different from trustee's
reported numbers.

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


NORMAN REGIONAL: S&P Cuts Ratings to 'BB+'; Gives Stable Outlook
----------------------------------------------------------------
Standard & Poor's Ratings Services said that it lowered its rating
to 'BB+' from BBB-' and revised its outlook to stable on Norman
Regional Hospital Authority, Oklahoma's $94 million series 2007
revenue and refunding bonds, $67 million series 2005 bonds, and
$49.4 million series 2002 bonds, all issued on behalf of Norman
Regional Health System.  The analysis focuses on NRHS'
consolidated results, including obligated and non-obligated
entities.  Total long-term debt outstanding at fiscal year-end
June 30, 2009, was $258.2 million.

"The rating and outlook revision reflect NRHS's 5.8% decline in
patient admissions in 2009, which led to a bigger-than-expected
decline in profitability such that the health system just met its
1.1x rate covenant requirement," said Standard & Poor's credit
analyst Kenneth Rodgers.

The stable outlook reflects S&P's belief that management's efforts
over the next two years to control expenses and preserve and
enhance liquidity while incurring no additional debt should
strengthen the health system's financial operating performance and
enable it to very slowly rebuild the organization's credit
strength.


PORTER SQUARE: Fitch Downgrades Ratings on Three Classes of Notes
-----------------------------------------------------------------
Fitch Ratings has downgraded three classes and affirmed one class
of notes issued by Porter Square CDO I, Ltd./Inc., as a result of
continued credit deterioration in the portfolio since last review
in November 2007.  Approximately 70% of the portfolio has been
downgraded since that time.  The details of the rating action
follow at the end of this press release.

As of the September 2009 trustee report, the current balance of
the portfolio is $55.3 million.  Defaulted securities, as defined
in the transaction's governing documents now comprise 26.6% of the
portfolio, compared to 0.6% at last review.  The downgrades to the
portfolio have left approximately 72.9% of the portfolio with a
Fitch derived rating below investment grade and 59.5% with a
rating in the 'CCC' rating category or lower (including defaulted
assets), compared to 28.5% and 8.9%, respectively at last review.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Structured Finance Portfolio Credit Model for projecting
future default levels for the underlying portfolio.  For each
class of notes, the credit enhancement levels where compared to
the rating loss levels projected by the SF PCM.

For this review, Fitch did not perform cash flow model analysis
under the framework described in Global Criteria for Cash Flow
Analysis in CDOs.  The transaction is currently paying down in a
straight sequential order and is expected to continue to do so
until maturity.  In addition, while some portion of the interest
proceeds is currently being used to pay down class A-2 notes, the
magnitude of this additional credit enhancement was not considered
sufficient to offset the significant deterioration in the credit
quality of the portfolio.  Further, the availability of interest
proceeds to pay down class balances is expected to diminish in the
future as over 30% of the portfolio consist of impaired securities
and as the portfolio continues to amortize.  For the class A-2 and
class A-3 notes, Fitch also considered the size of each class
balances relative to the size and expected amortization of the
portfolio.

The affirmation of the class A-2 notes is attributed to the
increase in credit enhancement available to the notes resulting
from principal amortizations and the application of interest
proceeds due to the continuing failure of the class A/B
overcollateralization test.  Since closing approximately 98% of
the class A-2 notes' balance amortized down.  The current CE
available to the class A-2 notes is consistent with the SF PCM
rating loss rate for the 'AAA' rating.  Fitch expects the
remaining balance of the class A-2 notes to be paid down on the
next distribution date in February 2010, as reflected by the
Stable Rating Outlook assigned to the notes.

The current CE level for the class A-3 notes is generally
consistent with the SF PCM rating loss rates for the 'AA' rating
category.  The notes are assigned a Negative Rating Outlook due to
the high concentration of residential mortgage-backed securities
bonds in the portfolio, which are expected to continue to face
ratings volatility in the next one to two years.

Additionally, the class A-2 and class A-3 notes are assigned a
Loss Severity rating of 'LS5'.  The LS rating indicates a
tranche's potential loss severity given default, as evidenced by
the ratio of tranche size to the base-case loss expectation for
the collateral, as explained in 'Criteria for Structured Finance
Loss Severity Ratings'.  For the class A-2 and class A-3 notes
this ratio is below 0.5.  The LS rating should always be
considered in conjunction with the probability of default for
tranches.

The class B notes are downgraded to 'CC' and the class C notes are
downgraded to 'C' due to the degree of deterioration within the
underlying portfolio.  While the class B notes are still receiving
timely interest distributions, Fitch believes that default is
probable for the class B notes and inevitable for the class C
notes at or prior to maturity.

Porter Square I is a structured finance collateralized debt
obligation that closed on July 31, 2003 and is managed by TCW
Asset Management Company.  Presently 53.1% of the portfolio is
composed of residential mortgage-backed securities, 25.3% consist
of high yield CDOs, 9.6% of investment grade corporate CDOs, and
5.9% comprises of U.S. SF CDOs.  The remaining 6.1% consists of
commercial mortgage-backed securities 5.9%, and commercial asset-
backed securities 0.2%.

Fitch has downgraded, affirmed, and assigned Rating Outlooks and
LS Ratings to these classes of Porter Square I as indicated:

  -- $1,590,023 class A-2 notes affirmed at 'AAA/LS5'; Outlook
     Stable;

  -- $5,889,664 class A-3 notes downgraded to 'AA/LS5' from 'AAA';
     Outlook Negative;

  -- $24,000,000 class B notes downgraded to 'CC' from 'A';
     removed from Rating Watch Negative;

  -- $17,014,285 class C notes downgraded to 'C' from 'BB+';
     removed from Rating Watch Negative.

Fitch does not assign Rating Outlooks to classes rated 'CCC' or
lower.


PORTER SQUARE: Fitch Downgrades Ratings on Two Classes of Notes
---------------------------------------------------------------
Fitch Ratings has downgraded two and affirmed two classes of notes
issued by Porter Square CDO II, Ltd./Inc., as a result of
continued credit deterioration in the portfolio since last review
in February 2009.  Approximately 76.7% of the portfolio has been
downgraded since that time.  The details of the rating action
follow at the end of this press release.

As per the October 2009 trustee report, the current balance of the
portfolio is $99.4 million.  Defaulted securities, as defined in
the transaction's governing documents, now comprise 30% of the
portfolio, compared to 13.8% at last review.  The downgrades to
the portfolio have left approximately 82% of the portfolio with a
Fitch derived rating below investment grade and 69.6% with a
rating in the 'CCC' rating category or lower (including defaulted
assets), compared to 60.9% and 30.1%, respectively at last review.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Structured Finance Portfolio Credit Model for projecting
future default levels for the underlying portfolio.  Due to the
significant collateral deterioration, all PCM rating loss rates
exceed the credit enhancement available to each class of notes.
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.
Given these factors, Fitch believes that the likelihood of default
for all classes of notes in this transaction can be assessed
without performing cash flow model analysis under the framework
described in the Global Criteria for Cash Flow Analysis in CDOs
report.

As of the November 2009 distribution date, the class A-1 notes
have been paid in full.  Due to the significant collateral
deterioration, however, the class A-2 notes are downgraded to 'CC'
to indicate Fitch's belief that default is probable at or prior to
maturity.

While the class B notes are still receiving current interest
distributions, given the large outstanding amount of the class A-2
notes and expected low recoveries for assets considered defaulted,
Fitch believes that default is inevitable for the class B notes at
or prior to maturity.

The class C and class D notes are affirmed at 'C', indicating
Fitch's continued belief that default is inevitable at or prior to
maturity.  Both classes are currently paying-in-kind interest due
and are not expected to receive any future interest or principal
payments.

Porter Square II is a structured finance collateralized debt
obligation that closed on Oct. 27, 2004, and is managed by TCW
Asset Management Company.  Presently 52.7% of the portfolio is
composed of residential mortgage-backed securities, 24.8% consist
of high yield CDOs, 12.5% of U.S. SF CDOs, and 5.8% is comprised
of investment grade corporate CDOs.  The remaining 4.6% consists
of commercial mortgage-backed securities 3.8%, and commercial
asset-backed securities 0.8%.

Fitch has downgraded or affirmed these classes of Porter Square II
as indicated:

  -- $0 class A-1 notes have been paid in full;
  -- $63,166,902 class A-2 notes downgraded to 'CC' from 'B';
  -- $23,500,000 class B notes downgraded to 'C' from 'CCC';
  -- $10,479,127 class C notes affirmed at 'C';
  -- $9,087,827 class D notes affirmed at 'C'.

Fitch does not assign Rating Outlooks to classes rated 'CCC' or
lower.


PPLUS TRUST: S&P Downgrades Ratings on $25 Mil. Certs. to 'BB-'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on PPLUS
Trust Series LTD-1's $25 million class A and B certificates to
'BB-' from 'BB'.  At the same time, S&P removed the ratings from
CreditWatch with negative implications, where they were placed on
June 18, 2009.

The ratings on the certificates are dependent solely on the rating
on the underlying security, Limited Brands Inc.'s 6.95% debentures
due March 1, 2033 ('BB-').

The rating actions reflect the Nov. 10, 2009, lowering of S&P's
rating on the underlying security and its removal from CreditWatch
negative, where it was placed on June 15, 2009.


PPLUS TRUST: S&P Puts 'BB' Cert. Rating on CreditWatch Negative
---------------------------------------------------------------
Standard & Poor's Ratings Services placed its 'BB' rating on PPLUS
Trust Series SPR-1's $42.515 million certificates on CreditWatch
with negative implications.

The rating on the certificates is dependent solely on the rating
on the underlying security, Sprint Capital Corp.'s 6.875% notes
due Nov. 15, 2028 ('BB/Watch Neg').

The CreditWatch placement reflects S&P's Nov. 11, 2009, placement
of the underlying security on CreditWatch with negative
implications.


PRICHARD HOUSING: Moody's Affirms 'Ba3' Rating on 1998 Bonds
------------------------------------------------------------
Moody's Investors Service has affirmed the rating on $615,000 of
outstanding Prichard Housing Corporation, First Mortgage Housing
Revenue Bonds (Ridge Manor - Section 8 Assisted Elderly Project)
Series 1998 at Ba3.  The outlook remains stable.  The rating
affirmation is based upon low debt service coverage levels, which
are offset by a relatively short time until bond maturity and
available fund balances.

Ridge Manor is a 120-unit housing property located in Prichard,
Alabama.  The property contains 102 one-bedroom apartments and 18
two-bedroom apartments, and is intended for low-income elderly
tenants.  Rental rate increases at the property are limited by the
annual adjustment factor approved by HUD.

                            Strengths

* Relatively short time until bond maturity in 9/1/2011.  Bond
  maturity coincides with the expiration of the HAP Contract.

* Fully funded Debt Service Reserve Fund

* Well-funded trustee-held funds, including a Replacement Reserve
  Fund and Refund Savings Fund.  The Replacement Reserve is
  intended for property maintenance, but may be drawn upon to pay
  debt service if the Debt Service Reserve Fund is depleted.
  Amounts currently held in the Replacement Reserve Fund are
  greater than those held in the Debt Service Reserve Fund.

* 95.8% occupancy rate as of November, 2009 and a 50-person
  waiting list

                           Challenges

* Debt service coverage levels remain depressed.  Audited
  financial statements show debt service coverage levels have been
  0.57x (FY2007), 0.71x (FY2008) and 0.68x (FY2009).  These debt
  service coverage levels are in line with other Moody's-rated
  Section 8 properties at this rating level.

* Rental revenue has been stagnant over the past three fiscal
  years.

                             Outlook

The outlook on the bonds remains stable due to substantial fund
balances and the relatively short time until bond maturity.

Key Statistics:

  -- Current Occupancy: 95.8%
  -- Bond Maturity: 9/1/2011
  -- HAP Expiration: 9/1/2011
  -- Debt Service Coverage (FY2009): 0.68x
  -- Average Rent as % of FMR: 81%
  -- Debt Service Reserve Fund balance: $339,145

The last rating action for this program was taken on May 28, 2008,
when the rating was downgraded to Ba3 from Ba1 and the stable
outlook was affirmed.


PRIME 2004-CL1A: S&P Downgrades Ratings on Two Classes of Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on two
classes of certificates from PRIME 2004-CL1A, a U.S. residential
mortgage-backed securities resecuritized real estate mortgage
investment conduit transaction.  S&P lowered its rating on class
B-1 to 'CCC' from 'AA', and S&P lowered its rating on class B-2 to
'CC' from 'BBB-'.  At the same time, S&P affirmed its 'CCC' rating
on class X-B.

The downgrades reflect the significant deterioration in
performance of the loans backing the underlying certificates.  The
affirmation reflects the sufficient amount of credit support
within the re-REMIC to maintain the current rating on class X-B.

PRIME 2004-CL1A, which closed in February 2004, is collateralized
by three underlying classes that support the certificates within
the re-REMIC.  The loans securing the three underlying classes
consist predominately of fixed-rate prime mortgage loans.

Classes B-1 and B-2 from PRIME 2004-CL1A are supported by classes
B-1 (currently rated 'B') and B-2 (currently rated 'CCC'),
respectively, from PRIME Mortgage Trust, Series 2004-CL1.  The X-B
class from PRIME 2004-CL1A is supported by the B-1, B-2 and B-3
(currently rated 'D') classes from PRIME Mortgage Trust Series
2004-CL1.

The performance of the loans securing the certificates from this
trust has declined in recent months.  This pool had experienced
losses of 0.24% of the original pool balance as of the October
2009 distribution, and currently has approximately 11.59% of the
current pool balance in delinquent loans.  The current pool factor
is 0.1347 (13.47%), which represents the outstanding pool balance
as a proportion of the original balance.

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 expectation.

                         Ratings Lowered

                         PRIME 2004-CL1A
                      Series      2004-CL1A

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        B-1        07383UGB5     CCC                  AA
        B-2        07383UGC3     CC                   BBB-

                          Rating Affirmed

                          PRIME 2004-CL1A
                      Series      2004-CL1A

                Class       CUSIP         Rating
                -----       -----         ------
                X-B         07383UGE9     CCC


PUTNAM CBO: Fitch Downgrades Ratings on Notes to 'D/RR6'
--------------------------------------------------------
Fitch Ratings has downgraded and withdrawn its rating on the
remaining class of notes issued by Putnam CBO II Ltd./Corp., a CBO
managed by Putnam Advisory Company LLC.

The downgrade reflects the issuer's failure to redeem the full
principal amount due to the second priority senior notes on its
legal final maturity date of Nov. 8, 2009.  Due to an event of
default that occurred in Nov. 18, 2008, the asset manager does not
have right to sell the portfolio assets unless directed by the
controlling class of investors.  Liquidation of the collateral is
still pending, contingent on the investors' consent.  As a result,
no final distributions have been made to the remaining notes.

According to the trustee report dated Oct. 20, 2009, approximately
$1.75 million of cash and $2.52 million of collateral remains,
including $1.9 million currently listed as defaulted.  The total
portfolio proceeds available to the notes, even when accounted for
at par, represent less than 10% of the outstanding principal
amount, which is aligned with Fitch's 'RR6' recovery rating.

Fitch subsequently withdraws the rating of the second priority
senior notes since the notes have matured.

This rating action is effective immediately:

  -- $50,338,563 second priority senior notes downgraded to
     'D/RR6' from 'C/RR6' and withdrawn.


RACERS 2000-16-P-STRONG: Moody's Withdraws 'C' Rating on Certs.
---------------------------------------------------------------
Moody's Investors Service announced that it has withdrawn the
rating of these certificates issued by RACERS 2000-16-P-Strong:

  -- US$2,012,750 RACERS 2000-16-P-Strong Trust Certificates;
     Withdrawn; Previously on December 17, 2008 Downgraded to C

The transaction is a structured note whose rating is based on the
underlying securities and legal structure of the transaction.  The
rating action is a result of the withdrawal of the Moody's rating
of the underlying securities, which are the $2,012,750.71 Lehman
Brothers Zero Coupon Bond due 10/15/2013, following the bankruptcy
filing by Lehman Brothers Holdings Inc.


RACERS 2001-17-P: Moody's Withdraws 'C' Rating on Certificates
--------------------------------------------------------------
Moody's Investors Service announced that it has withdrawn the
rating of these certificates issued by RACERS 2001-17-P:

  -- US$1,708,000 RACERS 2001-17-P Certificates due November
     2014; Withdrawn; Previously on December 17, 2008 Downgraded
     to C

The transaction is a structured note whose rating is based on the
underlying securities held by the certificate issuer and the legal
structure of the transaction.  The underlying securities are the
$1,708,000 principal amount of zero coupon due July 15, 2014,
issued by Lehman Brothers Holdings Inc. whose current rating was
withdrawn by Moody's following a bankruptcy filing by that entity.


RACE POINT: Fitch Downgrades Ratings on Four Classes of Notes
-------------------------------------------------------------
Fitch Ratings has affirmed four and downgraded four classes of
notes issued by Race Point CLO Ltd./Inc.

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 class A-1, A-2, 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-1 notes have received over
77% of their initial principal balance since the end of the
reinvestment period in May 2007.  The relative priorities of the
class A-2, B-1 and B-2 notes have improved due to the significant
amortization of the class A-1 notes above them, helping to
mitigate the deteriorating performance of the underlying
collateral.  The relatively small par balances of the class B-1
and B-2 notes increase their likelihood of continued performance,
given the strong performance expectations of the class A-1 and A-2
tranches immediately senior to them.

The downgrades to the class C notes and the class D-1, D-2, and D-
3 notes are due to the collateral deterioration experienced since
Fitch's last rating review in December 2008.  Defaulted assets
currently account for 13.2% of the portfolio, representing a
marked increase from 1.5% at Fitch's last rating review.  Fitch
also considers 36.7% of the performing portfolio to be rated
'CCC+' or below, up from 27.7% at the last review.  Additionally,
35.4% of the underlying portfolio ratings have a Negative Rating
Outlook, indicating the possibility of further negative rating
migration.  While a degree of credit enhancement remains for the
class C and D notes, the significant credit deterioration of the
portfolio has decreased the protection that these levels of credit
enhancement once provided.

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-1 and A-2 notes displayed solid
performance in both of these scenarios and have therefore been
assigned a Stable Outlook.  The class B-1, B-2, C, and D notes
displayed greater degrees of sensitivity to lower recovery rates.
This sensitivity, in addition to the large amount of underlying
portfolio credits with Negative Outlooks, has led Fitch to assign
Negative Outlooks on these classes of notes.

The class A-1, A-2, 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.

Race Point CLO is a cash flow collateralized loan obligation that
closed on Nov. 20, 2001, and is managed by Sankaty Advisors, LLC.
The transaction's reinvestment period ended in May 2007.  The
portfolio is composed of 89.1% senior secured loans, 5.8% senior
unsecured bonds, and 5.1% junior secured and subordinate bonds and
loans.

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

  -- $72,711,468 class A-1 notes affirmed at 'AAA/LS3'; Outlook
     Stable;

  -- $71,000,000 class A-2 notes affirmed at 'AA-/LS3'; Outlook
     Stable;

  -- $10,000,000 class B-1 notes affirmed at 'A-/LS4'; Outlook to
     Negative from Stable;

  -- $12,000,000 class B-2 notes affirmed at 'A-/LS4'; Outlook to
     Negative from Stable;

  -- $20,000,000 class C notes downgraded to 'B/LS4' from 'BBB';
     Outlook Negative;

  -- $15,500,000 class D-1 notes downgraded to 'CCC' from 'BB-';

  -- $2,000,000 class D-2 notes downgraded to 'CCC' from 'BB-';

  -- $3,500,000 class D-3 notes downgraded to 'CCC' from 'BB-'.


RFC CDO: Fitch Downgrades Ratings on 10 Classes of 2006-1 Notes
---------------------------------------------------------------
Fitch Ratings downgrades ten classes of RFC CDO 2006-1, Ltd./LLC,
formerly known as CBRE Realty Finance CDO 2006-1, Ltd. / LLC,
reflecting Fitch's base case loss expectation of 34.8%.  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.

RFC 2006-1 is collateralized by both senior and subordinate
commercial real estate debt, with 51.6% whole loans/A-notes, 12.8%
B-notes, and 17.6% mezzanine loans.  Fitch expects significant
losses upon default for the subordinate positions since they are
generally highly leveraged, thin debt classes.  Further, the
portfolio currently contains 9.4% defaulted or delinquent assets.
A mezzanine loan secured by an interest in a construction project
(3.4%) is defaulted and expected to be a complete loss, while a
multifamily whole loan (6%) is delinquent on interest payments.
An additional four assets (19.1%) are considered Fitch Loans Of
Concern; two are whole loans, and two are mezzanine loans.

Beginning in the first quarter of 2009, each of the class C, D, E,
F, and G overcollateralization tests breached their respective
covenants.  As a result, classes D and below are no longer
receiving any proceeds as of the October 2009 trustee report.  All
excess interest proceeds (after class C) and any principal
proceeds are currently being redirected to redeem the class A-1
notes.  As a result, class A-1 has paid down by over $60 million
to date.  Given its expectations of further defaults, Fitch
considers it unlikely that classes below the D, E, F, and G OC
tests will receive any further proceeds over the life of the
transaction.  Fitch believes it may be possible for the class C
test to cure, at least temporarily, as the senior notes continue
to de-lever and as the hedge notional reduces.  Payments to the
hedge counterparty are currently the single largest transaction
expense.

RFC 2006-1 was issued as a $600 million CRE collateralized debt
obligation managed by Realty Finance Corporation.  The transaction
has a five-year reinvestment period that will end in March 2011.
As of the October 2009 trustee report and per Fitch
categorizations, the CDO is substantially invested: office
(31.8%), hotel (23.8%), CMBS (18%), multifamily (13.7%),
industrial (7.1%), construction (3.4%), and other (2.2%).  Fitch
is generally concerned with the relatively high concentration of
hotel properties in the portfolio, as these have proven to be more
volatile assets.  While the hotels securing the assets in this
portfolio are typically full-service trophy properties, all but
one of the loans are subordinated positions.

Under Fitch's updated methodology, approximately 53.3% 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 14% from either year end 2008 or more
recently reported cash flows.  Fitch estimates that recoveries
will average 34.8%.

The largest component of Fitch's base case loss expectation is a
mezzanine loan (4.7%) secured by an interest in a 1,340 room full
service hotel located in Honolulu, Hawaii.  The loan is highly
leveraged and as of April 2009 has experienced a 28% cash flow
decline from the prior year.  While it is likely the loan will
continue to receive interest payments during the loan term, Fitch
expects this asset to experience a complete loss at maturity in
its modeling.

The next largest component of Fitch's base case loss expectation
is a whole loan (6.6%) secured by a 72-room boutique hotel located
in the Times Square area of New York City.  While the property has
been able to maintain occupancy at above 60%, room revenues as of
April 2009 were down over 40% from the prior year, and net
operating income decreased by nearly 90%.  The lenders modified
the loan terms in order to relieve some of the immediate pressures
due to debt service payments; however, the severe cash flow
decline presents a high risk of default.

The third largest component of Fitch's base case loss expectation
is a whole loan (6%) secured by a 324-unit multifamily property
located in Phoenix, Arizona.  The property is currently delinquent
as performance declined steadily due to the general market
conditions in the Phoenix area, where apartment inventories have
grown in part due to failed condo projects being re-apartmented.
Management at this property has been offering significant
concessions in attempts to maintain occupancy.

This transaction was analyzed according to the 'U.S. CREL CDO
Surveillance Criteria,' which applies stresses to property cash
flows and 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 'BB' rating category; and the class A-2 and class B notes'
breakeven rates are generally consistent with the 'B' rating
category.

Ratings for classes C through K are generally based on a
deterministic analysis, which considers the current percentage of
defaulted and delinquent assets and any Fitch Loans of Concern, as
well as the likelihood for OC tests to fail and/or cure.  Based on
this analysis, class C is consistent with a 'CCC' rating, meaning
default is possible given the credit enhancement to each class
falls below Fitch's base case loss expectation of 34.8%.  Classes
D through F are rated 'CC', meaning default is probable, and
classes G through K are rated 'C', meaning default is deemed
inevitable.

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 'LS3' 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 and K 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
(53.3% and 34.8%, 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 class' tranche size to determine a recovery rating.  The
assumptions for the 'B' stress US$ LIBOR up stress scenario are
found in the report, 'Fitch US$ LIBOR Stresses'.

The assignment of 'RR5' to class C reflects modeled recoveries of
27.5% of its outstanding balance.  The expected recovery proceeds
are broken down:

  -- Present value of expected principal recoveries
     ($1.2 million);

  -- Present value of expected interest payments ($2.9 million);

  -- Total present value of recoveries ($4.1 million);

  -- Sum of undiscounted recoveries ($8.3 million).

The assignment of 'RR6' to classes D through K reflects that the
modeled recovery for each class is less than 10% of its principal
balance.

Fitch has affirmed and assigned LS ratings and a Rating Outlook to
this class:

  -- $34,500,000 class B at 'B/LS5'; Outlook Negative.

Fitch has downgraded, assigned LS and RR ratings, and assigned
Rating Outlooks to the remaining classes:

  -- $311,173,996 class A-1 to 'BB/LS3' from 'AA'; Outlook
     Negative;

  -- $33,000,000 class A-2 to 'B/LS5' from 'A'; Outlook Negative;

  -- $15,000,000 class C to 'CCC/RR5' from 'B';

  -- $13,500,000 class D to 'CC/RR6' from 'B';

  -- $9,000,000 class E to 'CC/RR6' from 'B';

  -- $10,500,000 class F to 'CC/RR6' from 'B';

  -- $13,500,000 class G to 'C/RR6' from 'CCC';

  -- $4,500,000 class H to 'C/RR6' from 'CCC';

  -- $24,000,000 class J to 'C/RR6' from 'CCC';

  -- $20,250,000 class K to 'C/RR6' from 'CCC'.

Additionally, all classes are removed from Rating Watch Negative.


SANKATY HIGH: S&P Downgrades Ratings on Eight Classes of Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of notes issued by Sankaty High Yield Partners II L.P., a
market value collateralized debt obligation.  At the same time,
Standard & Poor's affirmed its rating on one class of notes issued
by Sankaty.

The rating actions reflect S&P's opinion that the outstanding
notes will likely experience a principal payment default on
Nov. 30, 2009, their legal final maturity date.  S&P expects that
a default will occur because the class A-2 noteholders (the
controlling class) executed a forbearance agreement that will
delay the liquidation of the collateral portfolio and the
distribution of the proceeds beyond the notes' Nov. 30, 2009,
legal final maturity date.

Based on the collateral portfolio's current market value, as
reported by the trustee, and the application of S&P's criteria,
S&P believes that the class A-2 notes' full principal amount will
be recovered after the legal final maturity date.

Standard & Poor's will continue to monitor this transaction and
take rating actions pursuant to its criteria, as appropriate.

                         Ratings Lowered
               Sankaty High Yield Partners II L.P.

                                          Rating
                                          ------
         Class                       To            From
         -----                       --            ----
         A-2 (fixed rate)            CCC           AA
         A-2 (floating rate)         CCC           AA
         B (fixed rate)              CC            BB
         B (floating rate)           CC            BB
         C (fixed rate)              CC            CCC-
         C (floating rate)           CC            CCC-
         D (fixed rate)              CC            CCC-
         D (floating rate)           CC            CCC-

                         Rating Affirmed
               Sankaty High Yield Partners II L.P.

               Class                       Rating
               -----                       ------
               E (floating rate)           CC


SATURNS TRUST: S&P Puts 'BB' Ratings on CreditWatch Negative
------------------------------------------------------------
Standard & Poor's Ratings Services placed its 'BB' ratings on
SATURNS Trust No. 2003-2's $30 million class A and B units on
CreditWatch with negative implications.

The ratings on the units are dependent solely on the rating on the
underlying security, Sprint Capital Corp.'s 8.75% notes due
March 15, 2032 ('BB/Watch Neg').

The CreditWatch placements reflect S&P's Nov. 11, 2009, placement
of the underlying security on CreditWatch with negative
implications.


SEAWALL SPC: S&P Downgrades Ratings on 2008 CMBS CDO-3 Notes
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
notes issued by Seawall SPC's series 2008 CMBS CDO-3 and series
2008-39.  One of the two lowered ratings remains on CreditWatch
with negative implications.  Both deals are U.S. synthetic
collateralized debt obligation transactions.

The rating on Seawall SPC's series 2008 CMBS CDO-3 is directly
linked to the rating on the class A-J certificates from Cobalt
CMBS Commercial Mortgage Trust 2007-C3, and the rating on Seawall
SPC's series 2008-39 is directly linked to the rating on the class
A-2A certificates from MAX CMBS I Ltd.  S&P lowered its ratings on
the two U.S. synthetic CDO tranches in conjunction with its rating
actions affecting the related commercial mortgage-backed
securities transactions on Nov. 13, and Nov. 20, 2009,
respectively.

                          Rating Actions

                           Seawall SPC
$62.126 million series 2008 CMBS CDO-3 class A floating-rate notes

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

                           Seawall SPC
          $20 million floating-rate notes series 2008-39

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


SOUTH COUNTY: Moody's Confirms 'Ba1' Rating on Series 2006A Bonds
-----------------------------------------------------------------
Moody's Investors Service has confirmed the Ba1 long-term
(underlying) bond rating of South County Hospital following the
successful remarketing of Series 2006A bonds from auction mode to
a one-year term mode.  The 2006A bonds are also insured by Radian
Asset Insurance whose current claims-paying rating is Ba1.  The
rating confirmation affects $54.5 million of rated debt
outstanding which is listed at the end of this report.  At this
time the rating is removed from Watchlist.  The outlook is
negative.

Legal Security: The bonds are issued under the Master Indenture
and are secured by a general obligation guaranty by the South
County Hospital Healthcare System Endowment and by a pledge of the
hospital's gross receipts.  The Endowment is not a member of the
Obligated Group, which consists solely of South County Hospital
but Moody's includes the Endowment in Moody's analysis given the
guaranty.  The MTI permits the addition and withdrawal of other
obligated group members, including the hospital, upon certain
conditions.  Mortgage lien on the hospital's patient care
facilities and ancillary structures which secures equally all
notes issued under the MTI.  As part of the remarketing of the
Series 2006A bonds from auction mode to term mode, the debt
service reserve fund has been used to pay down $3.355 million in
principal.

Interest Rate Derivatives: SCH entered into an interest rate swap
in conjunction with the issuance of the Series 2006A bonds.  With
the fixed rate swap, SCH pays interest of 3.52% and the variable
component is set at 67% of LIBOR with a current notional amount of
$51.625 million.  The counterparty is Merrill Lynch Capital
Services, Inc., and the swap terminates on September 15, 2035.
The hospital's payment obligations under its 2006 Swap Agreement
are parity obligations and secured by the Guaranty and the
Mortgage.  Regularly scheduled swap payments, exclusive of
termination payments, are insured by Radian.  In the event that
SCH's long-term unsecured rating falls below investment grade, the
swap may default into early termination, requiring the hospital to
make a termination payment which could have a rating impact.  To
date, the counterparty has not terminated the swap.  As of
November 13, 2009, $5.4 million was posted for collateral
requirements related to the swap.  It is management's intention to
unwind the swap once market conditions are favorable.

                            Challenges

* Despite improvement in operating cash flow, operating deficits
  have continued with an operating loss of $7.8 million (-6.7%
  operating margin) in unaudited FY 2009 compared to an operating
  deficit of $7.2 million (-6.8% operating margin) in FY 2008 due
  to a spike in interest rate as a result of the failure of the
  auction rate market

* Weak debt measures attributed to poor operating performance and
  large amount of debt outstanding relative to total revenue
   (55%), with debt to cash flow ratio of 25.3 times and MADS
  coverage of 2.5 times in FY 2009

* Material decline in liquidity as of September 30, 2009 to
  $29.6 million (98.5 days cash on hand) from $37.4 million (127.9
  days cash on hand) at FYE 2008 due to investment losses,
  operating deficits, and required collateral posting related to
  its swaps

* Investment portfolio with over 60% allocated in equities which
  includes a modest amount in alternative assets

* Continued negative volumes trends in FY 2009, particularly in
  inpatient admissions and endoscopies, that speak to the long-
  term viability of the organization

* Expectation that South County will not meet the days cash on
  hand financial covenant within the Letter of Credit agreement on
  the Series 2003B&C bonds ($12.670 million outstanding)

                            Strengths

* Successful remarketing of Series 2006A bonds from auction mode
  to term mode which will materially reduce interest expense in FY
  2010 and removes some of the weaknesses in South County's debt
  structure

* Leading market share (53%) in a favorable primary service area
  with limited competition from the nearest hospitals that are
  approximately 20 miles away

* Successfully renegotiation of major commercial payors with
  significant rate increases

* Implementation of various expense reduction initiatives have
  yielded $3 million in annualized savings

                   Recent Developments/Results

The confirmation of the Ba1 bond rating follows the successful
remarketing of the Series 2006A bonds from auction mode to a one-
year term mode on September 15, 2009.  Under the terms of the
remarketing, Radian Asset Insurance, Inc. is now the sole
bondholder and the term mode will be in effect for one year ending
September 30, 2010.  The maximum interest rate will be 2% provided
that the interest swap on the Series 2006A bonds remains
outstanding.  If the swap agreement is terminated during the
initial interest period, the interest will increase by 300 basis
points from the date of the termination until the end of the
initial interest period.  Following the initial interest period,
the term interest rate will be negotiated by SCH and Radian on an
annual basis.  If an agreement is not reached, the default maximum
rate will be: 7% per annum for the period ending September 30,
2011, 9% per annum for the interest period ending September 30,
2012, and 12% per annum for each interest period commencing on or
after October 1, 2012.  If Radian no longer remains the sole
bondholder, the maximum rate will be 7% commencing on or after
October 1, 2010.

In addition to the financial covenants set forth in the Master
Trust agreement, Radian has also agreed to change the required
financial covenants such that the minimum days cash on hand of the
hospital and endowment combined was reduced from 90 days to 50
days for fiscal year 2009, 55 days for FY 2010, 65 days for FY
2011, 70 days for FY 2012, and 75 days for FY 2013 and thereafter.
Debt service coverage ratio was also reduced from 1.5 times to .80
times for FY 2009 and 1.25 times for FY 2010 and thereafter.
Radian also added an average payment period covenant whereby it
will not exceed 75 days.

Management is now currently in discussion with RBS Citizens, the
Letter of Credit provider for its Series 2003B and C bonds in an
attempt to renegotiate certain covenants as SCH is not expected to
be in compliance with its days cash on hand covenant of 125 days
(for the hospital and endowment combined) in FY 2009.  Per the
covenant calculation set forth by RBS Citizens, SCH and the
endowment calculates days cash to be 83 days at fiscal year end
2009.

Operating performance in unaudited FY 2009 was relatively flat to
FY 2008 with an operating deficit of $7.2 million (-6.9% operating
margin) compared to an operating deficit of $7.3 million (-6.8%
operating margin).  Operating cash flow, however, did improve in
unaudited FY 2009 to $7.4 million (6.4% operating cash flow
margin) from an operating cash flow of $4.5 million (4.2%
operating cash flow margin) in FY 2008 and exceeded projected year
end results of -7.4% operating margin and 5.6% operating cash flow
margin provided back in Moody's last review in August 2009.
Despite negative volume trends that have continued for both
inpatient admissions and outpatient surgeries, which management
attributed to the current recession and the continued negative
impact of a competing freestanding GI center, revenues grew 9.5%
due to rate increases from its major payors.  In May 2009, SCH
received double digit rate increases from its major commercial
payors.  Management has also continued to implement various
expense reduction initiatives which yielded $3 million in
annualized savings.

At unaudited FYE 2009, SCH's liquidity position declined a
material 20% from FYE 2008 to $29.6 million (98.5 days cash on
hand) from $37.4 million (127.9 days cash on hand) at FYE 2008.
The decline in unrestricted cash was driven by continued operating
deficits, collateral posting requirements related to its interest
rate swaps outstanding, and significant investment losses at the
end of the calendar year 2008.  As a result, cash to debt declined
for a second consecutive year to a weak 49.7% from 58.0% at FYE
2008.  A lower ratio was precluded as management reduced its debt
by $10.4 million with the return of unused Series 2006A bond
proceeds in May 2009 and the application of the debt service
reserve fund to further pay down the Series 2006A principal
balance in conjunction with the recent remarketing.  As part of
its operational improvement plan, the board has decided to reduce
its foundation support and allow the foundation's assets to grow.

With the restructuring of the Series 2006A bonds, interest expense
will be materially reduced and management projects to reach break
even operating performance by FY 2011.  However, reaching this
operating target will be difficult to achieve given the current
economic conditions in the state of Rhode Island, competitive
pressure from entrepreneurial physicians and the decision to abate
the annual financial support from the Foundation starting this
current FY 2010.  Management will need to successfully implement
its growth strategies and stabilize volumes to meet its goals.

                             Outlook

The negative outlook reflects Moody's belief that despite the
successful remarketing of its Series 2006A bonds and the various
initiatives that have been put in place, significant challenges
remain in successfully reaching financial targets.  Inability to
stabilize financial performance over the near term will likely
result in a rating downgrade.

                What could change the rating -- UP

Significantly improved and sustained operating performance;
increasing operating surpluses and cashflow generation; material
gains in liquidity

                What could change the rating -- DOWN

Inability to meet FY 2010 projections, continued deterioration of
liquidity measures, additional debt

                          Key Indicators

Assumptions & Adjustments:

  -- Based on financial statements for South County Hospital
     Healthcare System and Affiliates

  -- First number reflects audit year ended September, 30, 2008

  -- Second number reflects unaudited twelve month financials
     ended September 30, 2009

  -- Investment returns normalized at 6% unless otherwise noted

* Inpatient admissions: 5,562 ; 5,384

* Total operating revenues: $106.4 million; $116.5 million

* Moody's-adjusted net revenue available for debt service:
  $8.2 million; $10.3 million

* Total debt outstanding: $69.3 million; $59.5 million

* Maximum annual debt service (MADS): $4.2 million; $4.2 million

* Moody's-adjusted MADS Coverage with normalized investment
  income: 1.95 times; 2.46 times

* Debt-to-cash flow: 21.9 times; 25.3 times

* Days cash on hand: 127.9 days; 98.5 days

* Cash-to-debt: 58.0%; 49.7%

* Operating margin: -6.8%; -6.7%

* Operating cash flow margin: 4.2%; 6.4%

Outstanding Bonds (As Of September 30, 2009):

  -- Series 2003 B&C: $12.670 million outstanding; Aa1/VMIG1
     rating based on two-party pay provided by Letter of Credit
     from RBS Citizens, National Association; Ba1 underlying
     rating

  -- Series 2006A: $41.595 million outstanding; Ba1 rating based
     on Radian Asset Insurance; Ba1 underlying rating

The last rating action was on August 4, 2009, when the bond
ratings of South County Hospital were downgraded to Ba1 from Baa3
and the rating was placed on Watchlist for further downgrade.


STRUCTURED ASSET: S&P Downgrades Rating on $25 Mil. Units to 'BB-'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on
Structured Asset Trust Unit Repackagings Limited Brands Inc.
Debenture Backed Series 2005-3's $25 million callable units to
'BB-' from 'BB'.  At the same time, S&P removed its rating from
CreditWatch with negative implications, where S&P placed it on
June 18, 2009.

The rating on the callable units is dependent solely on the rating
on the underlying security, Limited Brands Inc.'s 6.95% debentures
due March 1, 2033 ('BB-').

The rating action reflects the Nov. 10, 2009, lowering of S&P's
rating on the underlying security and its removal CreditWatch
negative, where S&P placed it on June 15, 2009.


STRUCTURED REPACKAGED: S&P Puts 'BB' Rating on Negative Watch
-------------------------------------------------------------
Standard & Poor's Ratings Services placed its 'BB' rating on
Structured Repackaged Asset Backed Trust Securities Trust For
Sprint Capital Corp. Securities Series 2004-2's $38 million class
A-1 certificates on CreditWatch with negative implications.

The rating on class A-1 is dependent solely on the rating on the
underlying security, Sprint Capital Corp.'s 6.875% notes due
Nov. 15, 2028 ('BB/Watch Neg').

The CreditWatch placement reflects S&P's Nov. 11, 2009, placement
of the rating on the underlying security on CreditWatch with
negative implications.


TEXAS STATE: S&P Changes Outlook on 'C' Bond Rating to Negative
---------------------------------------------------------------
Standard & Poor's Ratings Services revised its 'C' underlying
rating outlook on Texas State Affordable Housing Corp.'s (American
Housing Foundation portfolio) $114 million multifamily housing
revenue bonds series 2002A bonds to negative from CreditWatch with
negative implications.  The bonds are credit enhanced by National
Public Finance Guaranty, formerly MBIA, and continues to have a
'A/Developing' long-term rating based on the bond insurance
policy, which remains in place for this issue.

The trustee, Wells Fargo Bank N.A., informed Standard & Poor's
that they drew $872,555.83 from the series 2002A debt service
reserve fund to make the Sept. 1, 2009, payment on the bonds.

As of Sept. 15, 2009, the series 2002A debt service reserve fund
had a balance of $0, below the $8,055,155 required pursuant to the
Trust Indenture.


TIGRIS CDO: Fitch Downgrades Ratings on Seven Classes of Notes
--------------------------------------------------------------
Fitch Ratings has downgraded and withdrawn the ratings of seven
classes of notes issued by Tigris CDO 2007-1, Ltd./LLC as a result
of liquidation of the portfolio.  The details of the rating action
follow at the end of this press release.

Tigris 2007-1 declared an event of default on Jan. 25, 2008 as a
result of the default in the payment of interest on the class S,
class A-2, and class B notes.  As a remedy to the EOD, the
majority of the controlling class directed the trustee to declare
the principal and accrued and unpaid interest of all of the notes
to be immediately due and payable.  Subsequently, the holders of
100% of the outstanding notes and preference shares exercised
their right to sell and liquidate the collateral.  The liquidation
proceeds were distributed in accordance with the liquidation
priority of payments on the final distribution dates of Sept. 24,
2009 and Nov. 16, 2009.

After the final distribution, the class A-1A note's ultimate
principal loss stands at 72.9% of its original balance of
$259 million.  The class A-1B, S, A-2, B, C, and D notes did not
receive any liquidation proceeds.

Tigris 2007-1 is a cash flow CDO that closed on March 15, 2007,
and was monitored by Harding Advisory LLC.  The portfolio was 100%
comprised of US structured finance collateralized debt obligations
of 2006 and 2007 vintage and 100% of the portfolio was considered
defaulted as per the transaction's governing documentation prior
to the liquidation.

Fitch has downgraded and withdrawn the ratings as indicated:

  -- $188,751,124.18 class A-1A notes downgraded to 'D' from
     'CC';

  -- $168,670,918.05 class A-1B notes downgraded to 'D' from
     'CC';

  -- $8,325,000 class S notes downgraded to 'D' from 'C';

  -- $40,560,073.64 class A-2 notes downgraded to 'D' from 'C';

  -- $88,330,827.04 class B notes downgraded to 'D' from 'C';

  -- $55,258,326.30 class C notes downgraded to 'D' from 'C';

  -- $99,780,421.93 class D notes downgraded to 'D' from 'C'.


TULSA HOUSING: Moody's Raises Ratings on Revenue Bonds From 'Ba1'
-----------------------------------------------------------------
Moody's Investors Service has upgraded $1,410,000 of outstanding
Tulsa Housing Assistance Corporation First Lien Revenue Bonds,
Refunding Series 2001A to Baa3 from Ba1.  The outlook on the bonds
has been changed to stable from negative.

The rating change is based upon new information supplied by the
Tulsa Housing Assistance Corporation regarding the performance of
the Murdock Villa property.  After the last rating action taken by
Moody's, the property managers provided additional disclosure on
the FY2007 and FY2008 audited financial statements for Murdock
Villa, as well as unaudited reports on the operating performance
of the property in 2009 which showed that the debt service
coverage of the project was stronger than originally disclosed.

                          Legal Security

The bonds are a special obligation of THAC.  Bonds are secured by
revenue derived from operations of the Murdock Villa property,
Section 8 HAP payments and funds pledged under the bond indenture.
Murdock Villa is a 144-unit, six-story apartment building located
in Tulsa, intended to be occupied by elderly and handicapped
tenants.

                        Credit Strengths

* High physical and economic occupancy rates for the past four
  fiscal years; vacancy expense constituted only 1.2% of rental
  revenue in fiscal year 2008

* The existence of a Rate Stabilization Fund, which can be drawn
  upon in the event of a debt service shortfall.  The trustee has
  not needed to draw any funds from the Rent Stabilization Fund to
  cover debt service.  Forty-five thousand dollars ($45,000) can
  be released to THAC from the rate stabilization fund annually if
  the property meets a 1.05x debt service coverage test.  This
  coverage test was not met in fiscal year 2007 or fiscal year
  2008 and as a result no funds were withdrawn.  The Trustee
  reports that the Rate Stabilization Fund currently has
  approximately $288,000.

* Strong REAC score of 92b as of August 2008

* Short time until bond maturity, on July 1, 2011

* Moody's-adjusted debt service coverage ratios of 1.04x (FY2008)
  and 1.08x (FY2007) are in line with other Baa3-rated Section 8 -
  subsidized bonds rated by Moody's with a comparable time to
  maturity

                        Credit Weaknesses

* Oversized principal payment at maturity intended to be funded by
  the Debt Service Reserve Fund; reliance on the Debt Service
  Reserve Fund to make the final debt service payment reduces the
  ability of the trustee to tap the debt service reserve to cover
  shortfalls while still meeting the final payment.

                             Outlook

The outlook on the bonds has been changed to stable from negative.
Based on a additional financial performance and operating
projections the creditworthiness of the bonds is expected to be
stable until maturity.

Key Statistics:

* Debt Outstanding: $1,410,000
* Bond Maturity: 7/1/2011
* HAP Maturity: 7/1/2011
* Debt Service Coverage (FY2008): 1.04x
* REAC: 92B
* Debt Service Reserve Fund Balance: $429,000

The last rating action for this program was taken on October 23,
2009, when the rating was changed to Ba1 from Baa3 and the outlook
was revised to negative from stable.


VERTICAL ABS: Fitch Downgrades Ratings on Three Classes of Notes
----------------------------------------------------------------
Fitch Ratings has downgraded three and affirmed three classes of
notes issued by Vertical ABS CDO 2006-2, Ltd./Corp. as a result of
continued credit deterioration in the portfolio since the last
review in August 2009.  The details of the rating action follow at
the end of this press release.

An event of default was declared on Nov. 9, 2009, as a result of
the default in the payment of interest on the class A1 and class
A2 notes.  Fitch rates these classes to the timely receipt of
interest and has therefore downgraded these classes to 'D' from
'CC'.  Noteholders had not given direction to accelerate the notes
or liquidate the portfolio at the time of this review.

The guaranteed investment certificate account, which is used to
cover losses from credit events, has been fully depleted.  To
cover ongoing credit events, class A-S1VF has been drawn in the
amount of $41.3 million as of the latest trustee report dated
Nov. 3, 2009.  The remaining unfunded portion of the class is
$193.4 million.  The notional balance of the portfolio assets
stands at $210 million and 90.8% of the portfolio is currently
rated 'CC' and lower.  Given the composition of the portfolio,
Fitch expects further drawdown of the class A-S1VF and no recovery
on the other classes of notes.

Although class A-S1VF is still receiving its commitment fee and
interest accruing on the drawn portion, the drawn amounts are
unlikely to be repaid, and therefore principal loss to this class
is inevitable.  Given the certainty of default to all classes of
notes, Fitch did not use its Structured Finance Portfolio Credit
Model or cash flow model analysis as described in Fitch's
respective criteria.

Vertical 2006-2 is a structured finance collateralized debt
obligation that closed on June 20, 2006 and is monitored by
Vertical Capital, LLC.  Presently 99% of the portfolio is composed
of residential mortgage-backed securities and 1% of U.S. SF CDOs.

Fitch has taken actions on these classes of Vertical 2006-2:

  -- $193,354,610 class A-S1VF notes downgraded to 'C' from 'CCC';
  -- $52,000,000 class A1 notes downgraded to 'D' from 'CC';
  -- $41,000,000 class A2 notes downgraded to 'D' from 'CC';
  -- $28,063,417 class A3 notes affirmed at 'C';
  -- $23,454,349 class B notes affirmed at 'C';
  -- $5,986,685 class C notes affirmed at 'C'.


WACHOVIA BANK: Moody's Affirms Ratings on Eight 2006-C28 Certs.
---------------------------------------------------------------
Moody's Investors Service affirmed the ratings of eight classes
and downgraded 16 classes of Wachovia Bank Commercial Mortgage
Securities Trust Commercial Mortgage Pass-Through Certificates,
Series 2006-C28.  The downgrades are due to higher expected losses
for the pool resulting from anticipated losses from specially
serviced and watchlisted loans and concerns about refinancing risk
associated with five-year loans approaching maturity in an adverse
environment.  Twenty-one loans, representing 16% of the pool,
mature within the next 24 months and have a Moody's stressed debt
service coverage ratio below 1.00X.

The affirmations are primarily due to key rating parameters,
including Moody's loan to value ratio, stressed DSCR and the
Herfindahl Index, remaining within acceptable ranges.

On August 11, 2009, Moody's placed 15 classes on review for
possible downgrade due to the credit uncertainty surrounding
Maguire Properties Inc., the sponsor of the Gas Company Loan (6%
of the pool) and anticipated losses from specially serviced and
watchlisted loans.  On November 12, 2009, Moody's placed the
mezzanine Aaa rated class of the transaction on review for
possible downgrade due to higher projected losses from specially
serviced loans.  This action concludes Moody's review of the
transaction.  The rating action is the result of Moody's on-going
surveillance of commercial mortgage backed securities
transactions.

As of the October 19, 2009 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$3.56 billion from $3.59 billion at securitization.  The
Certificates are collateralized by 208 mortgage loans ranging in
size from less than 1% to 6% of the pool, with the top ten loans
representing 42% of the pool.

Fifty-four loans, representing 26% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.  Not all loans on the
watchlist are delinquent or have significant issues.

The pool has not experienced any losses since securitization.
Nine loans, representing 4% of the pool, are currently in special
servicing.  The largest specially serviced loan is the Cross
Island Plaza ($26.1 million -- 1% of the pool), which is secured
by a 221,758 square foot office building in Rosedale, NY.  The
loan was transferred to special servicing in November 2008 and is
currently in foreclosure.

Of the remaining eight specially serviced loans, two are 90+ days
delinquent and six are either real estate owned (REO) or in the
process of foreclosure.  Moody's estimates an aggregate loss for
all the specially serviced loans of $63.6 million (48% loss
severity on average).

Moody's was provided with full-year 2008 operating results for 98%
of the pool.  Moody's weighted average LTV ratio, excluding
specially serviced loans, is 134% compared to 140% at Moody's
prior review in February 2009.  Moody's prior review was part of
the first quarter 2009 ratings sweep of 2006-2007 vintage conduit
and fusion CMBS transactions.

Moody's stressed DSCR is 0.84X compared to 0.89X at last review.
Moody's stressed DSCR is based on Moody's net cash flow and a
9.25% stressed rate applied to the loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf is 40.  The pool
has a Herf of 41 compared to 43 at last review.

The four largest loans represent 22% of the pool.  The largest
loan is the Gas Company Tower loan ($229.0 million -- 6.4% of the
pool), which represents a pari passu interest in a $458.0 million
first mortgage loan.  The loan is secured by a 1.3 million square
foot Class A office building located in downtown Los Angeles,
California.  The property was 95% occupied as of June 2009,
essentially the same as at securitization.  The largest tenant is
Southern California Gas Company, which occupies 43% of the
premises through November 2011.  The sponsor is Maguire.  Although
performance has been stable, Moody's is concerned about lease
rollover exposure within the next three years, given the softness
of the Los Angeles office market.  Moody's is also concerned about
Maquire's ability to fund tenant costs due to its current
financial issues.  Moody's LTV and stressed DSCR are 156% and
0.61X, respectively, compared to 137% and 0.71X at last review.

The second largest loan is the 1180 Peachtree St. Loan
($193.9 million -- 5% of the pool), which is secured by a 669,711
square foot office building located in Atlanta, Georgia.  The
property was 92% occupied as of June 2009 compared to 91% at last
review.  The largest tenant is King & Spalding, which occupies 64%
of the premises through March 2021.  Moody's LTV and stressed DSCR
are 129% and 0.77X, respectively, compared to 155% and 0.64X at
last review.

The third largest loan is the Montclair Plaza Loan ($190.0 million
-- 5% of the pool), which is secured by an 875,085 square foot
regional mall located in Montclair, California.  The property was
85% occupied as of June 2009 compared to 87% at last review.  The
center is anchored by Macy's, Sears and JCPenney.  Recent
performance has been impacted by a decline in occupancy.  Circuit
City and Linen N'Things, previously the second and third largest
tenants, vacated the center in 2008 due to their bankruptcy.
Moody's LTV and stressed DSCR are 111% and 0.87X, respectively
compared to 84% and 1.20X at last review.

The fourth largest loan is the Four Seasons Resort and Club Loan
($175.0 million -- 5% of the pool), which is secured by a 357
room, full service hotel located in Irving, Texas.  Occupancy and
revenue per available room for the trailing 12 month period ending
June 2009 were 54% and $133, respectively, compared to 65% and
$177 for 2008 and 75% and $185 at securitization.  The property is
operating below Moody's original projections because of declines
in tourist and business travel due to the economic recession.
Moody's is concerned that this loan represents a significant
default risk because of poor performance.  The high-end luxury
hotel market has been particularly hard hit during the economic
recession and is not expected to recover in the short term.
Moody's LTV and stressed DSCR are in excess of 200% and 0.42X,
respectively, compared to 185% and 0.63X at last review.

Moody's rating action is:

  -- Class A-1, $18,786,189, affirmed at Aaa; previously assigned
     at Aaa on 1/22/2007

  -- Class A-2, $418,676,000, affirmed at Aaa; previously assigned
     at Aaa on 1/22/2007

  -- Class A-PB, $168,389,000, affirmed at Aaa; previously
     assigned at Aaa on 1/22/2007

  -- Class A-3, $215,000,000, affirmed at Aaa; previously assigned
     at Aaa on 1/22/2007

  -- Class A-4, $802,246,000, affirmed at Aaa; previously assigned
     at Aaa on 1/22/2007

  -- Class A-4FL, $250,000,000, affirmed at Aaa; previously
     assigned at Aaa on 1/22/2007

  -- Class A-1A, $613,021,047, affirmed at Aaa; previously
     assigned at Aaa on 1/22/2007

  -- Class IO, Notional, affirmed at Aaa; previously assigned at
     Aaa on 1/22/2007

  -- Class A-M, $359,520,000, downgraded to Aa2 from Aaa; placed
     on review for possible downgrade on 11/12/2009

  -- Class A-J, $278,628,000, downgraded to Baa1 from A1; placed
     on review for possible downgrade on 8/11/2009

  -- Class B, $22,470,000, downgraded to Baa3 from A2; placed on
     review for possible downgrade on 8/11/2009

  -- Class C, $58,422,000, downgraded to Ba3 from A3; placed on
     review for possible downgrade on 8/11/2009

  -- Class D, $31,458,000, downgraded to B3 from Baa1; placed on
     review possible downgrade on 8/11/2009

  -- Class E, $49,433,000, downgraded to Caa1 from Baa3; placed on
     review for possible downgrade on 8/11/2009

  -- Class F, $40,446,000, downgraded to Caa2 from Ba1; placed on
     review for possible downgrade on 8/11/2009

  -- Class G, $40,446,000, downgraded to Caa3 from Ba3; placed on
     review for possible downgrade on 8/11/2009

  -- Class H, $40,446,000, downgraded to Ca from B2; placed on
     review for possible downgrade on 8/11/2009

  -- Class J, $44,940,000, downgraded to Ca from B3; placed on
     review for possible downgrade on 8/11/2009

  -- Class K, $17,976,000, downgraded to Ca from Caa2; placed on
     review for possible downgrade on 8/11/2009

  -- Class L, $8,988,000, downgraded to C from Caa2; placed on
     review for possible downgrade on 8/11/2009

  -- Class M, $13,482,000, downgraded to C from Caa3; placed on
     review for possible downgrade on 8/11/2009

  -- Class N, $4,494,000, downgraded to C from Caa3; placed on
     review for possible downgrade on 8/11/2009

  -- Class O, $8,988,000, downgraded to C from Caa3; placed on
     review for possible downgrade on 8/11/2009

  -- Class P, $8,988,000, downgraded to C from Caa3; placed on
     review for possible downgrade on 8/11/2009


WASHINGTON MUTUAL: Moody's Upgrades Ratings on 10 Securities
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on 10 classes
of credit card receivable-backed securities issued through the
Washington Mutual Master Note Trust.  These securities are backed
by approximately $6.3 billion of consumer credit card receivables
originated and serviced by Chase Bank USA, NA, and its affiliates.

                            Rationale

This ratings action is prompted by marked improvement in Moody's
expectations for the WMMNT's collateral performance following the
May 19 removal of legacy receivables originated by Washington
Mutual.  The WMMNT's collateral is now entirely comprised of
receivables originated by Chase, which have demonstrably better
performance and credit attributes than the legacy, WaMu-originated
receivables.  In addition, when compared to the notes currently
outstanding from Chase trusts of similar collateral composition,
the senior notes issued from the WMMNT have substantially higher
levels of credit enhancement from subordination.

Specifically, compared to the legacy WaMu collateral, the Chase-
originated collateral exhibits both significantly lower charge-off
rates and a higher principal payment rate, while having lower
yield.  The Chase-originated collateral also has a lower
percentage of sub-prime obligors and lower percentages of
cardholders residing in California and Florida.

In recent months, the yield and principal payment rate for the
WMMNT have been similar to those of the collateral in other trusts
that are originated and serviced by Chase.  The charge-off rate
for the WMMNT has been substantially lower than other Chase
trusts, but Moody's expect this performance differential to narrow
as the WMMNT receivables age.  These Chase-originated receivables
are expected to perform similarly to the portfolios backing other
Chase trusts.  In fact, Moody's performance expectations for the
WMMNT are identical to those for the Chase Credit Card Master
Trust.

Furthermore, because the WMMNT portfolio was initially comprised
of much weaker collateral, it has a considerably stronger capital
structure compared to Chase's other credit card trusts.  For
example, the WMMNT Class A notes have 27% subordination, while the
Chase Credit Card Master Trust and Chase Issuance Trust have 16%
and 14%, respectively.

Moody's current performance expectations for the WMMNT are for the
net charge-off rate to stabilize in the range of 9.5% - 12.5%
(previously 13% - 15%), the principal payment rate to be in the
range of 13% - 16% (previously 7% - 9%), and the trust yield in
the range of 12.5% - 15.5% (previously 19% -22%).  Moody's revised
expectations reflect the better credit quality and performance of
the Chase originated credit card receivables relative to legacy
WaMu collateral.

               Loss Of Sale Treatment For The Trust

The May 19 removal of WaMu accounts precludes sale accounting
treatment for the WMMNT's ABS, which has negative implications for
the securitized assets in the highly unlikely event that Chase
goes into receivership.

According to the Statement of Financial Accounting Standards No.
140, issuers are not permitted to initiate unilateral, non-random
removals of accounts without jeopardizing sale accounting
treatment.  Without sale accounting treatment, the WMMNT will not
qualify for the FDIC's safe harbor protections from the
repudiation of securitization contracts (rule 12 CFR Section
360.6).  In order to qualify for the safe harbor protection,
certain conditions must be met -- chief among them is that the
transfer of assets meets all conditions for sale accounting
treatment.  Without sale accounting treatment, there is no longer
the same level of assurance that in the unlikely event that Chase
goes into receivership, the FDIC, as receiver, will not exercise
its power to repudiate the securitization contracts.

Given Chase's considerable credit strength (Aa1/P-1/C-), the
likelihood of receivership is very remote.  Therefore, despite the
lack of protection from an FDIC repudiation, Moody's believe that
the incremental credit risk to the WaMu ABS is exceptionally
small.  Nevertheless, the incremental risk amplifies the linkages
between the ratings of Chase and those of the WMMNT notes.

The complete rating actions are:

Issuer: Washington Mutual Master Note Trust

Ratings Upgraded

  -- $750,000,000 Floating Rate Class 2006-A2 Asset Backed Notes,
     upgraded to Aaa from A1; previously on May 21, 2009, ratings
     placed on review for possible upgrade

  -- $200,000,000 Floating Rate Class 2006-C1 Asset Backed Notes,
     upgraded to A3 from Ba2; previously on May 21, 2009, ratings
     placed on review for possible upgrade

  -- $150,000,000 Floating Rate Class 2006-C2 Asset Backed Notes,
     upgraded to A3 from Ba2; previously on May 21, 2009, ratings
     placed on review for possible upgrade

  -- $1,100,000,000 Floating Rate Class 2007-A1 Asset Backed
     Notes, upgraded to Aaa from A1; previously on May 21, 2009,
     ratings placed on review for possible upgrade

  -- $875,000,000 Floating Rate Class 2007-A2 Asset Backed Notes,
     upgraded to Aaa from A1; previously on May 21, 2009, ratings
     placed on review for possible upgrade

  -- $425,000,000 Fixed Rate Class 2007-A4 Asset Backed Notes,
     upgraded to Aaa from A1; previously on May 21, 2009, ratings
     placed on review for possible upgrade

  -- $200,000,000 Floating Rate Class 2007-A5 Asset Backed Notes,
     upgraded to Aaa from A1; previously on May 21, 2009, ratings
     placed on review for possible upgrade

  -- $150,000,000 Fixed Rate Class 2007-B1 Asset Backed Notes,
     upgraded to Aa1 from Baa3; previously on May 21, 2009,
     ratings placed on review for possible upgrade

  -- $125,000,000 Floating Rate Class 2007-C1 Asset Backed Notes,
     upgraded to A3 from Ba2; previously on May 21, 2009, ratings
     placed on review for possible upgrade

  -- Class 2005-D2 Variable Funding Asset Backed Notes, upgraded
     to Ba2 from B3; previously on May 21, 2009, ratings placed on
     review for possible upgrade

Chase, based in Newark, Delaware, reported total assets of
$92.7 billion as of June 30, 2009.  Chase's long-term bank
deposits are rated Aa1 and its Bank Financial Strength rating is
C-.  The rating outlook on all ratings is negative.


* Moody's Downgrades Ratings on 14 Tranches From 10 US SF CDOs
--------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of 14 tranches contained within 10 US Structured Finance
CDOs.  The tranches affected by the actions are from CDOs that
have experienced an Event of Default and in each case the Trustee
has been directed to liquidate the collateral as a post-event-of-
default remedy.  Moody's has been notified by the respective
Trustee in each of these cases that a final distribution of
liquidation proceeds has taken place (except for retention of a
small amount of residual funds in certain cases).

The rating actions taken reflect the final liquidation
distribution and are indicative of the loss given default
associated with the downgraded tranches.

Issuer: Arca Funding 2006-I, Ltd.

  -- US$99,500,000 Class II Funded Senior Notes Due 2046,
     Downgraded to C; previously on April 7, 2008 Downgraded to Ca

  -- US$59,500,000 Class III Funded Senior Notes Due 2046,
     Downgraded to C; previously on April 7, 2008 Downgraded to Ca

  -- US$17,000,000 Class IV Funded Senior Notes Due 2046,
     Downgraded to C; previously on April 7, 2008 Downgraded to Ca

Issuer: Athos Funding, Ltd.

  -- US$40,000,000 Class A-1 Floating Rate Notes Due 2043,
     Downgraded to C; previously on December 17, 2008 Downgraded
     to Ca

  -- US$28,000,000 Class A-2 Floating Rate Notes Due 2043,
     Downgraded to C; previously on June 11, 2008 Downgraded to Ca

Issuer: Kent Funding, Ltd.

  -- US$60,000,000 Class A-1 Notes, Downgraded to C;
     previously on April 24, 2009 Downgraded to Ca

Issuer: Kleros Preferred Funding VI, Ltd.

  -- US$1,000,000,000 Class A-1S-1A First Priority Senior Secured
     Delayed Draw Floating Rate Notes due May 2047, Downgraded to
     C; previously on September 23, 2008 Downgraded to Ca

  -- US$1,400,000,000 Class A-1S-1B First Priority Senior Secured
     Floating Rate Notes due May 2047, Downgraded to C; previously
     on September 23, 2008 Downgraded to Ca

Issuer: LOCHSONG, LTD.

  -- US$ 12,100,000 Class S Floating Rate Notes Due 2010,
     Downgraded to C; previously on April 24, 2009 Downgraded to
     Ca

Issuer: Longshore CDO Funding 2006-2, Ltd.

  -- US$870,000,000 Class A-1 Floating Rate Notes Due 2046,
     Downgraded to C; previously on September 23, 2008 Downgraded
     to Ca

Issuer: Raffles Place II Funding, Ltd.

  -- US$600,000,000 Class A1M Floating Rate Notes Due 2047,
     Downgraded to C; previously on September 23, 2008 Downgraded
     to Ca

Issuer: Scorpius CDO, Ltd.

  -- US$975,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Notes due November 2046, Downgraded to C;
     previously on September 23, 2008 Downgraded to Ca

Issuer: TOPANGA CDO, LTD.

  -- US$49,000,000 Class A-1 Floating Rate Senior Secured Notes
     Due 2045, Downgraded to C; previously on April 24, 2009
     Downgraded to Ca

Issuer: Tierra Alta Funding I, Ltd.

  -- Class F Notes, Downgraded to C; previously on April 24, 2009
     Downgraded to Ca


* Moody's Reviews Ratings on 16 Tranches From Seven Trust CDOs
--------------------------------------------------------------
Moody's has placed on review for possible downgrade 16 tranches
across seven Trust Preferred CDOs.  The review for downgrade is
prompted by the exposure of these TRUP CDOs to trust preferred or
subordinated debt issued by real estate investment trusts, real
estate operating companies, homebuilders, commercial mortgage
backed securities, and real estate related loans which are
currently underperforming.  According to Moody's, the rating
actions taken on the notes are the result of larger than
anticipated par loss and credit deterioration in the collateral
pools since April 2009.

Moody's last rating action took place in April 2009 as a result of
continued weak economic conditions that have led to increased
expectations of asset defaults and interest deferrals and reduced
recovery prospects for mortgage REITs and homebuilders.  Since
then, the credit fundamentals for the REITs sector continued to be
challenging and Mood's expects that it will remain so at least in
the near term.

In addition, due to par loss these deals' coverage tests failure
have worsened, according to the trustee reports.  Furthermore, the
transactions are negatively impacted by a large pay-fixed,
receive-floating interest rate swap where payments to the hedge
counterparty are absorbing a large portion of the excess spreads
in the deal.  Moody's anticipates that the burden of making hedge
payment over the remaining life of these transactions will
significantly reduce the amount of cash available to pay senior
notes and put the ultimate payments of principal on these notes at
significant risk.

Moody's notes that the data contained in the latest trustee
reports suggest that some of these transactions may declare an
Event of Default due to failure to pay interest to the senior
notes.  Currently, four transactions are on EOD including Attentus
CDO II, Ltd, Taberna Preferred Funding III, Ltd, Taberna Preferred
Funding IV, Ltd, and Taberna Preferred Funding VI, Ltd.

In connection with placing the notes under review for possible
downgrade, Moody's will evaluate these transactions to quantify
the impact of each one of these factors to determine the credit
risk of the rated notes.

Attentus CDO II, Ltd.

  -- US$60,000,000 Class A-2 Second Priority Senior Secured
     Floating Rate Notes Due 2041, placed on review for possible
     downgrade; previously on 4/09/2009 downgraded to B3

  -- US$55,000,000 Class A-3A Third Priority Senior Secured
     Floating Rate Notes Due 2041, placed on review for possible
     downgrade; previously on 4/09/2009 downgraded to Caa2

  -- US$5,000,000 Class A-3B Third Priority Senior Secured
     Floating Rate Notes Due 2041, placed on review for possible
     downgrade; previously on 4/09/2009 downgraded to Caa2

Taberna Preferred Funding III, Ltd.

  -- Class A-1a, placed on review for possible downgrade;
     previously on 4/09/2009 downgraded to Ba1

  -- Class A-1b, placed on review for possible downgrade;
     previously on 4/09/2009 downgraded to Ba1

  -- Class A-1c, placed on review for possible downgrade;
     previously on 4/09/2009 downgraded to Ba1

Taberna Preferred Funding Iv, Ltd.

  -- Class A-1, placed on review for possible downgrade;
     previously on 4/09/2009 downgraded to Ba1

Taberna Preferred Funding VI, Ltd.

  -- Class A-1A, placed on review for possible downgrade;
     previously on 4/09/2009 downgraded to Ba2

  -- Class A-1B, placed on review for possible downgrade;
     previously on 4/09/2009 downgraded to Ba2

Taberna Preferred Funding VII, Ltd.

  -- US$350,000,000 Class A-1LA Floating Rate Notes Due February
     2037, placed on review for possible downgrade; previously on
     4/09/2009 downgraded to Ba2

Taberna Preferred Funding VIII, Ltd.

  -- US$160,000,000 Class A-1A First Priority Delayed Draw Senior
     Secured Floating Rate Notes Due 2037, placed on review for
     possible downgrade; previously on 4/09/2009 downgraded to Ba1

  -- US$215,000,000 Class A-1B First Priority Senior Secured
     Floating Rate Notes Due 2037, placed on review for possible
     downgrade; previously on 4/09/2009 downgraded to Ba1

  -- US$120,000,000 Class A-2 Second Priority Senior Secured
     Floating Rate Notes Due 2037, placed on review for possible
     downgrade; previously on 4/09/2009 downgraded to Ba3

Taberna Preferred Funding IX, Ltd.

  -- US$275,000,000 Class A-1LA Floating Rate Notes Due May 2038,
     placed on review for possible downgrade; previously on
     4/09/2009 downgraded to Ba1

  -- US$100,000,000 Class A 1LAD Delayed Draw Floating Rate Notes
     Due May 2038, placed on review for possible downgrade;
     previously on 4/09/2009 downgraded to Ba1


* Moody's Withdraws Ratings on 159 Classes of Notes by 20 SF CDOs
-----------------------------------------------------------------
Moody's Investors Service announced that it has withdrawn the
ratings of 159 classes of notes issued by 20 structured finance
CDO transactions.  The tranches affected by the actions are from
CDOs that have experienced an Event of Default.  In each case the
Trustee has been directed to liquidate the collateral as a post-
event-of-default remedy.  Moody's has been notified by the
respective Trustee in each case that a final distribution of
liquidation proceeds has taken place (except for retention of a
small amount of residual funds in certain cases).

Arca Funding 2006-I, Ltd.

  -- US$99,500,000 Class II Funded Senior Notes Due 2046,
     Withdrawn; previously on November 20, 2009 Downgraded to C

  -- US$59,500,000 Class III Funded Senior Notes Due 2046,
     Withdrawn; previously on November 20, 2009 Downgraded to C

  -- US$17,000,000 Class IV Funded Senior Notes Due 2046,
     Withdrawn; previously on November 20, 2009 Downgraded to C

  -- US$17,000,000 Class V Funded Mezzanine Notes Due 2046,
     Withdrawn; previously on April 7, 2008 Downgraded to C

  -- US$17,000,000 Class VI Funded Mezzanine Notes Due 2046,
     Withdrawn; previously on April 7, 2008 Downgraded to C

  -- US$7,000,000 Class VII Funded Mezzanine Notes Due 2046,
     Withdrawn; previously on April 7, 2008 Downgraded to C

  -- US$7,000,000 Class VIII Funded Mezzanine Notes Due 2046,
     Withdrawn; previously on April 7, 2008 Downgraded to C

Athos Funding, Ltd.

  -- US$40,000,000 Class A-1 Floating Rate Notes Due 2043,
     Withdrawn; previously on November 20, 2009 Downgraded to C

  -- US$28,000,000 Class A-2 Floating Rate Notes Due 2043,
     Withdrawn; previously on November 20, 2009 Downgraded to C

  -- US$20,000,000 Class B Floating Rate Subordinate Notes Due
     2043, Withdrawn; previously on June 11, 2008 Downgraded to C

  -- US$5,000,000 Class Q Combination Notes Due 2043,
     Withdrawn; previously on June 11, 2008 Downgraded to C

Aurelius Capital CDO 2007-1 Limited

  -- US$240,300,000 Class A Loan due 2052, Withdrawn;
     previously on October 21, 2009 Downgraded to Ca

  -- US$15,200,000 Class C Secured Floating Rate Deferrable
     Interest Notes due 2052, Withdrawn; previously on October 21,
     2009 Downgraded to C

  -- US$18,000,000 Class D Secured Floating Rate Deferrable
     Interest Notes due 2052, Withdrawn; previously on October 21,
     2009 Downgraded to C

  -- US$13,500,000 Class E Secured Floating Rate Deferrable
     Interest Notes due 2052, Withdrawn; previously on October 21,
     2009 Downgraded to C

Halcyon Securitized Products Investors ABS CDO I Ltd.

  -- US$236,400,000 Class A-1 Senior Secured Floating Rate
     Notes, due 2050, Withdrawn; previously on April 22, 2009
     Downgraded to C

  -- US$76,000,000 Class A-2 Senior Secured Floating Rate
     Notes, due 2050, Withdrawn; previously on April 22, 2009
     Downgraded to C

  -- US$28,400,000 Class B Senior Secured Floating Rate Notes,
     due 2050, Withdrawn; previously on April 22, 2009 Downgraded
     to C

  -- US$19,600,000 Class C Senior Secured Deferrable Interest
     Floating Rate Notes, due 2050, Withdrawn; previously on
     May 18, 2008 Downgraded to C

  -- US$19,600,000 Class D Senior Secured Deferrable Interest
     Floating Rate Notes, due 2050, Withdrawn; previously on
     May 18, 2008 Downgraded to C

  -- US$4,000,000 Class EClass E Senior Secured Deferrable
     Interest Floating Rate Notes, due 2050, Withdrawn; previously
     on May 18, 2008 Downgraded to C

Ischus High Grade Funding I, Ltd.

  -- US$1,041,500,000 Class A1S, Withdrawn; previously on
     April 22, 2009 Downgraded to Ca

  -- US$85,000,000 Class A1J, Withdrawn; previously on
     April 22, 2009 Downgraded to C

  -- US$17,000,000 Class A2Class A2, Withdrawn; previously on
     April 22, 2009 Downgraded to C

  -- US$30,500,000 Class A3, Withdrawn; previously on
     October 20, 2008 Downgraded to C

  -- US$12,500,000 Class B, Withdrawn; previously on
     October 20, 2008 Downgraded to C

  -- US$3,000,000 Class C, Withdrawn; previously on October 20,
     2008 Downgraded to C

  -- US$5,000,000 Class X Combination Securities, Withdrawn;
     previously on March 15, 2006 Assigned Aaa

Kent Funding, Ltd.

  -- US$60,000,000 Class A-1 Notes, Withdrawn; previously on
     November 20, 2009 Downgraded to C

  -- US$15,000,000 Class A-2 Notes, Withdrawn; previously on
     April 24, 2009 Downgraded to C

  -- US$18,500,000 Class B Notes, Withdrawn; previously on
     October 28, 2008 Downgraded to C

  -- US$900,000,000 Funding Notes, Withdrawn; previously on
     April 24, 2009 Downgraded to Ca

Kleros Preferred Funding VI, Ltd.

  -- US$1,000,000,000 Class A-1S-1A First Priority Senior
     Secured Delayed Draw Floating Rate Notes due May 2047,
     Withdrawn; previously on November 20, 2009 Downgraded to C

  -- US$1,400,000,000 Class A-1S-1B First Priority Senior
     Secured Floating Rate Notes due May 2047, Withdrawn;
     previously on November 20, 2009 Downgraded to C

  -- US$300,000,000 Class A-1S-2 Second Priority Senior Secured
     Floating Rate Notes due May 2047, Withdrawn; previously on
     September 23, 2008 Downgraded to C

  -- US$169,500,000 Class A-1J Third Priority Senior Secured
     Floating Rate Notes due May 2047, Withdrawn; previously on
     September 23, 2008 Downgraded to C

  -- US$56,000,000 Class A-2 Fourth Priority Senior Secured
     Floating Rate Notes due May 2047, Withdrawn; previously on
     September 23, 2008 Downgraded to C

  -- US$27,500,000 Class A-3 Fifth Priority Senior Secured
     Deferrable Floating Rate Notes due May 2047, Withdrawn;
     previously on May 30, 2008 Downgraded to C

  -- US$32,000,000 Class B Sixth Priority Deferrable Senior
     Secured Floating Rate Notes due May 2047, Withdrawn;
     previously on May 30, 2008 Downgraded to C

LOCHSONG, LTD.

  -- US$12,100,000 Class S Floating Rate Notes Due 2010,
     Withdrawn; previously on November 20, 2009 Downgraded to C

  -- US$1,032,000,000 Notional Outstanding Amount Senior Swap,
     Withdrawn; previously on April 24, 2009 Downgraded to C

  -- US$18,000,000 Class A Floating Rate Notes Due 2046,
     Withdrawn; previously on April 24, 2009 Downgraded to C

  -- US$78,000,000 Class B Floating Rate Notes Due 2046,
     Withdrawn; previously on September 3, 2008 Downgraded to C

  -- US$24,000,000 Class C Floating Rate Deferrable Notes Due
     2046, Withdrawn; previously on September 3, 2008 Downgraded
     to C

  -- US$27,000,000 Class D Floating Rate Deferrable Notes Due
     2046, Withdrawn; previously on September 3, 2008 Downgraded
     to C

  -- US$4,500,000 Class E Floating Rate Deferrable Notes Due
     2046, Withdrawn; previously on June 4, 2008 Downgraded to C

Le Monde CDO I PLC

  -- US$120,000,000 Class A-1US Variable Funding Dollar Notes
     Due 2052, Withdrawn; previously on April 22, 2009 Downgraded
     to Ca

  -- US$80,000,000 and EUR69,500,000 Class A-1R Redenominatable
     Floating Rate Notes Due 2052, Withdrawn; previously on
     April 22, 2009 Downgraded to Ca

  -- US$604,250,000 Class A-2US Floating Rate Dollar Notes Due
     2052, Withdrawn; previously on April 22, 2009 Downgraded to
     Ca

  -- EUR360,000,000 Class A-3EU Floating Rate Euro Notes Due 2052,
     Withdrawn; previously on April 22, 2009 Downgraded to Ca

  -- US$62,500,000 Class A-4 Floating Rate Dollar Notes Due
     2052, Withdrawn; previously on April 22, 2009 Downgraded to C

  -- US$30,750,000 Class B Floating Rate Dollar Notes Due 2052,
     Withdrawn; previously on April 22, 2009 Downgraded to C

  -- US$22,500,000 Class C Deferrable Floating Rate Dollar
     Notes Due 2052, Withdrawn; previously on April 22, 2009
     Downgraded to C

  -- US$17,500,000 Class D Deferrable Floating Rate Dollar
     Notes Due 2052, Withdrawn; previously on April 22, 2009
     Downgraded to C

  -- US$3,000,000 Class E Subordinated Deferrable Floating Rate
     Dollar Notes Due 2052, Withdrawn; previously on April 22,
     2009 Downgraded to C

  -- US$803,119,000 Class A-2MML - US Floating Rate Dollar
     Notes Due 2052, Withdrawn; previously on May 11, 2009
     Assigned Ca

  -- US$152,974,000 Class A-3MML - US Floating Rate Dollar
     Notes Due 2052, Withdrawn; previously on May 11, 2009
     Assigned Ca

Liberty Harbour II CDO Ltd.

  -- US$168,000,000 Class A-1 Secured Floating Rate Notes Due
     2051, Withdrawn; previously on May 28, 2008 Downgraded to C

  -- US$50,000,000 Class A-2 Secured Floating Rate Notes Due
     2051, Withdrawn; previously on May 28, 2008 Downgraded to C

  -- US$27,000,000 Class B Secured Floating Rate Notes Due
     2051, Withdrawn; previously on May 28, 2008 Downgraded to C

  -- US$17,000,000 Class C Deferrable Floating Rate Notes Due
     2051, Withdrawn; previously on May 28, 2008 Downgraded to C

  -- US$30,000,000 Rate Swap Due 2016 (Swap ID# 1640617B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$30,000,000 Rate Swap Due 2016 (Swap ID# 1640585B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$30,000,000 Rate Swap Due 2016 (Swap ID# 1640547B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$20,000,000 Rate Swap Due 2016 (Swap TDt 1643235B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$22,500,000 Rate Swap Due 2015 (Swap ID# 16432118),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$30,000,000 Rate Swap Due 2017 (Swap ID# 1643202B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$16,500,000 Rate Swap Due 2016 (Swap ID# 16431738),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$50,000,000 Rate Swap Due 2016 (Swap ID# 1640592B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$15,000,000 Rate Swap Due 2015 (Swap ID# 1643227B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$24,000,000 Rate Swap Due 2016 (Swap ID# 16432953),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$30,000,000 Rate Swap Due 2017 (Swap ID# 1643199B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$40,000,000 Rate Swap Due 2016 (Swap ID# 1640612B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$30,000,000 Rate Swap Due 2016 (Swap ID# 1640607B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$40,000,000 Rate Swap Due 2016 (Swap ID# 16406033),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$44,000,000 Rate Swap Due 2016 (Swap 1D# 1640625B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$25,000,000 Rate Swap Due 2016 (Swap ID# 16406318),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$30,000,000 Rate Swap Due 2016 (Swap ID# 1640714B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$30,000,000 Rate Swap Due 2016 (Swap IDtt 1640629B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$21,000,000 Rate Swap Due 2016 (Swap ID# 1640578B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$50,000,000 Rate Swap Due 2016 (Swap ID# 16433248),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$50,000,000 Rate Swap Due 2016 (Swap ID# 1643341B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$50,000,000 Rate Swap Due 2016 (Swap ID# 16433123),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$14,795,000 Rate Swap Due 2015 (Swap ID# 1643303B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$10,000,000 Rate Swap Due 2015 (Swap TDtt 1643300B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$15,000,000 Rate Swap Due 2016 (Swap ID# 16432393),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$13,500,000 Rate Swap Due 2017 (Swap ID# 1813449B),
     Withdrawn; previously on August 29, 2008 Assigned A1

  -- US$20,000,000 Rate Swap Due 2016, Withdrawn; previously on
     August 29, 2008 Assigned A1

  -- US$17,300,000 Pre-Paid Swap Due 2017, Withdrawn;
     previously on September 8, 2009 Downgraded to C

Long Hill 2006-1 CDO, Ltd

  -- US$410,000,000 Class A-S1VF Notes, Withdrawn; previously
     on August 31, 2009 Downgraded to C

  -- US$125,000,000 Class A-S2T Notes, Withdrawn; previously on
     August 31, 2009 Downgraded to C

  -- US$40,000,000 Class A1 Notes, Withdrawn; previously on
     February 4, 2009 Downgraded to C

  -- US$140,000,000 Class A2 Notes, Withdrawn; previously on
     February 4, 2009 Downgraded to C

  -- US$28,000,000 Class A3 Notes, Withdrawn; previously on
     May 9, 2008 Downgraded to C

  -- US$25,000,000 Class B Notes, Withdrawn; previously on
     May 9, 2008 Downgraded to C

  -- US$5,000,000 Class C Notes, Withdrawn; previously on
     May 9, 2008 Downgraded to C

Longshore CDO Funding 2006-2, Ltd.

  -- US$870,000,000 Class A-1 Floating Rate Notes Due 2046,
     Withdrawn; previously on November 20, 2009 Downgraded to C

  -- US$60,000,000 Class A-2 Floating Rate Notes Due 2046,
     Withdrawn; previously on September 23, 2008 Downgraded to C

  -- US$42,000,000 Class B Floating Rate Notes Due 2046,
     Withdrawn; previously on September 23, 2008 Downgraded to C

  -- US$8,000,000 Class C-1 Floating Rate Deferrable Interest
     Notes Due 2046, Withdrawn; previously on May 30, 2008
     Downgraded to C

  -- US$5,000,000 Class C-2 Floating Rate Deferrable Interest
     Notes Due 2046, Withdrawn; previously on May 30, 2008
     Downgraded to C

  -- US$7,500,000 Class D Floating Rate Deferrable Interest
     Notes Due 2046, Withdrawn; previously on May 30, 2008
     Downgraded to C

  -- US$7,500,000 Preference Shares, Withdrawn; previously on
     May 30, 2008 Downgraded to C

Marathon Structured Finance CDO I, Ltd.

  -- US$30,000,000 Class A-1 Floating Rate Delayed Draw Notes
     Due 2046, Withdrawn; previously on July 20, 2009 Downgraded
     to Ca

  -- US$128,000,000 Class A-1 Floating Rate Term Notes Due
     2046, Withdrawn; previously on July 20, 2009 Downgraded to Ca

  -- US$18,000,000 A-2 Floating Rate Notes Due 2046, Withdrawn;
     previously on July 20, 2009 Downgraded to C

  -- US$63,000,000 Class B Floating Rate Notes Due 2046,
     Withdrawn; previously on July 20, 2009 Downgraded to C

  -- US$15,000,000 Class C Deferrable Floating Rate Notes Due
     2046, Withdrawn; previously on March 10, 2009 Downgraded to C

  -- US$22,900,000 Class D Deferrable Floating Rate Notes Due
     2046, Withdrawn; previously on March 10, 2009 Downgraded to C

  -- US$17,000,000 Class E Deferrable Floating Rate Notes Due
     2046, Withdrawn; previously on May 30, 2008 Downgraded to C

Raffles Place II Funding, Ltd.

  -- US$600,000,000 Class A1M Floating Rate Notes Due 2047,
     Withdrawn; previously on November 20, 2009 Downgraded to C

  -- US$260,000,000 Class A1Q Floating Rate Notes Due 2047,
     Withdrawn; previously on September 23, 2008 Downgraded to C

  -- US$40,000,000 Class A2 Floating Rate Notes Due 2047,
     Withdrawn; previously on June 4, 2008 Downgraded to C

  -- US$40,000,000 Class A3 Floating Rate Notes Due 2047,
     Withdrawn; previously on June 4, 2008 Downgraded to C

  -- US$40,000,000 Class A4 Floating Rate Notes Due 2047,
     Withdrawn; previously on June 4, 2008 Downgraded to C

STACK 2006-2 Ltd.

  -- US$585,000,000 Class I Supersenior Swap, Withdrawn;
     previously on February 26, 2009 Downgraded to C

  -- US$75,000,000 Class II Senior Floating Rate Notes Due
     2047, Withdrawn; previously on February 26, 2009 Downgraded
     to C

  -- US$105,000,000 Class III Senior Floating Rate Notes Due
     2047, Withdrawn; previously on February 26, 2009 Downgraded
     to C

  -- US$21,000,000 Class IV Senior Floating Rate Notes Due
     2047, Withdrawn; previously on February 26, 2009 Downgraded
     to C

  -- US$27,000,000 Class V Mezzanine Floating Rate Deferrable
     Notes Due 2047, Withdrawn; previously on May 8, 2008
     Downgraded to C

  -- US$42,000,000 Class VI Mezzanine Floating Rate Deferrable
     Notes Due 2047, Withdrawn; previously on May 8, 2008
     Downgraded to C

  -- US$11,000,000 Class VII Mezzanine Floating Rate Deferrable
     Notes Due 2047, Withdrawn; previously on May 8, 2008
     Downgraded to C

  -- US$10,000,000 Class P Notes Due 2047, Withdrawn;
     previously on May 8, 2008 Upgraded to Aa1

Scorpius CDO, Ltd.

  -- US$975,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Notes due November 2046, Withdrawn; previously
     on November 20, 2009 Downgraded to C

  -- US$90,000,000 Class A-2A Second Priority Senior Secured
     Floating Rate Notes due November 2046, Withdrawn; previously
     on September 23, 2008 Downgraded to C

  -- US$90,000,000 Class A-2B Third Priority Senior Secured
     Floating Rate Notes due November 2046, Withdrawn; previously
     on September 23, 2008 Downgraded to C

  -- US$50,000,000 Class B Fourth Priority Senior Secured
     Floating Rate Notes due November 2046, Withdrawn; previously
     on September 23, 2008 Downgraded to C

  -- US$60,000,000 Class C Fifth Priority Senior Secured
     Floating Rate Notes due November 2046, Withdrawn; previously
     on September 23, 2008 Downgraded to C

  -- US$22,000,000 Class D Sixth Priority Mezzanine Secured
     Floating Rate Notes due November 2046, Withdrawn; previously
     on September 23, 2008 Downgraded to C

  -- US$52,000,000 Class E Seventh Priority Mezzanine Secured
     Floating Rate Notes due November 2046, Withdrawn; previously
     on March 12, 2008 Downgraded to C

  -- US$58,000,000 Class F Eighth Priority Mezzanine Secured
     Floating Rate Notes due November 2046, Withdrawn; previously
     on March 12, 2008 Downgraded to C

  -- US$20,000,000 Class G Ninth Priority Mezzanine Secured
     Floating Rate Notes due November 2046, Withdrawn; previously
     on March 12, 2008 Downgraded to C

  -- US$37,500,000 Class A Preferred Securities, Withdrawn;
     previously on March 12, 2008 Downgraded to C

  -- US$30,000,000 Class B Preferred Securities, Withdrawn;
     previously on March 12, 2008 Downgraded to C

South Coast Funding IX Ltd

  -- US$250,000,000 Class A-1B First Priority Senior Secured
     Floating Rate Notes Due 2047, Withdrawn; previously on
     April 24, 2009 Downgraded to C

  -- US$47,000,000 Class A-2 Second Priority Senior Secured
     Floating Rate Notes Due 2047, Withdrawn; previously on
     April 24, 2009 Downgraded to C

  -- US$37,500,000 Class B Third Priority Senior Secured
     Floating Rate Notes Due 2047, Withdrawn; previously on
     April 24, 2009 Downgraded to C

  -- US$34,500,000 Class C Fourth Priority Mezzanine Secured
     Floating Rate Deferrable Notes Due 2047, Withdrawn;
     previously on April 24, 2009 Downgraded to C

  -- US$24,000,000 Class D Fifth Priority Mezzanine Secured
     Floating Rate Deferrable Notes Due 2047, Withdrawn;
     previously on May 18, 2008 Downgraded to C

  -- US$11,500,000 Class E Sixth Priority Mezzanine Secured
     Floating Rate Deferrable Notes Due 2047, Withdrawn;
     previously on May 18, 2008 Downgraded to C

  -- US$7,500,000 Class F Seventh Priority Mezzanine Secured
     Floating Rate Deferrable Notes Due 2047, Withdrawn;
     previously on May 18, 2008 Downgraded to C

TABS 2005-3, Ltd.

  -- US$195,000,000 Class A-1 Senior Secured Floating Rate
     Delayed Draw Term Notes Due 2045, Withdrawn; previously on
     April 24, 2009 Downgraded to C

  -- US$35,000,000 Class A-2 Senior Secured Floating Rate Term
     Notes Due 2045, Withdrawn; previously on April 24, 2009
     Downgraded to C

  -- US$33,000,000 Class B Senior Secured Floating Rate Term
     Notes Due 2045, Withdrawn; previously on April 24, 2009
     Downgraded to C

  -- US$5,000,000 Class C Secured Floating Rate Deferrable
     Interest Term Notes Due 2045, Withdrawn; previously on
     June 9, 2008 Downgraded to C

  -- US$18,000,000 Class D Secured Floating Rate Deferrable
     Interest Term Notes Due 2045, Withdrawn; previously on
     June 9, 2008 Downgraded to C

TOPANGA CDO, LTD.

  -- US$49,000,000 Class A-1 Floating Rate Senior Secured Notes
     Due 2045, Withdrawn; previously on November 20, 2009
     Downgraded to C

  -- US$37,000,000 Class A-2 Floating Rate Senior Secured Notes
     Due 2045, Withdrawn; previously on April 24, 2009 Downgraded
     to C

  -- US$26,000,000 Class B Floating Rate Deferrable Subordinate
     Secured Notes Due 2045, Withdrawn; previously on April 24,
     2009 Downgraded to C

  -- US$20,000,000 Class C Floating Rate Deferrable Junior
     Subordinate Secured Notes Due 2045, Withdrawn; previously on
     April 24, 2009 Downgraded to C

Tierra Alta Funding I, Ltd.

  -- US$90,000,000 Class A1 Floating Rate Notes Due 2046,
     Withdrawn; previously on April 24, 2009 Downgraded to C

  -- US$155,000,000 Class A2 Floating Rate Notes Due 2046,
     Withdrawn; previously on April 24, 2009 Downgraded to C

  -- US$47,600,000 Class A3A Floating Rate Notes Due 2046,
     Withdrawn; previously on April 24, 2009 Downgraded to C

  -- US$2,400,000 Class A3B Floating Rate Notes Due 2046,
     Withdrawn; previously on April 24, 2009 Downgraded to C

  -- US$27,900,000 Class B1A Floating Rate Notes Due 2046,
     Withdrawn; previously on October 28, 2008 Downgraded to C

  -- US$2,100,000 Class B1B Floating Rate Notes Due 2046,
     Withdrawn; previously on October 28, 2008 Downgraded to C

  -- US$22,000,000 Class C Floating Rate Notes Due 2046,
     Withdrawn; previously on May 30, 2008 Downgraded to C

  -- US$6,000,000 Class Q Combination Notes Due 2046,
     Withdrawn; previously on April 24, 2009 Downgraded to C

  -- Class F Notes, Withdrawn; previously on November 20, 2009
     Downgraded to C


* S&P Cuts Ratings on 26 Classes From Three RMBS Deals to 'D'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D' on
26 classes from three U.S. residential mortgage-backed securities
resecuritized real estate mortgage investment conduit transactions
and affirmed four ratings on one other re-REMIC transaction.  The
re-REMIC classes S&P reviewed contain underlying classes issued by
TBW Mortgage-Backed Trusts in 2006 and 2007.

The downgrades reflect S&P's assessment of missed interest
payments to certificateholders of these underlying classes, which
have in turn caused missed interest payments on the re-REMIC
classes.  The missed interest payments resulted from the lack of
collections from the mortgage loans being passed through to the
TBW Mortgage-Backed Trusts.

The affirmations reflect S&P's assessment of additional underlying
classes that were not issued from TBW Mortgage-Backed Trusts and
which have been able to provide the applicable interest payments
to the related re-REMIC classes.

The pools of loans backing the underlying trusts consist of fixed-
rate Alternative-A mortgage loans secured by first liens on one-
to four-family residential properties.

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

                          Rating Actions

                       CSMC Series 2009-7R
                          Series 2009-7R

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       17-A1      12641QEA6     D                    AAA
       17-A2      12641QEB4     D                    A
       17-A3      12641QEC2     D                    BBB
       17-A4      12641QED0     D                    BB
       17-A5      12641QEE8     D                    B
       17-A7      12641QEG3     D                    AAA
       17-A8      12641QEH1     D                    AAA
       17-A9      12641QEJ7     D                    AAA
       18-A1      12641QEK4     D                    AAA
       18-A2      12641QEL2     D                    A
       18-A3      12641QEM0     D                    BBB
       18-A4      12641QEN8     D                    BB
       18-A5      12641QEP3     D                    B
       18-A7      12641QER9     D                    AAA
       18-A8      12641QES7     D                    AAA
       18-A9      12641QET5     D                    AAA

                       CSMC Trust 2007-5R
                         Series 2007-5R

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       A-1        12640QAA1     D                    AAA
       A-2        12640QAB9     D                    AAA
       A-3        12640QAC7     D                    AAA
       A-4        12640QAD5     D                    AAA
       A-5        12640QAE3     D                    AAA

             Jefferies Resecuritization Trust 2009-R4
                          Series 2009-R4

                                        Rating
                                        ------
       Class      CUSIP         To                   From
       -----      -----         --                   ----
       28-A1      47232VFP2     D                    AAA
       28-A1A     47232VFQ0     D                    AAA
       28-A1B     47232VFR8     D                    AAA
       28-A2      47232VFS6     D                    A
       28-A3      47232VFT4     D                    A

                        Ratings Affirmed

       J.P.  Morgan Alternative Loan Trust, Series 2008-R3
                          Series 2008-R3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 3-A-1      466308AE3     CCC
                 3-A-2      466308AF0     CCC
                 3-A-3      466308AG8     CCC
                 3-A-4      466308AH6     CCC


* S&P Downgrades Ratings on 21 Classes From Five RMBS Transactions
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 21
classes from five residential mortgage-backed securities
transactions backed by U.S. Alternative-A mortgage loan collateral
issued in 2005 and 2006.  S&P removed eight of these ratings from
CreditWatch with negative implications.  In addition, S&P affirmed
its ratings on seven classes from SBI Home Equity Loan Trust 2006-
1.

Standard & Poor's has established loss projections for Alt-A
transactions rated from 2005-2007.  S&P's lifetime projected
losses have changed for this transaction in this release:

                                     Orig. bal.      Lifetime
  Transaction                        (mil. $)        exp. loss (%)
  -----------                        ----------      -------------
SBI Home Equity Ln Trust 2006-1             238              1.37

The downgrades reflect S&P's opinion that the projected credit
support for the affected classes is insufficient to cover S&P's
current projected losses due to increased delinquencies and the
current condition of the housing market.

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
the base-case assumption at a percentage specific to each rating
category, up to 150% for an 'AAA' rating.  For example, in
general, S&P would assess whether one class could withstand
approximately 110% of S&P's base-case loss assumptions to maintain
a 'BB' rating, while S&P would assess whether a different class
could withstand approximately 120% of S&P's base-case loss
assumptions to maintain a 'BBB' rating.  Each class with an
affirmed 'AAA' rating can, in S&P's view, withstand approximately
150% of its base-case loss assumptions under S&P's analysis.

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

Subordination provides credit support for the affected
transactions.  In addition, some classes also benefit from
overcollateralization and excess spread.  The underlying pools of
loans backing these transactions consist of different combinations
of fixed- and adjustable-rate, hybrid, and option adjustable-rate
mortgage Alt-A mortgage loans.

                          Rating Actions

    Deutsche Mortgage Securities Inc Cayman Series 2006-C3-PR1
                      Series    2006C3-PR1

                                    Rating
                                    ------
   Class      CUSIP         To                   From
   -----      -----         --                   ----
   3-A-F-1                  BBB                  AAA/Watch Neg

    Deutsche Mortgage Securities Inc Cayman Series 2006C4-PR1
                      Series    2006C4-PR1

                                    Rating
                                    ------
   Class      CUSIP         To                   From
   -----      -----         --                   ----
   4-A-F-1                  BBB                  AAA/Watch Neg

        Greenpoint Mortgage Funding Grantor Trust 2006-AR2
                        Series    2006-AR2

                                    Rating
                                    ------
   Class      CUSIP         To                   From
   -----      -----         --                   ----
   III-A-1                  BB                   AAA/Watch Neg

           GreenPoint Mortgage Funding Trust 2005-AR5
                       Series    2005-AR5

                                    Rating
                                    ------
   Class      CUSIP         To                   From
   -----      -----         --                   ----
   I-A-1      39538WEA2     CCC                  AAA
   I-A-2      39538WEC8     CC                   AAA/Watch Neg
   I-X-1      39538WEB0     CCC                  AAA
   I-X-2      39538WED6     CC                   AAA
   II-A-1     39538WEE4     CCC                  AAA
   II-A-2     39538WEF1     CC                   AAA/Watch Neg
   II-X-1     39538WEG9     CCC                  AAA
   II-X-2     39538WEH7     CCC                  AAA
   II-X-3     39538WEJ3     CCC                  AAA
   III-A-1    39538WEK0     CCC                  AAA
   III-A-2    39538WEL8     CC                   AAA/Watch Neg
   III-X-1    39538WEM6     CCC                  AAA
   IV-X-1     39538WEP9     CCC                  AAA
   IV-X-2     39538WER5     CC                   AAA
   IV-A-1     39538WEN4     CCC                  AAA
   IV-A-2     39538WEQ7     CC                   A/Watch Neg
   M-X        39538WES3     CC                   B
   M-1        39538WET1     CC                   B/Watch Neg

                        Ratings Affirmed

                 SBI Home Equity Loan Trust 2006-1
                         Series    2006-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 1A-1       78402TAA4     AAA
                 1A-2A      78402TAK2     AAA
                 1A-2B      78402TAL0     AAA
                 1M-1       78402TAB2     AA
                 1M-2       78402TAC0     A
                 1M-3       78402TAD8     BBB
                 1M-4       78402TAF3     BB


* S&P Downgrades Ratings on 72 Tranches From 11 CLO Transactions
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 72
tranches from 11 U.S. collateralized loan obligation transactions
and removed them from CreditWatch with negative implications.  The
affected tranches had a total issuance amount of $5.339 billion.
S&P also affirmed its ratings on six tranches from three of these
transactions and removed five of these 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 11 classes from five 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 its
criteria update.

S&P will continue to review the remaining transactions with
ratings placed on CreditWatch negative following its corporate CDO
criteria update, and will resolve the CreditWatch status of the
affected tranches as S&P completes its reviews.

                         Rating Actions

                                             Rating
                                             ------
  Transaction                    Class     To      From
  -----------                    -----     --      ----
  Atrium III                     A-1       AA      AAA/Watch Neg
  Atrium III                     A-2a      A       AA/Watch Neg
  Atrium III                     A-2b      A       AA/Watch Neg
  Atrium III                     B         BBB-    A/Watch Neg
  Atrium III                     C         BB-     BBB/Watch Neg
  Atrium III                     D-1       B-      BB/Watch Neg
  Atrium III                     D-2       B-      BB/Watch Neg
  Babson CLO Ltd. 2004-II        A-1       AA+     AAA/Watch Neg
  Babson CLO Ltd. 2004-II        A-2A      AA+     AAA/Watch Neg
  Babson CLO Ltd. 2004-II        A-2Av     AA+     AAA/Watch Neg
  Babson CLO Ltd. 2004-II        A-2B      AA+     AAA/Watch Neg
  Babson CLO Ltd. 2004-II        A-2C      AA+     AAA/Watch Neg
  Babson CLO Ltd. 2004-II        B         A+      AA+/Watch Neg
  Babson CLO Ltd. 2004-II        C-1       BBB+    A/Watch Neg
  Babson CLO Ltd. 2004-II        C-2       BBB+    A/Watch Neg
  Babson CLO Ltd. 2004-II        D-1       BB+     BBB/Watch Neg
  Babson CLO Ltd. 2004-II        D-2       BB+     BBB/Watch Neg
  Babson CLO Ltd. 2005-I         A-1A      A+      AAA/Watch Neg
  Babson CLO Ltd. 2005-I         A-1B-1    A+      AAA/Watch Neg
  Babson CLO Ltd. 2005-I         A-1B-2    A+      AAA/Watch Neg
  Babson CLO Ltd. 2005-I         A2        A-      AA/Watch Neg
  Babson CLO Ltd. 2005-I         B-1 Def   BB+     A/Watch Neg
  Babson CLO Ltd. 2005-I         B-2 Def   BB+     A/Watch Neg
  Babson CLO Ltd. 2005-I         C-1 Def   CCC+    BBB-/Watch Neg
  Babson CLO Ltd. 2005-I         C-2 Def   CCC+    BBB-/Watch Neg
  Babson CLO Ltd. 2008-I         A         AA+     AAA/Watch Neg
  Babson CLO Ltd. 2008-I         B         A+      AA/Watch Neg
  Babson CLO Ltd. 2008-I         C-1       BBB+    A/Watch Neg
  Babson CLO Ltd. 2008-I         C-2       BBB+    A/Watch Neg
  Babson CLO Ltd. 2008-I         D         BBB-    BBB/Watch Neg
  Babson CLO Ltd. 2008-I         E         B+      BB/Watch Neg
  Babson Loan Opportunity CLO    A         AA+     AAA/Watch Neg
   Ltd.
  Clydesdale CLO 2006 Ltd.      A-1       AA      AAA/Watch Neg
  Clydesdale CLO 2006 Ltd.      A-2       A+      AA/Watch Neg
  Clydesdale CLO 2006 Ltd.      B         BBB+    A/Watch Neg
  Clydesdale CLO 2006 Ltd.      C         B+      BBB/Watch Neg
  Clydesdale CLO 2006 Ltd.      D         CCC-    BB/Watch Neg
  Dryden V-Leveraged Loan CDO    A         AA+     AAA/Watch Neg
   2003
  Dryden V-Leveraged Loan CDO    B-1       A+      AA/Watch Neg
   2003
  Dryden V-Leveraged Loan CDO    B-2       A+      AA/Watch Neg
   2003
  Dryden V-Leveraged Loan CDO    C-1       BBB     A/Watch Neg
   2003
  Dryden V-Leveraged Loan CDO    C-2       BBB     A/Watch Neg
   2003
  Dryden V-Leveraged Loan CDO    D-1       CCC+    BB/Watch Neg
   2003
  Dryden V-Leveraged Loan CDO    D-2       CCC+    BB/Watch Neg
   2003
  Dryden V-Leveraged Loan CDO    D-3       CCC+    BB/Watch Neg
   2003
  Dryden V-Leveraged Loan CDO    E         CCC-    CCC+/Watch Neg
   2003
  Gulf Stream-Compass CLO        A-1       AA+     AAA/Watch Neg
   2005-1 Ltd.
  Gulf Stream-Compass CLO        A-2       AA+     AAA/Watch Neg
   2005-1 Ltd.
  Gulf Stream-Compass CLO        B         A+      AA/Watch Neg
   2005-1 Ltd.
  Gulf Stream-Compass CLO        C         BBB+    A/Watch Neg
   2005-1 Ltd.
  Gulf Stream-Compass CLO        D         BB      BBB/Watch Neg
   2005-1 Ltd.
  Katonah V Ltd.                A-1       AA      AAA/Watch Neg
  Katonah V Ltd.                A-2       A       AA/Watch Neg
  Katonah V Ltd.                B-1       B+      BBB/Watch Neg
  Katonah V Ltd.                B-2       B+      BBB/Watch Neg
  Katonah V Ltd.                C         CCC-    BB-/Watch Neg
  Katonah V Ltd.                D         CC      CCC/Watch Neg
  Race Point II CLO Ltd.        A-1       AA+     AAA/Watch Neg
  Race Point II CLO Ltd.        B-1       BBB-    A/Watch Neg
  Race Point II CLO Ltd.        B-2       BBB-    A/Watch Neg
  Race Point II CLO Ltd.        C-1       BB-     BBB/Watch Neg
  Race Point II CLO Ltd.        C-2       BB-     BBB/Watch Neg
  Race Point II CLO Ltd.        D-1       B       BB/Watch Neg
  Race Point II CLO Ltd.        D-2       B       BB/Watch Neg
  Race Point II CLO Ltd.        D-3       B       BB/Watch Neg
  Stone Tower CLO VI Ltd.       A-1       AA+     AAA/Watch Neg
  Stone Tower CLO VI Ltd.       A-2a      AA+     AAA/Watch Neg
  Stone Tower CLO VI Ltd.       A-2b      AA+     AAA/Watch Neg
  Stone Tower CLO VI Ltd.       A-3       A+      AA/Watch Neg
  Stone Tower CLO VI Ltd.       B         BBB+    A/Watch Neg
  Stone Tower CLO VI Ltd.       C         BB+     BBB/Watch Neg
  Stone Tower CLO VI Ltd.       D         CCC+    BB/Watch Neg

      Ratings Affirmed And Removed From Creditwatch Negative

                                               Rating
                                               ------
  Transaction                           Class To   From
  -----------                           ----- --   ----
  Babson Loan Opportunity CLO Ltd.     B     AA   AA/Watch Neg
  Babson Loan Opportunity CLO Ltd.     C     A    A/Watch Neg
  Babson Loan Opportunity CLO Ltd.     D     BBB  BBB/Watch Neg
  Babson Loan Opportunity CLO Ltd.     E     BB   BB/Watch Neg
  Race Point II CLO Ltd.               A-2   AA+  AA+/Watch Neg

                           Rating Affirmed

     Transaction                           Class      Rating
     -----------                           -----      ------
     Babson CLO Ltd. 2005-I                P          AAA


* S&P Downgrades Ratings on 129 Tranches From 22 CLO Transactions
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 129
tranches from 22 U.S. collateralized loan obligation transactions
and removed them from CreditWatch with negative implications.  The
affected tranches had a total issuance amount of $9.034 billion.
S&P also affirmed its ratings on seven tranches from six of these
transactions and removed them 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 17 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 with
ratings 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
-----------                            -----     --      ----
ABCLO 2007-1 Ltd                       A-1a      AA+     AAA/Watch Neg
ABCLO 2007-1 Ltd                       A-1b      A+      AAA/Watch Neg
ABCLO 2007-1 Ltd                       A-2       A-      AA/Watch Neg
ABCLO 2007-1 Ltd                       B         BB+     A/Watch Neg
ABCLO 2007-1 Ltd                       C         B+      BBB/Watch Neg
ABCLO 2007-1 Ltd                       D         CCC-    BB/Watch Neg
AMMC CLO VI Ltd                        A-1-B     AA+     AAA/Watch Neg
AMMC CLO VI Ltd                        A-2       AA+     AAA/Watch Neg
AMMC CLO VI Ltd                        B         A+      AA/Watch Neg
AMMC CLO VI Ltd                        C         BBB+    A/Watch Neg
AMMC CLO VI Ltd                        D         CCC-    BBB/Watch Neg
Avenue CLO IV Ltd                      A         BBB-    AAA/Watch Neg
Avenue CLO IV Ltd                      B         CCC-    A/Watch Neg
Avenue CLO IV Ltd                      C         CCC-    BBB/Watch Neg
Avenue CLO IV Ltd                      D         CC      BB/Watch Neg
Avenue CLO VI, Ltd.                    A-1       AA+     AAA/Watch Neg
Avenue CLO VI, Ltd.                    A-2       A+      AAA/Watch Neg
Avenue CLO VI, Ltd.                    B         BBB+    AA/Watch Neg
Avenue CLO VI, Ltd.                    C         BB+     A/Watch Neg
Avenue CLO VI, Ltd.                    D         CCC-    BBB/Watch Neg
Avenue CLO VI, Ltd.                    E         CCC-    BB/Watch Neg
Blackrock Senior Income Series IV      A         AA+     AAA/Watch Neg
Blackrock Senior Income Series IV      B         A+      AA/Watch Neg
Blackrock Senior Income Series IV      C         BBB+    A/Watch Neg
Blackrock Senior Income Series IV      D         B+      BBB-/Watch Neg
Callidus Debt Partners CLO Fund III    A-1       AA+     AAA/Watch Neg
Callidus Debt Partners CLO Fund III    A-2       AA+     AAA/Watch Neg
Callidus Debt Partners CLO Fund III    A-4       AA+     AAA/Watch Neg
Callidus Debt Partners CLO Fund III    B         A+      AA/Watch Neg
Callidus Debt Partners CLO Fund III    C         BBB+    A/Watch Neg
Callidus Debt Partners CLO Fund III    D         BB+     BBB/Watch Neg
Callidus Debt Partners CLO Fund III    E         B+      BB/Watch Neg
Carlyle High Yield Partners VII        A-1       AA-     AAA/Watch Neg
Carlyle High Yield Partners VII        A-2-A     AA+     AAA/Watch Neg
Carlyle High Yield Partners VII        A-3       AA-     AAA/Watch Neg
Carlyle High Yield Partners VII        B         A       AA/Watch Neg
Carlyle High Yield Partners VII        C         BBB+    A-/Watch Neg
Carlyle High Yield Partners VII        D-1       CCC-    BB+/Watch Neg
Carlyle High Yield Partners VII        D-2       CCC-    BB+/Watch Neg
Centurion CDO VII Limited              A-1a      AA+     AAA/Watch Neg
Centurion CDO VII Limited              A-1b      AA+     AAA/Watch Neg
Centurion CDO VII Limited              A-2       AA+     AAA/Watch Neg
Centurion CDO VII Limited              B-1 Def   BBB+    A/Watch Neg
Centurion CDO VII Limited              B-2 Def   BBB+    A/Watch Neg
Centurion CDO VII Limited              C-1 Def   BB+     BBB/Watch Neg
Centurion CDO VII Limited              C-2 Def   BB+     BBB/Watch Neg
Centurion CDO VII Limited              D-1 Def   CCC+    BB/Watch Neg
Centurion CDO VII Limited              D-2 Def   CCC+    BB/Watch Neg
Centurion CDO VII Limited              G Combo   BB+     BBB-/Watch Neg
CSAM Funding I                         A-1       AA+     AAA/Watch Neg
CSAM Funding I                         A-2       AA+     AAA/Watch Neg
CSAM Funding I                         B-1       BBB+    A-/Watch Neg
CSAM Funding I                         B-2       BBB+    A-/Watch Neg
CSAM Funding II                        A         AA-     AAA/Watch Neg
CSAM Funding II                        B-1       BBB-    A-/Watch Neg
CSAM Funding II                        B-2       BBB-    A-/Watch Neg
CSAM Funding II                        C-1       B+      BB+/Watch Neg
CSAM Funding II                        C-2       B+      BB+/Watch Neg
CSAM Funding II                        D         CCC-    B/Watch Neg
Flagship CLO III                       A Fd Nt   AA      AAA/Watch Neg
Flagship CLO III                       A Rev Nt  AA      AAA/Watch Neg
Flagship CLO III                       B         BBB+    A/Watch Neg
Flagship CLO III                       C         BB+     BBB/Watch Neg
Flagship CLO III                       D         CCC-    BB/Watch Neg
Flagship CLO V                         A         AA-     AAA/Watch Neg
Flagship CLO V                         B         BBB+    AA/Watch Neg
Flagship CLO V                         C         BB+     A/Watch Neg
Flagship CLO V                         D         B+      BBB/Watch Neg
Flagship CLO V                         E         CCC-    BB/Watch Neg
Galaxy V CLO, Ltd.                     A-1       AA+     AAA/Watch Neg
Galaxy V CLO, Ltd.                     A-2       AA+     AAA/Watch Neg
Galaxy V CLO, Ltd.                     B         A+      AA/Watch Neg
Galaxy V CLO, Ltd.                     C         BBB     A/Watch Neg
Galaxy V CLO, Ltd.                     D-1       B+      BB/Watch Neg
Galaxy V CLO, Ltd.                     D-2       B+      BB/Watch Neg
Greyrock CDO Ltd                       A-1L      AA+     AAA/Watch Neg
Greyrock CDO Ltd                       A-2L      A+      AA/Watch Neg
Greyrock CDO Ltd                       A-3L      BBB+    A-/Watch Neg
Greyrock CDO Ltd                       B-1F      BB      BBB/Watch Neg
Greyrock CDO Ltd                       B-1L      BB      BBB/Watch Neg
Greyrock CDO Ltd                       B-2F      CCC+    BB/Watch Neg
Greyrock CDO Ltd                       B-2L      CCC+    BB/Watch Neg
Gulf Stream-Compass CLO 2004-1,        A         A-      AAA/Watch Neg
Gulf Stream-Compass CLO 2004-1,        C         BB+     A/Watch Neg
Gulf Stream-Compass CLO 2004-1,        D         CCC-    BBB-/Watch Neg
MAPS CLO Fund II Ltd.                  A-1       A+      AAA/Watch Neg
MAPS CLO Fund II Ltd.                  A-1J      A+      AAA/Watch Neg
MAPS CLO Fund II Ltd.                  A-1R      AA+     AAA/Watch Neg
MAPS CLO Fund II Ltd.                  A-1S      AA+     AAA/Watch Neg
MAPS CLO Fund II Ltd.                  A-2       A+      AA/Watch Neg
MAPS CLO Fund II Ltd.                  B         BBB     A/Watch Neg
MAPS CLO Fund II Ltd.                  C         BB      BBB/Watch Neg
MAPS CLO Fund II Ltd.                  D         CCC+    BB/Watch Neg
Market Square CLO Ltd                  A         AA-     AAA/Watch Neg
Market Square CLO Ltd                  B         BBB-    A-/Watch Neg
Market Square CLO Ltd                  C         BB      BBB/Watch Neg
Market Square CLO Ltd                  D         CCC+    BB-/Watch Neg
Octagon Investment Partners IX, Ltd    A-1       AA+     AAA/Watch Neg
Octagon Investment Partners IX, Ltd    A-2       AA-     AA/Watch Neg
Octagon Investment Partners IX, Ltd    C         BBB-    BBB/Watch Neg
Pacifica CDO III Ltd.                  A-1       AA+     AAA/Watch Neg
Pacifica CDO III Ltd.                  A-2a      BBB+    AA/Watch Neg
Pacifica CDO III Ltd.                  A-2b      BBB+    AA/Watch Neg
Pacifica CDO III Ltd.                  B-1       BBB     A/Watch Neg
Pacifica CDO III Ltd.                  B-2       BBB     A/Watch Neg
Pacifica CDO III Ltd.                  C-1       CCC-    BB+/Watch Neg
Pacifica CDO III Ltd.                  C-2       CCC-    BB+/Watch Neg
Rosedale CLO Ltd                       A-1A      A+      AAA/Watch Neg
Rosedale CLO Ltd                       A-1D      A+      AAA/Watch Neg
Rosedale CLO Ltd                       A-1J      A+      AAA/Watch Neg
Rosedale CLO Ltd                       A-1R      A+      AAA/Watch Neg
Rosedale CLO Ltd                       A-1S      AA+     AAA/Watch Neg
Rosedale CLO Ltd                       B         BBB+    AA/Watch Neg
Rosedale CLO Ltd                       C         BB-     A/Watch Neg
Rosedale CLO Ltd                       D-1       CCC-    BBB/Watch Neg
Rosedale CLO Ltd                       D-2       CCC-    BBB/Watch Neg
Rosedale CLO Ltd                       E         CCC-    BB/Watch Neg
Southport CLO, Limited                 2         BB+     BBB/Watch Neg
Southport CLO, Limited                 A-1       AA+     AAA/Watch Neg
Southport CLO, Limited                 A-3       AA+     AAA/Watch Neg
Southport CLO, Limited                 B         BBB+    A/Watch Neg
Southport CLO, Limited                 C         CCC-    BB+/Watch Neg
Southport CLO, Limited                 D         CCC-    B/Watch Neg
Stone Tower CLO IV, Ltd.               A-1       AA+     AAA/Watch Neg
Stone Tower CLO IV, Ltd.               A-2       A+      AA/Watch Neg
Stone Tower CLO IV, Ltd.               B         BBB+    A/Watch Neg
Stone Tower CLO IV, Ltd.               C-1       B+      BBB/Watch Neg
Stone Tower CLO IV, Ltd.               C-2       B+      BBB/Watch Neg
Stone Tower CLO IV, Ltd.               D         CCC+    BB/Watch Neg

      Ratings Affirmed And Removed From Creditwatch Negative

                                                    Rating
                                                    ------
   Transaction                            Class   To      From
   -----------                            -----   --      ----
   AMMC CLO VI Ltd                        A-1-A   AAA     AAA/Watch Neg
   AMMC CLO VI Ltd                        A-1-R   AAA     AAA/Watch Neg
   Avenue CLO IV Ltd                      X       AAA     AAA/Watch Neg
   Callidus Debt Partners CLO Fund III    A-3     AAA     AAA/Watch Neg
   Octagon Investment Partners IX, Ltd    B       A       A/Watch Neg
   Rosedale CLO Ltd                       X       AAA     AAA/Watch Neg
   Southport CLO, Limited                 A-2     AAA     AAA/Watch Neg

                          Rating Affirmed

     Transaction                             Class     Rating
     -----------                             -----     ------
     Greyrock CDO Ltd                        X         AAA


* S&P Downgrades Ratings on 703 Classes of Certificates to 'D'
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D' on
703 classes of mortgage pass-through certificates from 631 U.S.
residential mortgage-backed securities transactions.  S&P removed
eight of the lowered ratings from CreditWatch with negative
implications.  In addition, S&P placed 166 other ratings from 17
transactions on CreditWatch with negative implications.  The
ratings on 87 additional classes from nine of these transactions
remain on CreditWatch with negative implications.

Approximately 83.78% of the defaulted classes were from
transactions backed by Alternative-A or subprime mortgage loan
collateral.  The 703 defaulted classes consisted of these:

* 399 classes were from Alt-A transactions (56.68% of all
  defaults);

* 190 were from subprime transactions (26.99% of all defaults);

* 86 were from prime jumbo transactions;

* 10 were from reperforming transactions;

* Six were from closed-end second-lien transactions;

* Four were from outside-the-guidelines transactions;

* Three were from first-lien high loan-to-value transactions;

* Two were from home equity line of credit transactions;

* One was from a document-deficient transaction;

* One was from a re-REMIC (resecuritized real estate mortgage
  investment conduit) transaction; and

* One was from a risk-transfer transaction.

The 703 downgrades to 'D' reflect S&P's assessment of principal
write-downs on the affected classes during recent remittance
periods.  The CreditWatch placements reflect the fact that the
affected classes are within a group that includes a class that
defaulted from a 'B-' rating or higher.  S&P lowered approximately
96.30% of the ratings from the 'CCC' or 'CC' rating categories,
and S&P lowered approximately 98.29% from a speculative-grade
category.

S&P expects to resolve the CreditWatch placements affecting these
transactions after S&P completes its reviews of the underlying
credit enhancement.  Standard & Poor's will continue to monitor
its ratings on securities that experience principal write-downs,
and S&P will adjust the ratings as S&P deems appropriate.


* S&P Downgrades Ratings on Eight Classes From Two Synthetic CDOs
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D' on
eight classes of notes from two U.S. synthetic collateralized debt
obligation transactions backed by mezzanine tranches of
residential mortgage-backed securities transactions.

The downgrades follow a number of recent write-downs to the
underlying reference entities, which have caused the classes to
incur full or partial principal losses.

                         Ratings Lowered

                                               Rating
                                               ------
        Deal Name                  Class      To    From
        ---------                  -----      --    ----
        ABACUS 2006-8 Ltd.          A-1        D     CCC-
        ABACUS 2006-8 Ltd.          A-2        D     CCC-
        ABACUS 2006-8 Ltd.          D          D     CCC-
        ABACUS 2006-12 Ltd.         A-1        D     CCC-
        ABACUS 2006-12 Ltd.         A-2        D     CCC-
        ABACUS 2006-12 Ltd.         B          D     CCC-
        ABACUS 2006-12 Ltd.         C          D     CCC-
        ABACUS 2006-12 Ltd.         D          D     CCC-



                           *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
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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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