TCR_Public/100328.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, March 28, 2010, Vol. 14, No. 86

                            Headlines

AH MORTGAGE: Moody's Reviews Ratings on Series 2009-ADV2 Notes
ALTIUS II: Moody's Downgrades Ratings on Two Classes of Notes
ARROYO I: Fitch Affirms Ratings on Four Classes of Notes
BANC OF AMERICA: Fitch Takes Various Rating Actions on Notes
BANC OF AMERICA: S&P Downgrades Rating on Eight 2002-X1 Certs.

BAYVIEW FINANCIAL: Fitch Downgrades Ratings on Class A Notes
BAYVIEW FINANCIAL: Fitch Takes Action on Four 2007-SSR1 Notes
BEAR STEARNS: Fitch Corrects Amended Loan Level Analysis
BEAR STEARNS: Fitch Takes Rating Actions on 2004-TOP16 Securities
BERNOULLI HIGH: Fitch Takes Rating Actions on Various Classes

BRISTOL CDO: Fitch Affirms Ratings on Two Classes of Notes
COMM 2004-LNB4: Moody's Affirms Ratings on Three Classes of Notes
COMM 2008-RS3: Moody's Reviews 11 Classes of Certificates
COMMONWEALTH PORTS: Fitch Affirms 'CCC' Rating on $15 Mil. Bonds
COMMONWEALTH PORTS: Fitch Gives Neg. Outlook; Affirms 'BB-' Rating

COOLIDGE FUNDING: Moody's Downgrades Ratings on Three Classes
CREDIT AND REPACKAGED: S&P Withdraws 'CCC-' Rating on Notes
CREDIT SUISSE: Moody's Affirms Ratings on Six 2002-CKP1 Certs.
DETROIT MEDICAL: Fitch Puts Bonds' 'BB' Ratings on Positive Watch
EMPIRE HOME: Fitch Downgrades Ratings on 14 Classes to 'C'

FMC REAL: Fitch Downgrades Ratings on All Classes of Notes
GE COMMERCIAL: S&P Downgrades Ratings on 14 Classes of Notes
GLACIER FUNDING: Fitch Downgrades Ratings on Three Classes
GOLDMAN SACHS: Moody's Affirms Ratings on Seven 2006-GG8 Certs.
GREENWICH CAPITAL: Moody's Reviews Ratings on 15 2005-GG5 Certs.

HARTFORD FINANCIAL: Fitch Assigns 'BB' Rating on $500 Mil. Stock
HOUSE OF EUROPE: Moody's Cuts Class A2 Notes to Ca
HOUSE OF EUROPE FUNDING: Moody's Cuts Ratings on Two Classes to B1
INFINITI SPC: S&P Downgrades Ratings on Class 7C-1 Notes to 'CC'
JP MORGAN: Fitch Takes Rating Actions on 2002-CIBC5 Notes

JPMORGAN CHASE: S&P Downgrades Ratings on Seven 2005-CIBC11 Notes
KATONAH IV: Moody's Reviews Ratings on Three Classes of Notes
KINGSLAND IV: Moody's Reviews Ratings on Three Classes of Notes
KLEROS REAL: Moody's Downgrades Ratings on Class A-1 Notes
LB-UBS COMMERCIAL: Fitch Takes Rating Actions on 2003-C1 Notes

LIMEROCK CLO: Moody's Reviews Ratings on Various Classes of Notes
LOUISIANA PUBLIC: S&P Affirms 'BB' Rating on Two Bonds
MAX CMBS: Moody's Reviews Ratings on 14 Classes of Notes
MORGAN STANLEY: Moody's Confirms Ratings on Two Classes of Notes
MORGAN STANLEY: Moody's Downgrades Ratings on 2001-TOP3 Certs.

MORGAN STANLEY: S&P Corrects Rating on Class A-11 Notes From 'BB+'
MORGAN STANLEY: S&P Downgrades Ratings on Various Classes to 'CC'
PHOENIX CDO: Fitch Takes Rating Actions on Various Classes
PYXIS MASTER: S&P Withdraws 'B-' Rating on Point Green II Units
REPACS TRUST: S&P Withdraws 'CCC-' Rating on Debt Units

SAGAMORE CLO: Moody's Reviews Ratings on Two Classes of Notes
VALLEJO PUBLIC: S&P Raises Rating on $10.8 Mil. Bonds From 'B'
WACHOVIA BANK: Fitch Downgrades Ratings on Series 2003-C9 Certs.
WACHOVIA BANK: Fitch Takes Various Rating Actions on 2003-C3 Notes
WEBBERVILLE: S&P Downgrades Rating on Bonds to 'BB'

* Moody's Confirms Ratings on 13 Classes From Five CMBS Deals
* S&P Downgrades Ratings on 23 Tranches From Five CLO Transactions
* S&P Downgrades Ratings on 24 Tranches From Eight CDO Deals
* S&P Downgrades Ratings on 28 Classes From 13 RMBS Transactions
* S&P Downgrades Ratings on 78 Classes From Five RMBS Transactions

* S&P Downgrades Ratings on 95 Classes From 29 RMBS Transactions
* S&P Downgrades Ratings on 473 Classes of Certificates to 'D'



                            *********



AH MORTGAGE: Moody's Reviews Ratings on Series 2009-ADV2 Notes
--------------------------------------------------------------
Moody's placed on review for possible downgrade the Aaa ratings of
the Series 2009-ADV2 notes issued from AH Mortgage Advance Trust
2009-ADV2.  The sponsor of the transaction is American Home
Mortgage Servicing, Inc.  The rating action is driven by certain
deficiencies in the reconciliation process for deals serviced by
AHMSI.  The SAF is backed by reimbursement rights for servicer
advances that AHMSI makes for the residential mortgage backed
securitizations that it services.  Moody's, however, is not taking
any rating action on RMBS serviced by AHMSI, solely as a result of
the concerns related to the reconciliation processes.

The rating action on the SAF reflects Moody's concerns about
significant number of aged reconciliation items outstanding in
AHMSI's RMBS custodial bank accounts.  Custodial bank account
reconciliation is the process of comparing figures from the
accounting records (cash book, loan level records) against those
shown on the monthly bank statements.  When a servicer is unable
to reconcile any entry between the bank books and the accounting
books, that entry becomes a "reconciliation item."  Although
reconciliation items are not uncommon in the mortgage servicing
industry, servicers will typically resolve such items within 30
days of being identified.  As items age beyond 30 days or more,
the probability that either the servicer or the SAF may suffer a
loss increases, although there has been no evidence of this from
the items cleared to date.  In the case of AHMSI, there is a
significant amount of aged (60 days or more) reconciliation items.
The majority of the aged reconciliation items for AHMSI exist in
these areas: loan liquidations, loan modifications, mortgage
insurance claims, and the servicer's "stop-advance" process on
delinquent loans.  AHMSI has been working to clear these
reconciliation items.  Even as AHMSI has cleared a large number of
outstanding items, new reconciliation items have been created.

All RMBS that are serviced by AHMSI and rated by Moody's
(including RMBS transaction for which servicer advances have been
pledged to the SAF) were also reviewed in the context of the
concerns outlined above.  The incremental credit risk posed to the
RMBS solely as a result of the issues identified in this press
release was not considered material in comparison to current
expectation of losses on these deals.  Therefore no rating actions
were taken on the RMBS serviced by AHMSI solely as result of the
reconciliation issues identified in this release.

AHMSI has indicated that reporting inconsistencies between two
internal systems, Loan Processing System and a custom designed
system, have caused most of the reconciliation items.  AHMSI's
servicing system, or the system of record, is LPS.  However, LPS
is not the system that AHMSI uses for all functions related to
investor reporting.  For reporting to investors, master servicers
and other transaction related parties AHMSI uses a custom designed
solution.

AHMSI has provided information on the aged reconciliation items,
including its corrective action plan.  As part of this action
plan, AHMSI has contracted with third-party vendors to resolve the
aged items, determine their root causes, assist in the
implementation of permanent process modifications to prevent
recurrence and perform quality control checks on the remedial
measures.

The most recent estimate from AHMSI to complete this project is
over the next four to six months.  AHMSI has committed to increase
the reserve fund of the SAF by $20 million.  This incremental
reserve amount can reduce with the resolution of the
reconciliation items.  In any case, the management has
communicated to us that until such time that all aged
reconciliation items are resolved, the net incremental addition to
reserve fund will not be lower than $10 million.  In Moody's
opinion this contribution by AHMSI demonstrates a strong
commitment to resolving the issues and provides additional
protection against any potential losses attributable to unresolved
reconciliation items.  If the aged reconciliation items are
resolved, show no signs of re-occurring and an independent third
party validates the improving situation Moody's are likely to
reaffirm the Aaa rating.  On the other hand, if the reconciliation
items continue to grow, over next three months, Moody's will
downgrade the SAF notes.

The AH Mortgage Advance Trust 2009-ADV2 transaction closed in
August 2009 and its revolving period is due to end August 2010.
At such time, the rated notes will begin to amortize and the SAF
will no longer finance new advances made to the pledged RMBS
transactions.

The complete rating action is:

* The Class A-1 term note: Aaa on review for possible downgrade;
  previous rating action on August 13, 2009 rated Aaa.

* Series 2009-ADV2 Variable Funding Notes: Aaa on review for
  possible downgrade; previous rating action on August 13, 2009
  rated Aaa.


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

  -- US$1,313,000,000 Class A-1 Floating Rate Notes Due 2040
     (current balance of $1,021.6 million), Downgraded to Ca;
     previously on 1/30/09 Downgraded to B1

  -- US$84,000,000 Class A-2 Floating Rate Notes Due 2040 (current
     balance of $73.2 million), Downgraded to C; previously on
     1/30/09 Downgraded to Ca

Altius II Funding, Ltd., is a collateralized debt obligation
issuance backed by a portfolio of primarily Residential Mortgage-
Backed Securities originated in 2004 and 2005, with the majority
originated in 2005.

According to Moody's, the rating downgrade actions are the result
of deterioration in the credit quality of the underlying
portfolio.  Such credit deterioration is observed through numerous
factors, including a decline in the average credit rating of the
portfolio (as measured by an increase in the weighted average
rating factor), an increase in the dollar amount of defaulted
securities, and failure of the coverage tests.  The weighted
average rating factor, as reported by the trustee, has increased
from 410 in January 2009 to 2794 in January 2010.  During the same
time, defaulted securities increased from $36.6 million to
$147.1 million.  In addition, the Trustee reports that the
transaction is currently failing its Overcollateralization test.

Moody's explained that in arriving at the rating action noted
above, the ratings of 2005-2007 subprime, Alt-A and Option-ARM
RMBS which are currently on review for possible downgrade were
stressed.  For purposes of monitoring its ratings of SF CDOs with
exposure to such 2005-2007 vintage RMBS, Moody's used certain
projections of the lifetime average cumulative losses as set forth
in Moody's press releases dated January 13th for subprime,
January 14 for Alt-A, and January 27th for Option-ARM.  Based on
the anticipated ratings impact of the updated cumulative loss
numbers, the stress varied based on vintage, current rating, and
RMBS asset type.

For 2005 Alt-A and Option-ARM securities, securities that are
currently rated Aaa or Aa were stressed by eleven notches, and
securities currently rated A or Baa were stressed by eight
notches.  Those securities currently rated in the Ba or B range
were stressed to Caa3, while current Caa securities were treated
as Ca.  For 2006 and 2007 Alt-A and Option-ARM securities,
currently Aaa or Aa rated securities were stressed by eight
notches, and securities currently rated A, Baa or Ba were stressed
by five notches.  Those securities currently rated in the B range
were stressed to Caa3, while current Caa securities were treated
as Ca.

For 2005 subprime RMBS, those currently rated Aa, A or Baa were
stressed by five notches, Ba rated securities were stressed to
Caa3, and B or Caa securities were treated as Ca.  For subprime
RMBS originated in the first half of 2006, those currently rated
Aaa were stressed by four notches, while Aa, A and Baa rated
securities were stressed by eight notches.  Those securities
currently rated in the Ba range were stressed to Caa3, while
current B and Caa securities were treated as Ca.  For subprime
RMBS originated in the second half of 2006, those currently rated
Aa, A, Baa or Ba were stressed by four notches, currently B rated
securities were treated as Caa3, and currently Caa rated
securities were treated as Ca.  For 2007 subprime RMBS, currently
Ba rated securities were stressed by four notches, currently B
rated securities were treated as Caa3, and currently Caa rated
securities were treated as Ca.

Moody's noted that the stresses applicable to categories of 2005-
2007 subprime RMBS that are not listed above will be two notches
if the RMBS ratings are on review for possible downgrade.

Moody's further explained that these stresses are based on a
preliminary sample analysis of deals from a given vintage and
asset type, and that they will be utilized in its SF CDO rating
analysis while subprime, Alt-A and Option-ARM securities remain on
review for downgrade.  Current public ratings will be used for
securities that have undergone an in depth review by Moody's RMBS
team and are no longer on review for downgrade.


ARROYO I: Fitch Affirms Ratings on Four Classes of Notes
--------------------------------------------------------
Fitch Ratings has affirmed four classes of notes issued by Arroyo
I CDO, Ltd.

Since the last rating action in February 2009, the collateral has
deteriorated; however, this has been offset by increased credit
enhancement levels for the class A and B notes due to the
continuing deleveraging of the transaction.

As of the February 2010 trustee report, the current balance of the
portfolio is $124.4 million.  Defaulted securities, as defined in
the transaction's governing documents, now comprise 25.8% of the
portfolio, compared to 18.5% at last review.  Approximately 31.2%
of the portfolio has been downgraded since Fitch's last rating
action, resulting in 56.3% of the portfolio with a Fitch derived
rating below investment grade and 26.4% with a rating in the 'CCC'
rating category or below, as compared to 48.1% and 24.2%,
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 (SF PCM) for
projecting future default levels for the underlying portfolio.
These default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs -
Amended'.  Based on this analysis, the class A, class B, and class
C-1 and C-2 (class C) notes' breakeven rates are generally
consistent with the rating assigned below.

As of the February 2010 distribution date, approximately 87.7% of
the class A notes' original principal balance has amortized down.
As a result, the credit enhancement available to the class A notes
increased from 61%, at last review, to 68.4%.  Similarly, the
credit enhancement for the class B notes increased from 35.1% to
37.3%.  The credit enhancement for the class C notes decreased
slightly from 17.8% to 16.4%.

However, Fitch revised the Outlook to Negative from Stable for
classes A and B due to the concern over the transaction's ability
to meet timely interest payments on future distribution dates.
Significant interest rate swap payments owed by the transaction
have led to a shortfall of available interest proceeds to the
notes, causing approximately $0.7 million of principal proceeds on
the last payment date to be used to pay portion of the swap
payment and entire interest due to class A and B notes, thus
reducing the amount of principal proceeds available to pay down
the notes.  This diversion may continue through the next four
payment dates until the hedge schedule steps down in February
2012.

Additionally, the class A and class B notes are assigned a Loss
Severity rating of 'LS3'.  The LS rating indicates a tranche's
potential loss severity given default, as evidenced by the ratio
of tranche size to the base-case loss expectation for the
collateral, as explained in 'Criteria for Structured Finance Loss
Severity Ratings'.  Currently, for both classes this ratio falls
in the range of 1.1 to 4.0.  The LS rating should always be
considered in conjunction with the probability of default for
tranches.  Fitch does not assign LS ratings and Outlooks for
classes rated 'CCC' and lower.

Arroyo I is a structured finance collateralized debt obligation
that closed on Dec. 20, 2002, and is monitored by Western Asset
Management Company.  The transaction exited its reinvestment
period in August 2004.  The manager is currently restricted to
sales of defaulted, credit risk, or credit improved securities.
Presently Arroyo I's portfolio is comprised of 34% residential
mortgage-backed security assets, 29.2% commercial asset-backed
securities, 17% senior unsecured corporate bonds, 12.9% commercial
mortgage-backed securities, 4.6% real estate investment trust debt
securities, and 2.3% consumer ABS.

Fitch has affirmed and assigned LS ratings and revised Outlooks as
indicated to these classes:

  -- $39,272,186 class A notes at 'AA/LS3, Outlook revised to
     Negative from Stable;

  -- $38,800,000 class B notes at 'BBB/LS3', Outlook revised to
     Negative from Stable;

  -- $10,000,000 class C-1 notes at 'CCC';

  -- $16,000,000 class C-2 notes at 'CCC'.


BANC OF AMERICA: Fitch Takes Various Rating Actions on Notes
------------------------------------------------------------
Fitch Ratings has downgraded, and assigned Rating Outlooks, Loss
Severity ratings and Recovery Ratings, to Banc of America
Commercial Mortgage Inc., series 2003-2:

  -- $23.1 million class G to 'A/LS5' from 'AA-'; Outlook Stable;

  -- $21 million class H to 'BBB/LS5' from 'A'; Outlook Stable;

  -- $18.9 million class J to 'BB/LS5' from 'BBB+'; Outlook
     Negative;

  -- $10.5 million class K to 'B/LS5' from 'BBB-'; Outlook
     Negative;

  -- $10.5 million class L to 'B-/LS5' from 'BB'; Outlook
     Negative;

  -- $8.4 million class M to 'B-/LS5' from 'B+'; Outlook Negative;

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

  -- $10.1 million class O to 'C/RR6' from 'CCC/RR1'.

In addition Fitch has affirmed, assigned Rating Outlooks and LS
ratings:

  -- $412.3 million class A-1A at 'AAA/LS1'; Outlook Stable;
  -- $36.2 million class A-2 at 'AAA/LS1'; Outlook Stable;
  -- $168.1 million class A-3 at 'AAA/LS1'; Outlook Stable;
  -- $482.3 million class A-4 at 'AAA/LS1'; Outlook Stable;
  -- Interest-Only class X-C at 'AAA'; Outlook Stable;
  -- Interest-Only class X-P at 'AAA'; Outlook Stable.
  -- $56.7 million class B at 'AAA/LS4'; Outlook Stable;
  -- $21 million class C at 'AAA/LS5'; Outlook Stable;
  -- $44.1 million class D at 'AAA/LS4'; Outlook Stable;
  -- $23.1 million class E at 'AAA/LS5'; Outlook Stable;
  -- $21 million class F at 'AA/LS5'; Outlook Stable;
  -- $2.5 million class BW-A at 'AAA/LS1'; Outlook Stable;
  -- $1.1 million class BW-B at 'AAA/LS1'; Outlook Stable;
  -- $8.2 million class BW-C at 'AAA/LS1'; Outlook Stable;
  -- $2.5 million class BW-D at 'AAA/LS1'; Outlook Stable;
  -- $3.4 million class BW-E at 'AAA/LS1'; Outlook Stable;
  -- $3 million class BW-F at 'AAA/LS1'; Outlook Stable;
  -- $2.9 million class BW-G at 'AAA/LS1'; Outlook Stable;
  -- $2.5 million class BW-H at 'AAA/LS1'; Outlook Stable;
  -- $2.5 million class BW-J at 'AAA/LS1'; Outlook Stable;
  -- $2 million class BW-K at 'AAA/LS1'; Outlook Stable;
  -- $3.3 million class BW-L at 'AAA/LS1'; Outlook Stable.

Fitch does not rate the $23.3 million class P or classes HS-A
through HS-E.

The downgrades are the result of projected losses on the specially
serviced assets (9.3%) and future expected losses following
Fitch's prospective review of potential stresses to the
transaction.  Fitch expects losses of 3.1% of the remaining
transaction balance, or $43.2 million, from loans in special
servicing and loans that cannot refinance at maturity based on
Fitch's refinance test.  Rating Outlooks reflect the likely
direction of any changes to the ratings over the next one to two
years.

The BW-A through BW-L classes are associated with the 1328
Broadway loan which has fully defeased.

There are 128 of the original 152 loans remaining in the
transaction, 28 of which have defeased (30.6% of the current
transaction balance).

The largest specially serviced asset (2.72%) is secured by a mall
in Ogden, UT.  The loan transferred to special servicing April 20,
2009 due to the GGP bankruptcy.  GGP's bankruptcy plan was
confirmed at the end of 2009.  The loan has made last three
payments and is in the process of being returned to the master
servicer.

The second largest specially serviced asset (2.46%) is secured by
a manufactured home community in Justice, IL.  The loan
transferred Oct. 19, 2009, due to a mechanics lien being filed.
That led to discovery of additional mechanics liens and various
code violations.  The borrower cured the mechanics liens but the
special servicer continues to have questions regarding the
borrowers accounting.  The loan has a maturity of May 1, 2010 and
borrower has expressed difficulty in refinancing and has requested
an extension.

Fitch stressed the cash flow of the remaining non-defeased loans
by applying a 10% reduction to 2008 fiscal year end net operating
income and applying an adjusted market cap rate between 7.5% and
10% to determine value.

Similar to Fitch's prospective analysis of recent vintage CMBS,
each loan also underwent a refinance test by applying an 8%
interest rate and 30-year amortization schedule based on the
stressed cash flow.  Loans that could refinance to a debt service
coverage ratio of 1.25 times or higher were considered to pay off
at maturity.  Of the non-defeased or non-specially serviced loans,
none incurred a loss when compared to Fitch's stressed value.


BANC OF AMERICA: S&P Downgrades Rating on Eight 2002-X1 Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of commercial mortgage pass-through certificates from Banc
of America Structured Securities Trust's series 2002-X1.  S&P
placed these ratings and the ratings on three additional classes
from the same transaction on CreditWatch with negative
implications.

The collateral underlying Banc of America Structured Securities
Trust's series 2002-X1 consists of 45 commercial real estate
assets, including six with the special servicer, Berkadia
Commercial Mortgage.

The downgrades of seven classes reflect interest shortfalls.  The
CreditWatch placements reflect general liquidity concerns and the
potential for the trust to experience future shortfalls.  To date,
the interest shortfalls are primarily due to the lack of advancing
of trust expenses of one asset in foreclosure, as well as
appraisal subordinate entitlement reductions for two additional
specially serviced assets.  The lack of advancing on the
foreclosed asset follows a nonrecoverable advance declaration by
the master servicer, also Berkadia.  S&P anticipates that the
trust may experience additional shortfalls related to the trust
expenses, which include property operating expenses, property
taxes, and insurance payments.  As of the March remittance report,
the trust experienced interest shortfalls totaling $271,929, which
affected classes J through P.  S&P believes that the interest
shortfalls may increase in the near future, which could also
potentially affect classes E, F, and G.  Standard & Poor's will
resolve and/or update the CreditWatch placements after S&P has
further dialogue with Berkadia and perform a full analysis of the
waterfall.

As of the March 11, 2010, remittance report, the collateral pool
consisted of 45 loans with an aggregate trust balance of
$104.9 million.  Nine loans ($48.4 million, 46.2%) are defeased.
Of the six assets with the special servicer, one ($4.7 million,
4.5%) is real estate owned, one (4.4 million, 4.2%) is in
foreclosure, two ($9.0 million, 8.6%) are more than 90-days
delinquent, and two ($400,000, 0.4%) are more than 30-days
delinquent.  Two of the specially serviced assets have appraisal
reduction amounts in effect totaling $1.8 million.  To date, the
trust has experienced 11 losses totaling $5.5 million.  Details of
the three of six specially serviced assets that are causing the
interest shortfalls are:

The Village Park at Colleyville Shopping Center asset
($4.7 million, 4.52%) was transferred to the special servicer on
Aug. 26, 2009, due to imminent monetary default and is now REO.
The loan is secured by a 45,153-sq.-ft. retail property in
Colleyville, Texas.  An ARA totaling $962,074 is in effect for
this asset based on an appraisal of $3.9 million in October 2009.
As of the March 11, 2010, remittance report, the reported ASER was
$5,881, and the cumulative reported ASER was $12,393.  The Holiday
Inn ? Springfield loan ($4.4 million, 4.2%) was transferred to the
special servicer on Nov. 19, 2008, due to maturity default and is
now in foreclosure.  The loan is secured by a 244-room, full-
service, hotel property in Springfield, Ma.  The master servicer
declared future advances nonrecoverable on March 11, 2009.
Ongoing interest shortfalls due to the lack of interest advances
will be approximately $257,000 a month, including trust expenses,
interest not advanced and nonrecoverable amounts.  In addition,
there are approximately $1.5 million in outstanding advances on
this asset.  As of the March 11, 2010, remittance report, the
reported outstanding amount for this loan was $4.525 million.
Standard & Poor's expects a significant loss to the trust upon the
resolution of this asset.

The Comfort Inn ? Palm Springs loan ($4.2 million, 4.0%) was
transferred to the special servicer on March 1, 2009, due to
imminent monetary default and is now more than 90-days delinquent.
The loan is secured by a 129-room, limited-service, hotel property
in Palm Springs, Calif.  An ARA totaling $782,945 is in effect for
this asset based on an appraisal of $3.4 million in May 2009.  As
of the March 11, 2010, remittance report, the reported ASER was
$5,395, and the cumulative reported ASER was $34,877.  In
addition, there are approximately $575,000 in outstanding advances
on this asset.

        Ratings Lowered And Placed On Creditwatch Negative

            Banc of America Structured Securities Trust
   Commercial mortgage pass-through certificates series 2002-X1

                   Rating
                   ------
Class      To                   From      Credit enhancement (%)
-----      --                   ----      ----------------------
H          BBB+/Watch Neg       A                          45.44
J          BB+/Watch Neg        A-                         42.01
K          BB/Watch Neg         BBB+                       37.89
L          BB-/Watch Neg        BBB                        31.72
M          B+/Watch Neg         BBB-                       28.97
N          B/Watch Neg          BBB-                       26.23
O          CCC+/Watch Neg       BBB-                       23.48
P          CCC-/Watch Neg       BB+                        20.74

              Ratings Placed On Creditwatch Negative

           Banc of America Structured Securities Trust
  Commercial mortgage pass-through certificates series 2002-X1

                   Rating
                   ------
   Class      To             From       Credit enhancement (%)
   -----      --             ----       ----------------------
   E          A+/Watch Neg   A+                          65.34
   F          A/Watch Neg    A                           59.85
   G          A/Watch Neg    A                           53.68


BAYVIEW FINANCIAL: Fitch Downgrades Ratings on Class A Notes
------------------------------------------------------------
Fitch Ratings has downgraded one class within Bayview Financial
Asset Trust 2007-SSR2 transactions in the course of its ongoing
reviews.  The affected trust represents a beneficial ownership
interest in separate trust funds.

Fitch has downgraded, and assigned Recovery Ratings:

Bayview Financial Asset Trust 2007-SSR2

  -- Class A (07326CAC9) downgraded to 'CCC/RR2' from 'AAA'.

The notes are secured by underlying classes of asset-backed
securities (the Underlying Securities).  Each of the Underlying
Securities represents senior interest in an underlying pool of
loans consisting of fixed- and adjustable-rate residential
mortgage loans; small balance commercial, multi-family and mixed-
use loans; and installment contracts for the purchase of real
property.  The transactions also include senior interest in
underlying pools that consist of U.S. Small Business
Administration disaster assistance loans (SBA Assistance Loans).
The SBA Assistance Loans are secured by second liens on commercial
property or by various types of non-real estate collateral, or are
unsecured.

Bonds within the 2007 vintage transactions are being downgraded
due to the updated expected losses on the underlying loan pools
exceeding the initial loss projections.

In the BFAT 2007-SSR2 transaction the majority of the 10
Underlying Securities are undercollateralized, representing more
than 65% of their combined balance.  Further performance
deterioration in the loan portfolios securing the Underlying
Securities is expected.  As a result Fitch projects the 2007-SSR2
transaction itself to become undercollateralized, thereby
impairing the class A bond.  The initial credit enhancement of the
underlying bonds has decreased from a weighted average of 16% at
origination to -5% as of February 2010.  The deterioration of
enhancement is expected to continue as the losses projected on the
underlying pools are realized.

These rating actions reflect Fitch's expected collateral loss on
the underlying mortgage pools and cash flow analysis of each bond.

When determining each collateral pool's projected base-case loss,
Fitch used updated loan level information obtained from the
servicer (Bayview Loan Servicing, LLC; rated 'RSS2', 'RBSP2',
'SBSS2' by Fitch).  The frequency of foreclosure and loss severity
for the secured loans was derived using Fitch's proprietary loan-
level loss model as described in its Aug. 11, 2009 report,
'ResiLogic: U.S. Residential Mortgage Loss Model Criteria -
Amended', available at 'www.fitchratings.com'.  The ResiLogic FOF
results were performance adjusted to reflect the historical
performance of the individual transactions and, in some instances,
the lack of loan diversification resulting from a small remaining
pool size.  Loans that were determined to be unsecured were
assigned a 100% loss.

After determining each underlying pools' projected base-case and
stressed scenario loss assumptions, Fitch performs cash flow
analysis to ascertain the amount of collateral loss that the
transaction takes in the 'AAA-B' rating stresses.  Fitch's cash
flow assumptions are described in the Nov. 19, 2008 report,
'Updated Surveillance Criteria for U.S. Subprime RMBS'.  Fitch's
Cash flow Criteria is described in the report 'U.S RMBS Cash Flow
Analysis Criteria' published on Aug. 20, 2009.


BAYVIEW FINANCIAL: Fitch Takes Action on Four 2007-SSR1 Notes
-------------------------------------------------------------
Fitch Ratings has affirmed one and downgraded four classes within
Bayview Financial Asset Trust 2007-SSR1 in the course of its
ongoing reviews.  The affected trust represents a beneficial
ownership interest in separate trust funds.

Fitch has affirmed, downgraded, or assigned Recovery Ratings and
Outlooks:

Bayview Financial Asset Trust 2007-SSR1

  -- Class A (07325QAA3) affirmed at 'AAA'; Outlook Negative;

  -- Class M1 (07325QAB1) downgraded to 'A' from 'AA+'; Outlook
     Negative;

  -- Class M2 (07325QAC9) downgraded to 'B' from 'AA'; Outlook
     Negative;

  -- Class M3 (07325QAD7) downgraded to 'CCC/RR2' from 'AA-';

  -- Class M4 (07325QAE5) downgraded to 'CCC/RR2' from 'A+'.

The notes are secured by underlying classes of asset-backed
securities (the Underlying Securities).  Each of the Underlying
Securities represents senior interest in an underlying pool of
loans consisting of fixed- and adjustable-rate residential
mortgage loans; small balance commercial, multi-family and mixed-
use loans; and installment contracts for the purchase of real
property.  The transactions also include senior interest in
underlying pools that consist of U.S. Small Business
Administration disaster assistance loans (SBA Assistance Loans).
The SBA Assistance Loans are secured by second liens on commercial
property or by various types of non-real estate collateral, or are
unsecured.

Bonds within BFAT 2007-SSR1 are being downgraded due to the
updated expected losses on the underlying loan pools exceeding the
initial loss projections.

In BFAT 2007-SSR1 seven of the 22 Underlying Securities,
representing 35% of the combined balance, are currently
undercollateralized and putting negative credit pressure on the
subordinate bonds, resulting in downgrades.  The credit
enhancement of the underlying bonds has decreased from a weighted
average of 14% at origination to 5% as of February 2010.  The
deterioration of enhancement is expected to continue as the losses
projected on the underlying pools are realized.

These rating actions reflect Fitch's expected collateral loss on
the underlying mortgage pools and cash flow analysis of each bond.

When determining each collateral pool's projected base-case loss,
Fitch used updated loan level information obtained from the
servicer (Bayview Loan Servicing, LLC; rated 'RSS2', 'RBSP2',
'SBSS2' by Fitch).  The ResiLogic FOF results were performance
adjusted to reflect the historical performance of the individual
transactions and, in some instances, the lack of loan
diversification resulting from a small remaining pool size.  Loans
that were determined to be unsecured were assigned a 100% loss.

After determining each underlying pools' projected base-case and
stressed scenario loss assumptions, Fitch performs cash flow
analysis to ascertain the amount of collateral loss that the
transaction takes in the 'AAA-B' rating stresses.  Fitch's cash
flow assumptions are described in the Nov. 19, 2008 report,
'Updated Surveillance Criteria for U.S. Subprime RMBS'.  Fitch's
Cash flow Criteria is described in the report 'U.S RMBS Cash Flow
Analysis Criteria' published on Aug. 20, 2009.


BEAR STEARNS: Fitch Corrects Amended Loan Level Analysis
--------------------------------------------------------
Fitch Ratings has amended a press release originally published on
Jan. 8.  Among the changes made include amended loan level
analysis on the Park & Fly loan, which subsequently alters Fitch's
modeled loss on the loan.

Fitch takes various rating actions on Bear Stearns Commercial
Mortgage Securities Trust, 2005-Top20 commercial mortgage pass-
through certificates.

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 losses of 1.6% for this
transaction, should market conditions not recover.  The rating
actions are based on these full losses 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 12%, 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 53% of the pool and, in certain cases,
revised based on additional information and/or property
characteristics.

Approximately 83% of the mortgages mature within the next five
years: 8.2% in 2010, 6.9% in 2012, 3.2% in 2014 and 64.3% in 2015.

Fitch identified 28 Loans of Concern (17.8%) within the pool, two
of which (0.1%) are specially serviced.  Three of the Fitch Loans
of Concern (10.1%) are within the transaction's top 15 loans.

Fitch expects that 12 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 on most of them 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 term
loss: Circuit City Headquarters (1.6%).

Circuit City Headquarters consists of a 368,255 sf office property
in Richmond, VA.  The property formerly served as the headquarters
to Circuit City.  Following Circuit City's bankruptcy and
liquidation, the property has been vacant since April 2009.  The
loan remains current, but there is concern with the existing
operation's ability to continue to pay rent.  Fitch performed a
market value analysis in its determination of losses.

Fitch has adjusted its analysis on one loan within the pool's top
15: The Park N' Fly portfolio (2.4%).  Park N' Fly consists of a
four-property portfolio of parking garages, located in Atlanta,
Dallas, Cleveland, and Houston, totaling 8,818 spaces.  In Fitch's
January 2010 review, a term loss was calculated based on mid-year
2009 financial information provided by the servicer.  The
operating statements used in the January 2010 review indicated a
significant decline in performance from year-end 2008 to mid-year
2009.

Recently, it was determined this operating statement incorrectly
aggregated the total expenses for the portfolio.  Fitch received a
corrected operating statement from the servicer in March 2010,
which ultimately shows the portfolio did not experience a
performance decline to the degree originally thought.  The
portfolio's NOI DSCR as of third-quarter 2009 was 1.38x based on
the corrected operating statement.  Fitch incorporated the updated
cash flow into its analysis and determined the loan would not
incur a term loss; Fitch expects that if credit dislocation
persists and market conditions fail to improve, the loan could
default at maturity based on Fitch's stressed refinance test.

Fitch will review the year-end 2009 financials for all of the
loans in the pool as they become available and update the
transaction modeled losses accordingly.

Fitch downgrades and assigns LS Ratings and Outlooks to these
classes:

  -- $147.7 million class A-J to 'AA/LS2' from 'AAA'; Outlook
     Stable;

  -- $15.5 million Class B to 'AA/LS4' from 'AA+'; Outlook Stable;

  -- $20.7 million Class C to 'A/LS3' from 'AA'; Outlook Stable;

  -- $15.5 million Class D to 'A/LS4' from 'AA-'; Outlook Stable;

  -- $18.1 million Class F to 'BBB/LS4' from 'A-'; Outlook Stable;

  -- $18.1 million Class G to 'BBB-/LS4' from 'BBB+'; Outlook
     Stable;

  -- $23.3 million Class H to 'BB/LS3' from 'BBB'; Outlook Stable;

  -- $18.1 million Class J to 'B/LS4' from 'BBB-'; Outlook
     Negative;

  -- $5.2 million Class K to 'B/LS5' from 'BB+'; Outlook Negative;

  -- $7.8 million Class L to 'B-/LS5' from 'BB'; Outlook Negative;

  -- $7.8 million Class M to 'B-/LS5' from 'BB-'; Outlook
     Negative;

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

  -- $2.6 million Class O to 'B-/LS5' from 'B'; Outlook Negative;

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

  -- $28.5 million Class E at 'A/LS3'; Outlook Stable;
  -- $5.2 million Class P at 'B-/LS5'; Outlook Negative;
  -- $20 million Class LF at 'B/LS5'; Outlook Negative;

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

  -- $16.2 million class A-1 at 'AAA/LS1'; Outlook Stable;
  -- $189.5 million class A-2 at 'AAA/LS1'; Outlook Stable;
  -- $176 million class A-3 at 'AAA/LS1'; Outlook Stable;
  -- $142.6 million class A-AB at 'AAA/LS1'; Outlook Stable;
  -- $955 million class A-4A at 'AAA/LS1'; Outlook Stable;
  -- $130.8 million class A-4B at 'AAA/LS1'; Outlook Stable;
  -- Interest-only class X at 'AAA'; Outlook Stable;

Fitch does not rate class Q.


BEAR STEARNS: Fitch Takes Rating Actions on 2004-TOP16 Securities
-----------------------------------------------------------------
Fitch Ratings has downgraded and assigned Rating Outlooks, Loss
Severity ratings and Recovery Ratings to Bear Stearns Commercial
Mortgage Securities Trust 2004-TOP16 commercial mortgage pass-
through certificates:

  -- $11.6 million class G to 'BBB-/LS5' from 'BBB'; Outlook
     Stable;

  -- $10.1 million class H to 'BB/LS5' from 'BBB-'; Outlook
     Negative;

  -- $2.9 million class J to 'B/LS5' from 'BB+'; Outlook Negative;

  -- $4.3 million class K to 'B-/LS5' from 'BB'; Outlook Negative;

  -- $5.8 million class L to 'B-/LS5' from 'BB-'; Outlook
     Negative;

  -- $1.4 million class M to 'CCC/RR6' from 'B+';

  -- $1.4 million class N to 'CC/RR6' from 'B';

  -- $2.9 million class O to 'C/RR6' from 'B-'.

In addition Fitch has affirmed, assigned Rating Outlooks and LS
ratings:

  -- $92.2 million class A-4 at 'AAA/LS1'; Outlook Stable;
  -- $80 million class A-5 at 'AAA/LS1'; Outlook Stable;
  -- $676.1 million class A-6 at 'AAA/LS1'; Outlook Stable;
  -- Interest-Only class X-1 at 'AAA'; Outlook Stable;
  -- Interest-Only class X-2 at 'AAA'; Outlook Stable.
  -- $20.2 million class B at 'AA+/LS5'; Outlook Stable;
  -- $13 million class C at 'AA/LS5'; Outlook Stable;
  -- $13 million class D at 'A/LS5'; Outlook Stable;
  -- $15.9 million class E at 'A-/LS5'; Outlook Stable;
  -- $10.1 million class F at 'BBB+/LS5'; Outlook Stable.

Fitch does not rate the $4.2 million class P.  Classes A-1, A-2,
and A-3 have paid in full.

The downgrades are the result of projected losses on the two
specially serviced assets (1.58%) minimal future expected losses
following Fitch's prospective review of potential stresses to the
transaction.  Fitch expects losses of 1.22% of the remaining
transaction balance, or $11.8 million, from loans in special
servicing and loans that cannot refinance at maturity based on
Fitch's refinance test.  Rating Outlooks reflect the likely
direction of any changes to the ratings over the next one to two
years.

There are 105 of the original 117 loans remaining in the
transaction, twelve of which have defeased (11.4% of the current
transaction balance).

The largest specially serviced asset (1.44%) is secured by an
office building located in Foster City, CA.  The loan transferred
to special servicing on Dec. 8, 2009 due to monetary default.
Occupancy at the property has declined to 75% as of December 2009,
down from 84% in December 2008 and 99% in December 2007.  The
borrower is seeking a loan modification.

The second largest specially serviced asset (0.95%) is secured by
a retail property in Phoenix, AZ.  The loan transferred to special
servicing on Oct. 10, 2009.  The largest tenant, Basha Food City
(41.05% of NRA) cancelled its lease in bankruptcy and has vacated
the property thus reducing occupancy to 35%.  The special servicer
is moving forward with foreclosure and the auction is expected to
occur in June 2010.

Fitch stressed the cash flow of the remaining non defeased loans
by applying a 10% reduction to 2008 fiscal year end net operating
income and applying an adjusted market cap rate between 7.5% and
10% to determine value.

Similar to Fitch's prospective analysis of recent vintage CMBS,
each loan also underwent a refinance test by applying an 8%
interest rate and 30-year amortization schedule based on the
stressed cash flow.  Loans that could refinance to a debt service
coverage ratio of 1.25 times or higher were considered to payoff
at maturity.  Of the non-defeased or non-specially serviced loans,
none incurred a loss when compared to Fitch's stressed value.


BERNOULLI HIGH: Fitch Takes Rating Actions on Various Classes
-------------------------------------------------------------
Fitch Ratings has downgraded four and affirmed two classes of
notes issued by Bernoulli High Grade CDO I, Ltd., due to
deterioration in the credit quality of the portfolio since last
review.

As of the January 2010 trustee report, the current balance of the
portfolio is $1,196.2 million.  Defaulted securities, as defined
in the transaction's governing documents, now comprise 56.6% of
the portfolio, compared to 44.6% at last review in April 2009.
Approximately 70.3% of the portfolio has been downgraded since
Fitch's last rating action, resulting in 86.7% of the portfolio
with a Fitch derived rating below investment grade and 75.9% with
a rating in the 'CCC' rating category or below, as compared to
74.2% and 59.6%, respectively, at last review.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs'.  Due
to the extent of collateral deterioration and the sequential pay
structure following the acceleration of maturity, Fitch believes
that the likelihood of default for all classes of notes can be
assessed without using the Structured Finance Portfolio Credit
Model or performing cash flow model analysis under the framework
described in the 'Global Criteria for Cash Flow Analysis in CDOs -
Amended' report.

Based on the credit quality of the remaining portfolio, Fitch
believes default is highly probable for the class A-1B notes and
inevitable for all other classes of notes.  As a result of credit
events declared by the class A-1B swap counterparty, Merrill Lynch
International Bank, Ltd, the class A-1B notes were first drawn
upon on the January 2009 payment date and currently have a funded
and unfunded portion, in the amounts of $108.7 million, and
$216.8 million, respectively.  Future interest and principal cash
proceeds available after paying all timely classes' interest,
hedge, management fees and other administrative expenses, would be
used to first pay down the funded portion of the class A-1B.
Fitch expects the class A-1B notes to continue to be drawn upon to
settle future credit events in the portfolio.  A the same time,
due to the shrinking interest collection proceeds and an out-of-
the money interest rate swap, almost one third of the principal
collections on the last payment date in January were used to pay
interest on class A-1B, A-1A, A-2, class B notes and portion of
the interest rate swap.  The swap's notional gradually steps down
to a zero balance in 2021.  Given the composition of the portfolio
and ongoing principal leakage, which is expected to continue in
the future, Fitch considers that default on the class A-1B notes
is probable.

The class A-1A, A-2 and B notes are currently receiving full
interest payments, however, Fitch does not expect any principal
payments for these classes.  The class C and D notes have and will
continue to pay in kind, whereby the principal balances of the
notes are written up by the amount of interest owed due to the
coverage test failures.  Fitch does not expect any future interest
or principal payments to the class C and D notes.

Bernoulli I is a hybrid cash and synthetic arbitrage
collateralized debt obligation, which closed on March 30, 2006,
and is managed by Babcock & Brown Securities Pty Ltd.  The current
portfolio is composed of approximately 34.8% subprime residential
mortgage-backed securities, 32.2% of prime RMBS and 32.9% of
structured finance CDOs.

Fitch has downgraded these classes:

  -- $325,447,477 class A-1B notes to 'CC' from 'B';
  -- $856,376,278 class A-1A notes to 'C' from 'CCC';
  -- $86,536,865 class A-2 notes to 'C' from 'CC';
  -- $57,691,244 class B notes to 'C' from 'CC'.

Fitch has affirmed these classes:

  -- $15,562,184 class C notes at 'C';
  -- $16,181,410 class D notes at 'C'.

Fitch does not assign Outlooks to classes rated 'CCC' and lower.


BRISTOL CDO: Fitch Affirms Ratings on Two Classes of Notes
----------------------------------------------------------
Fitch Ratings has affirmed two and downgraded one class of notes
issued by Bristol CDO I, Ltd.

As of the January 2010 trustee report, the balance of the
portfolio was $87.9 million, including $30.8 million in par of
assets deemed defaulted as per the transaction's governing
documents.  Approximately 32.5% of the portfolio has been
downgraded since Fitch's last rating action in March 2009,
resulting in 63.7% of the portfolio with a Fitch derived rating
below investment grade and 47.9% with a rating in the 'CCC' rating
category or below, as compared to 59.7% and 41.1%, 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.  These default
levels were then compared to the breakeven levels generated by
Fitch's cash flow model of the CDO under various default timing
and interest rate stress scenarios, as described in the report
'Global Criteria for Cash Flow Analysis in CDOs - Amended'.

Based on this analysis, the class A-1 and A-2 (class A) notes'
breakeven rates are generally consistent with the rating assigned
below.  The affirmation of the class A notes is attributed to the
increase in credit enhancement available to the notes resulting
from principal amortizations and the application of interest
proceeds to pay down class A notes' balance, due to the continuing
failure of the class A/B overcollateralization test.  Since the
last review, approximately 3.6% of the class A notes' balance
amortized down thereby offsetting the effect of the collateral
deterioration.  Collectively, the class A notes represent 37.8% of
the current capital structure and have a credit enhancement of
57.2%.  However, Fitch revised the Outlook to Negative from Stable
for class A due to the potential for additional negative
performance in the underlying assets.  The class A notes are
highly dependent on the remaining few bonds, which introduces
potential performance and rating volatility.

Additionally, the class A 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'.  Currently, for the class A notes this ratio falls below
0.5.  The LS rating should always be considered in conjunction
with the probability of default for tranches.

Breakevens for the class B notes are below SF PCM's 'CCC' default
level, the lowest level of defaults projected by SF PCM.  For this
class, Fitch compared the credit enhancement level to the amount
of underlying assets considered distressed (rated 'CCC' and
lower).  These assets have a high probability of default and low
expected recoveries upon default.  The class B notes have the
credit enhancement level of 23.4%, half the share of the portfolio
rated 'CCC' and lower.  While the class B notes are still
receiving their timely interest distributions, Fitch believes that
default is inevitable at or prior to maturity.

Bristol I is a cash flow collateralized debt obligation, which
closed on Oct. 11, 2002, and is managed by Vanderbilt Capital
Advisors LLC.  The current portfolio is comprised of approximately
30.7% residential mortgage-backed securities, 28.5% commercial
asset-backed securities, 23.5% structured finance CDOs, 9.8%
commercial mortgage-backed securities, and 7.5% of consumer ABS.

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

  -- $34,725,994 class A-1 notes affirmed at 'BB/LS5'; Outlook
     revised to Negative from Stable;

  -- $3,185,158 class A-2 notes affirmed at 'BB/LS5'; Outlook
     revised to Negative from Stable;

  -- $30,000,000 class B notes downgraded to 'C' from 'CC'.


COMM 2004-LNB4: Moody's Affirms Ratings on Three Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of three classes,
confirmed one class and downgraded 16 classes of COMM 2004-LNB4,
Commercial Mortgage Pass-Through Certificates.  The downgrades are
due to higher losses for the pool resulting from realized and
anticipated losses from specially serviced and highly leveraged
watchlisted loans, interest shortfalls, and refinancing risk
associated with loans approaching maturity in an adverse
environment.  Eight loans, representing 6% of the pool, mature
within 36 months and have a Moody's stressed debt service coverage
ratio less than 1.0X.

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

Moody's placed 15 classes of this transaction on review for
possible downgrade on December 3, 2009, due to anticipated losses
from specially serviced and poorly performing loans as well as
interest shortfalls.  On March 18, 2010, the review was continued
and two additional classes were placed on review for possible
downgrade due to higher anticipated losses than originally
projected.  This action concludes the review.

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

As of the March 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 21% to
$965.7 million from $1.2 billion at securitization.  The
Certificates are collateralized by 103 mortgage loans ranging in
size from less than 1% to 8% of the pool, with the top ten loans
representing 40% of the pool.  The pool contains one loan,
representing 7% of the pool, which has an investment grade
underlying rating.  At last review, two other loans, representing
5% of the pool, also had investment grade underlying ratings.
However, due to declines in performance and increased leverage,
these loans are now analyzed as part of the conduit pool.

Twenty loans, representing 14% 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.

Three loans have been liquidated from the pool resulting in a
$12.0 million loss (36% loss severity on average).  There are 11
loans, representing 13% of the pool, currently in special
servicing.  The largest specially serviced loan is Metro I
Building Loan ($37.0 million -- 3.8% of the pool), which is
secured by a 310,000 square foot office building located in
Hyattsville, Maryland.  The property has experienced a significant
decline in occupancy due to lease rollovers.  The loan transferred
to special servicing in May 2009 for imminent default and the loan
is now 90+ days delinquent.  The servicer has recognized a
$21.6 million appraisal reduction for this loan.

The second largest specially serviced loan is the Lakeshore
Apartments Loan ($19.4 million -- 2.0% of the pool), which is
secured by a 652-unit multifamily property located in Clarkston,
Georgia.  The property was 77% occupied as of March 2009.  The
loan transferred to special servicing in May 2009.  The loan is
current and is expected to be returned to the master sevicer soon.

The remaining nine specially serviced loans are secured by a mix
of office, retail, and manufactured housing properties.  Moody's
estimates a $63 million aggregate loss for 11 of the specially
serviced loans (50% loss severity on average).  The special
servicer has recognized an aggregate $44.4 million appraisal
reduction for seven of the specially serviced loans.

Moody's has assumed a high default probability on four loans
representing approximately 2% of the pool.  These loans mature
within the next 36 months and have a Moody's stressed DSCR less
than 1.0X.  Moody's has estimated an aggregate $2.8 million loss
from these loans based on a 50% default probability and a 40% loss
severity.  Moody's rating action recognizes potential uncertainty
around the timing and magnitude of losses from these troubled
loans.

Based on the most recent remittance statement, Classes G through
P have experienced cumulative interest shortfalls totaling
$1.7 million.  Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced loans.  Interest shortfalls are caused by
special servicing fees, including workout and liquidation fees,
appraisal subordinate entitlement reductions and extraordinary
trust expenses.

Moody's was provided with full-year 2008 operating results for 95%
of the pool.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 92% compared to 96% at last
review.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.43X and 1.13X, respectively, compared to
1.43X and 1.07X at Moody's last review.  Moody's actual DSCR is
based on Moody's net cash flow and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF 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 33 compared to 39 at last review.

The loan with an underlying rating is the 731 Lexington Avenue
Loan ($64.8 million -- 6.7% of the pool), which is secured by a
694,000 square foot office condominium.  The collateral is part of
a 1.4 million square foot complex in midtown Manhattan situated on
Lexington Avenue between East 58th and East 59th Streets.  The
condominium is 100% leased to Bloomberg, LP, through 2028.
Moody's current underlying rating is A3, the same as at last
review.

The largest loan that previously had an underlying rating is the
280 Trumbull Street Loan ($32.4 million -- 3.3% of the pool),
which is secured by a 660,000 square foot Class A office tower
located in Hartford, Connecticut.  The property was 78% leased as
of November 2009 compared to 88% at last review and 95% at
securitization.  The two largest tenants are Prudential Insurance
Company of America, which leases 39% of the net rentable area
(NRA) through December 2017, and Robinson & Cole, which leases 22%
of the NRA through December 2016.  Performance has declined since
last review due to the decrease in occupancy.  Moody's LTV and
stressed DSCR are 95% and 1.02X, respectively, compared to 67% and
1.46X at securitization.

The second loan that previously had an underlying rating is the
DDR Portfolio Loan ($15.3 million -- 1.6% of the pool), which is a
pari passu interest in a $135.2 million first mortgage loan.  The
loan is secured by 20 retail properties located throughout six
states and totaling 3.3 million square feet.  The portfolio was
71% leased as of June 2009 compared to 96% at securitization.
Performance has declined significantly because of occupancy
declines and increased operating expenses.  The loan was
transferred to special servicing in May 2009 for imminent maturity
default.  The borrower was not able to obtain refinancing on its
June 1, 2009 maturity date.  The maturity date has been extended
until June 2011 and the loan has been transferred back to the
master servicer.  Moody's considers this loan a significant
default risk because of its high leverage.  Moody's LTV and
stressed DSCR are 140% and 0.73X, respectively, compared to 72%
and 1.39X at last review.

The three largest performing conduit loans represent 15% of the
pool.  The largest conduit loan is the Crossings at Corona-Phase I
& II Loan ($77.0 million -- 7.9% of the pool), which is secured by
the borrower's interest in a 878,000 square foot retail center
located in Corona, California, approximately 55 miles southeast of
downtown Los Angeles.  The property was 96% leased as of June 2009
compared to 99% at last review.  The largest tenants are Kohl's,
Best Buy and Gart's Sportmart.  The center is also shadow anchored
by Target.  Moody's LTV and stressed DSCR are 102% and 0.90X,
respectively, compared to 100% and 0.92X at last review.

The second largest loan is the Woodyard Crossing Shopping Center
Loan ($40.3 million -- 4.2% of the pool), which is secured by the
borrower's interest in a 483,000 square foot retail center located
in Clinton (Prince George's County), Maryland.  The property was
100% leased as of July 2009, the same as at last review.  The
largest tenants include Wal-Mart, which leases 28% of the NRA
through October 2020, Lowe's, which leases 24% of the NRA through
April 2021, and Safeway, which leases 12% of the NRA though
December 2019.  Performance has been stable and the loan has
benefited from amortization.  The loan has amortized 6% since last
review.  Moody's LTV and stressed DSCR are 79% and 1.20X,
respectively, compared to 84% and 1.10X at last review.

The third largest loan is the GMAC Building Loan ($32.4 million --
3.3% of the pool), which is secured by a 532,000 square foot
office building located in Winston Salem, North Carolina.  The
property is 100% leased to GMAC Insurance on a lease expiring in
2014.  The loan was transferred to special servicing in August
2009 for imminent maturity default.  The borrower was not able to
refinance the loan on its October 1, 2009 maturity.  The maturity
date has been extended until April 2011 and the loan has been
transferred back to the master servicer.  Moody's is still
concerned about the refinancing risk associated with this loan.
Moody's LTV and stressed DSCR are 110% and 0.94X, respectively,
compared to 84% and 1.22X at Moody's last review.

Moody's rating action is:

  -- Class A-2, $18,245,654, affirmed at Aaa; previously assigned
     Aaa on 12/1/2004

  -- Class A-3, $86,461,000, confirmed at Aaa; previously placed
     on review for possible downgrade on 3/18/2010

  -- Class A-4, $88,047,000, downgraded to Aa3 from Aaa;
     previously placed on review for possible downgrade on
     3/18/2010

  -- Class A-5, $343,272,000, downgraded to Aa3 from Aaa;
     previously placed on review for possible downgrade on
     3/18/2010

  -- Class A-1A, $287,699,886, downgraded to Aa3 from Aaa;
     previously placed on review for possible downgrade on
     3/18/2010

  -- Class X-C, Notional, affirmed at Aaa; previously assigned Aaa
     on 12/1/2004

  -- Class X-P, Notional, affirmed at Aaa; previously assigned Aaa
     on 12/1/2004

  -- Class B, $24,442,000, downgraded to A2 from Aaa; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class C, $10,693,000, downgraded to Baa2 from Aa2; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class D, $22,914,000, downgraded to Ba2 from A2; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class E, $10,694,000, downgraded to B2 from A3; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class F, $15,276,000, downgraded to Caa2 from Baa1;
     previously placed on review for possible downgrade on
     3/18/2010

  -- Class G, $15,276,000, downgraded to Ca from Baa2; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class H, $12,221,000, downgraded to C from Baa3; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class J, $4,583,000, downgraded to C from Ba1; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class K, $3,055,000, downgraded to C from Ba2; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class L, $6,111,000, downgraded to C from Ba3; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class M, $7,638,000, downgraded to C from B2; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class N, $3,055,000, downgraded to C from B3; previously
     placed on review for possible downgrade on 3/18/2010

  -- Class O, $3,055,000, downgraded to C from Caa1; previously
     placed on review for possible downgrade on 3/18/2010


COMM 2008-RS3: Moody's Reviews 11 Classes of Certificates
---------------------------------------------------------
Moody's Investors Service placed eleven classes of Certificates
issued by COMM 2008-RS3 Commercial Mortgage Related Securities,
Series 2008-RS3 under review for possible downgrade due to
deterioration in the credit quality of the underlying portfolio as
evidenced by deterioration in the weighted average rating factor.
The rating action is the result of Moody's on-going surveillance
of commercial real estate collateralized debt obligation
transactions.

COMM 2008-RS3 is a direct pass-through of Class A-2A, Class A-2B,
Class X-W, Class X-B, Class C, Class E, Class F, Class G, Class H,
Class J and Class K (together the Underlying Classes) of the Max
CMBS I Ltd., Series 2008-1 transaction.  As of the February 18,
2010 Trustee Report issued for Max Series 2008-1, the aggregate
balance of the Underlying Classes was $379 million, the same as
that at securitization.  This rating action is a result of placing
on review for possible downgrade the Underlying Classes on
March 19, 2010.

The rating action is:

  -- Class A-2A, Aa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Aa3

  -- Class A-2B, Aa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Aa3

  -- Class X-W*, Aa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Aa3

  -- Class X-B*, Aa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Aa3

  -- Class B, A2 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to A2

  -- Class C, A3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to A3

  -- Class D, Baa1 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Baa1

  -- Class E, Baa2 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Baa2

  -- Class F, Baa2 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Baa2

  -- Class G, Baa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Baa3

  -- Class H, Ba1 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Ba1

  * Notional Class

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 19, 2009.


COMMONWEALTH PORTS: Fitch Affirms 'CCC' Rating on $15 Mil. Bonds
----------------------------------------------------------------
Fitch Ratings affirms the 'CCC' rating and removes from rating
Watch Negative the $15 million in outstanding Commonwealth Ports
Authority, Commonwealth of the Northern Mariana Islands, 1998
senior series A airport revenue bonds.  The Rating Outlook is
Negative.  The bonds are secured by a pledge of net revenues.

The 'CCC' rating indicates that significant credit risk is present
and that a limited margin of safety remains due to declining
activity levels in a tourist-based economy; below 1.0 times (x)
coverage of debt service obligations that necessitates the use of
fund balance draws to meet the bond payments; and high dependence
on airline revenue.  The rating also reflects the recent actions
taken by the CPA to prevent further deterioration in its ability
to service the 1998 series A debt.  The CPA has narrowed its
revenue shortfall by implementing austerity measures, reinstating
airline rates and charges and pursuit of non-aeronautical revenue.
CPA is currently receiving reimbursements of funds from the
Commonwealth Utilities Corporation and grants from the TSA and
Homeland Security for work done on airport property.  A passenger
facility charge (PFC) hardship application was also filed which,
if approved, could allow for greater use of PFC revenue to cover
debt service.  The credit is also strengthened by the essentiality
of the airports serving as a key gateway to and within the CNMI,
and CNMI's ability to continue to draw visitors from new markets.
Fitch notes that the last audited financial statement for the CPA
was 2007.  While Fitch has been provided with drafts of the 2008
and 2009 audits and a 2010 budget, this is a concern.

The Negative Outlook reflects the possibility of continued cash
balance depletion over the next three years given comments of
further service cuts and the potential for intermigration to Guam.
Revision of airline rates and charges, additional non-aviation
revenue generating activities, continued tightening of expenses
and approval of additional PFC allocation for debt service could
delay the depletion of liquidity in the near term.  Given the
current state of the global economy and expectations of a slow
economic recovery, service adjustments in the airline industry are
likely to continue over the near term and may present additional
challenges to CPA's finances and operations, as will CNMI's
deteriorating local economic landscape and geographical location
that leaves it exposed to weather related risk (i.e. typhoons).
The U.S planned relocation of approximately 8,000 military
personnel and their dependents from Okinawa, Japan to neighboring
Guam by 2014 could also lead to migration from the CNMI for better
job opportunities.

CNMI continues to draw visitors and develop new markets such as
those in Korea, Russia, China, and the Philippines.  The strong
presence by Asiana Airlines in 2009, representing 125,130
enplanements at Saipan International Airport, up 64.7% from 2005,
reflects CPA's continued efforts in developing its tourism-based
economy.  Furthermore, the successful implementation of a PFC
program, management's proven history of obtaining FAA grants and
strong relationship with the CNMI government also enhance the
credit.

Fitch expects that the CPA will continue to experience volatility
in its near break-even operations and will continue to use
internal liquidity to sustain operations and meet debt service
needs.  The fluctuation in operations is due to a weak underlying
economy driven solely by a diminished tourism industry and the
loss of the garment industry.  The implementation of minimum wage
laws in 2007 and the federalization of immigration in 2008
completely phased out the garment industry which in 2005 generated
over $650 million in export revenue for the CNMI.  As CNMI is a
commonwealth of the United States, U.S. federal law and
regulation, such as minimum wage law requirements, immigration
restrictions, and environmental regulation all have an impact on
the island's economy.  Although the Islands have seen an increase
in tourism from Korea, China, Russia, and the Philippines,
enplanements have been steadily declining since 2005, driven by a
significant loss in lucrative Japanese tourism to the Islands.  In
2009, Japanese visitors to the CNMI fell by approximately 10.3%
compared to the previous year.  Since the departure of Japan
Airlines, carrier service to CNMI is concentrated with two
carriers, Delta Airlines (Issuer Rating: 'B-', Negative Outlook by
Fitch), and Asiana Airlines together accounting for over 70% of
total enplanements leaving CPA vulnerable to any operational
changes made by the airlines.  Traffic continued to decline across
the three airports through fiscal 2009, representing an overall
decrease of 28% over 2005.  Traffic appears to be testing a new
low of 475,769 enplanements down from 511,001 in 2008 or 6.9%.

CPA's operating and financial profile remains weak due to
sustained losses in tourist traffic and past decisions to
subsidize airlines resulting in rate covenant violations.  Fiscal
year 2007 and 2008 debt service coverage was a negative 0.34x and
0.61x, respectively, while 2009 saw a positive 0.62x coverage.
Although operating revenues jumped 25% or $2.1 million in fiscal
2009 from $8.5 million the year before, decreases of 10.5% and
12.4% were seen in 2007 and 2008, respectively.  Aviation and
concession revenue continue to be challenged given the smaller
base of traffic.  Containing expenditure resulted in a 9.6% and
7.5% reduction in expenses in 2007 and 2008, respectively, and a
modest increase of 3.3% in 2009.  CPA continues to make efforts to
reduce operating expenses through the use of scheduled work
reductions and the elimination of non-essential expenses.
Operating income turned positive in fiscal 2009 with a profit of
$455,225 from a loss of $1.3 million just the year before.  Cost
per enplanement soared to $15.9 in 2009 from $9.9 the year before
largely owed to the considerable decline in enplanements.  CPA
will continue to be challenged to balance operating expense
reductions and airline rate increases as remaining cost
competitive is deemed necessary to securing a sustainable tourist
market in the CNMI.

The CPA owns and operates three airports in the CNMI, the largest
of which is Saipan International Airport.  The commonwealth
consists of a chain of 14 islands of which four are inhabited.
The islands are located in the North Pacific Ocean, approximately
1,458 miles southeast of Tokyo, Japan and 5,969 miles west of Los
Angeles.


COMMONWEALTH PORTS: Fitch Gives Neg. Outlook; Affirms 'BB-' Rating
------------------------------------------------------------------
Fitch Ratings revises the Rating Outlook to Negative from Stable
on approximately $35 million of the Commonwealth Ports Authority,
Commonwealth of the Northern Mariana Islands, 1998 and 2005 senior
series A seaport revenue bonds.  Fitch also affirms the rating at
'BB-'.  The bonds are secured by a pledge of net revenues.

The 'BB-' rating of the seaport credit indicates the possibility
of credit risk developing due to the deterioration of the CNMI
economy in the past two years, however, a margin of safety and
sufficient cash balances remain allowing financial commitments to
be met.  The loss of the garment industry has had material impact
on CPA's harbour operations while a fragile tourism industry has
led to a reduction in productivity on the Islands.  However, CPA's
seaports will remain essential to the transportation of goods via
international and internal waterways.  Total revenue tonnage for
fiscal 2009 fell by 22.9% or 108,822 revenue tons from 474,274 in
the previous year.  Outbound cargo sharply decreased by 51% and is
largely responsible for this downward trend as ready-for-sale
clothing products, once manufactured by the garment industry, are
no longer being exported.  As of September 2009, total outbound
clothing tonnage and inbound garment tonnage came to a complete
halt from over 6,252 revenue tons in October 2007.  Fitch notes
that the last audited financial statement for the CPA was 2007.
While Fitch has been provided with drafts of the 2008 and 2009
audits and a 2010 budget, this is a concern.

The Negative Outlook reflects the possibility of a restrained
capacity to meet financial commitments if CPA's business profile
and CNMI's economic environment continue to be unfavorable.  The
overall economy of the CNMI is in decline and will likely take
several years for seaport operations to be adequately sized for a
more stabilized economy.  As CNMI is a commonwealth of the United
States, U.S. federal law and regulation, such as minimum wage law
requirements, immigration restrictions, and environmental
regulation all have an impact on the island's economy.  While CPA
has historically exhibited strong cash flows and a healthy balance
sheet, the port's ability to return to its historical financial
strength will require a sustained increase in wharfage rates which
will undoubtedly have a dampening effect on demand and will
increase the cost of goods across the islands.  The U.S planned
relocation of approximately 8,000 military personnel and their
dependents from Okinawa, Japan to Guam by 2014 is expected to
boost Guam's economy and could lead to migration from the CNMI.

CPA's continued financial weakness resulted in a 0.76 times (x)
debt service coverage ratio for 2008 recovering in 2009 at 1.30x
and budgeted to be at 1.20x in 2010.  Cash balances remain
adequate but have weakened with days-cash-on-hand falling to 154
days in 2009 from 537 days in 2007.  Harbor generated revenue for
fiscal 2009 grew by 25.2% to 4.4 million due to the upward
revision of wharfage rates whereas non-harbor revenue merely grew
by 1%.  CPA's total operating revenue improved by 17.5% in 2009 to
6 million from 5.1 million just the year before.  Cost cutting
measures resulted in a decrease of 27.3% in expenses over 2008.

CPA will continue to feel the effects of a weakening CNMI economy
and will remain vulnerable to operational and financial shocks,
including the island's economic volatility, weather events (such
as typhoons), and U.S. federal government policy.  These risks,
coupled with CPA's limited rate making flexibility will most
likely further strain CPA's operations and squeeze cash balances
in the medium term.

The CPA owns and operates three seaports in the CNMI, the largest
of which Is the Port of Saipan.  The commonwealth consists of a
chain of 14 islands of which four are inhabited.  The islands are
located in the North Pacific Ocean, approximately 1,458 miles
southeast of Tokyo, Japan and 5,969 miles west of Los Angeles.


COOLIDGE FUNDING: Moody's Downgrades Ratings on Three Classes
-------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of three classes of notes issued by Coolidge Funding, Ltd.
The notes affected by the rating action are:

  -- US$274,700,000 Class A-1 Floating Rate Notes due 2040
     (current balance of $171,821,529.00), Downgraded to Caa3;
     previously on March 24, 2009 Downgraded to Ba3;

  -- US$45,100,000 Class A-2 Floating Rate Notes due 2040 (current
     balance of $30,464,011.14), Downgraded to Ca; previously on
     March 24, 2009 Downgraded to Caa2;

  -- US$37,515,000 Class B Floating Rate Notes due 2040 (current
     balance of $30,743,483.14), Downgraded to C; previously on
     March 24, 2009 Downgraded to Ca.

Coolidge Funding, Ltd., is a collateralized debt obligation
issuance backed by a portfolio of Commercial Mortgage-Backed
Securities and Residential Mortgage-Backed Securities with the
majority originated in 2004.

According to Moody's, the rating downgrade action is the result of
deterioration in the credit quality of the underlying portfolio.
Such credit deterioration is observed through numerous factors,
including a decline in the average credit rating of the portfolio
(as measured by an increase in the weighted average rating
factor), an increase in the dollar amount of defaulted securities,
and failure of the coverage tests.  The weighted average rating
factor, as reported by the trustee, has increased from 1220 in
March 2009 to 1830 in March 2010.  During the same time, defaulted
securities increased from $47.3 million to $81.4 million.  In
addition, the Trustee reports that the transaction is currently
failing all principal coverage tests, including the Class A/B
Overcollateralization Test.

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 and features in each transaction, recent deal
performance in the current market environment, the legal
environment and specific documentation features.  All information
available to rating committees, including macroeconomic forecasts,
input from other Moody's analytical groups, market factors, and
judgments regarding the nature and severity of credit stress on
the transactions, may influence the final rating decision.


CREDIT AND REPACKAGED: S&P Withdraws 'CCC-' Rating on Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services withdrew its rating on the
notes issued by Credit and Repackaged Securities Ltd.'s series
2006-12, a synthetic corporate investment-grade collateralized
debt obligation transaction.

The rating withdrawal follows the complete redemption of the notes
pursuant to the notice dated March 2, 2010.

                         Rating Withdrawn

               Credit and Repackaged Securities Ltd.
                          Series 2006-12

                      Rating           Balance (mil. $)
                      ------           ----------------
      Class         To      From      Current      Previous
      -----         --      ----      -------      --------
      Trust units   NR      CCC-      0.000        15.000

                          NR - Not rated.


CREDIT SUISSE: Moody's Affirms Ratings on Six 2002-CKP1 Certs.
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings of six classes and
downgraded ten classes of Credit Suisse First Boston Commercial
Mortgage Corp., Commercial Mortgage Pass-Through Certificates,
Series 2002-CKP1.  The downgrades are due to higher expected
losses for the pool resulting from realized and anticipated losses
from specially serviced and other highly leveraged loans.

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

Moody's placed ten classes of this transaction on review for
possible downgrade on March 4, 2009, due to anticipated losses
from loans in special servicing.  This action concludes the
review.  The rating action is the result of Moody's on-going
surveillance of commercial mortgage backed securities
transactions.

As of the February 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 19% to
$808.8 million from $992.9 million at securitization.  The
Certificates are collateralized by 141 mortgage loans ranging in
size from less than 1% to 7% of the pool, with the top ten non-
defeased loans representing 39% of the pool.  Twenty-six loans,
representing 22% of the pool, have defeased and are secured by
U.S. Government securities.  Defeasance at last review represented
21% of the pool.

Twenty-eight loans, representing 10% of the pool, are on the
master servicer's watchlist.  The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the Commercial Mortgage Securities Association's monthly reporting
package.  As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.

Sixteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $23.5 million (41% loss severity on
average).  Seven loans, representing 4% of the pool, are currently
in special servicing.  The largest specially serviced loan is the
Seville Place Apartments Loan ($11.7 million - 1.4% of the pool),
which is secured by a 444-unit apartment complex located in
Orlando, Florida.  The loan was transferred to special servicing
in January 2009 for imminent default and is now 90+ days
delinquent.  The remaining six specially serviced loans are
secured by a mix of multifamily, office and retail properties.
Moody's has estimated a $22.3 million aggregate loss for the seven
specially serviced loans (62% loss severity on average).

Moody's has assumed a high default probability on ten loans,
representing 5% of the pool.  These loans mature within the next
36 months and have a Moody's stressed DSCR less than 1.0X.
Moody's has estimated a $9.8 aggregate loss on these loans (25%
loss severity on average).

Moody's was provided with year-end 2008 and partial-year 2009
operating statements for 99% and 47%, respectively, of the pool.
Moody's weighted average LTV for the conduit pool, excluding
specially serviced and troubled loans, is 79%, essentially the
same as Moody's prior full review.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.30X and 1.33X, respectively, compared to
1.34X and 1.32X at last review.  Moody's actual DSCR is based on
Moody's net cash flow and the loan's actual debt service.  Moody's
stressed DSCR is based on Moody's NCF 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 29 compared to 31 at last review.

The top three loans represent 19% of the pool.  The largest loan
is the Metroplex West Loan ($59.4 million -- 7.3% of the pool),
which is secured by the borrower's interest in a 477,000 square
foot retail center located in Plymouth Meeting, Pennsylvania.  The
center is anchored by Target and Lowe's, both of which own their
respective buildings and are not part of the collateral.  As of
October 2009, the property was 100% leased, the same last review.
Despite stable occupancy, property performance has declined since
last review due to lower revenues.  Moody's LTV and stressed DSCR
are 77% and 1.33X, respectively, compared to 72% and 1.42X at last
review.

The second largest loan is the 300 M Street Office Building Loan
($48.0 million -- 5.9% of the pool), which is secured by 280,000
square foot Class A office building located in Washington, D.C.
As of June 2009 the property was 100% leased, the same as last
review.  The largest tenants are Northrop Grumman (33% of the net
rentable area (NRA); lease expiration April 2011) and Lockheed
Martin Corporation (26% of the NRA; lease expiration April 2011).
Although property performance has been stable since last review,
Moody's analysis reflects a stressed cash flow due to Moody's
concerns about the property's significant lease rollover in 2011.
Moody's LTV and stressed DSCR are 77% and 1.37X, respectively,
compared to 70% and 1.50X at last review.

The third largest loan is The Shops at Deerfield Square Loan
($45.5 million -- 5.6% of the pool), which is secured by a mixed-
use property that includes 170,000 square feet of retail and
67,000 square feet of office space located in Deerfield, Illinois.
The property was 100% leased as of January 2010, the same as last
review.  Moody's LTV and stressed DSCR are 90% and 1.08X,
respectively, compared to 85% and 1.18X at last review.

Moody's rating action is:

  -- Class A-2, $37,752,943, affirmed at Aaa; previously assigned
     Aaa on 3/25/2002

  -- Class A-3, $601,059,000, affirmed at Aaa; previously assigned
     Aaa on 3/25/2002

  -- Class A-X, Notional, affirmed at Aaa; previously assigned Aaa
     on 3/25/2002

  -- Class B, $39,715,000, affirmed at Aaa; previously upgraded to
     Aaa from Aa2 on 3/16/2006

  -- Class C, $13,652,000, affirmed at Aaa; previously upgraded to
     Aaa from Aa3 on 3/16/2006

  -- Class D, $26,063,000, downgraded to Aa1 from Aaa; previously
     placed on review for possible downgrade on 3/4/2010

  -- Class E, $14,893,000, downgraded to Aa3 from Aa1; previously
     placed on review for possible downgrade on 3/4/2010

  -- Class F, $13,652,000, downgraded to A3 from Aa3; previously
     placed on review for possible downgrade on 3/4/2010

  -- Class G, $14,893,000, downgraded to Baa3 from A2; previously
     placed on review for possible downgrade on 3/4/2010

  -- Class H, $14,893,000, downgraded to Ba2 from Baa1; previously
     placed on review for possible downgrade on 3/4/2010

  -- Class K-Z, $19,875,000, downgraded to B3 from Ba1; previously
     placed on review for possible downgrade on 3/4/2010

  -- Class L, $16,134,000, downgraded to Caa3 from Ba2; previously
     placed on review for possible downgrade on 3/4/2010

  -- Class M, $8,688,000, downgraded to C from Ba3; previously
     placed on review for possible downgrade on 3/4/2010

  -- Class N, $7,447,000, downgraded to C from B3; previously
     placed on review for possible downgrade on 3/4/2010

  -- Class O, $8,687,000, downgraded to C from Caa1; previously
     placed on review for possible downgrade on 3/4/2010

  -- Class P, $2,595,521, affirmed at C; previously downgraded to
     C from Caa2 on 3/4/2010


DETROIT MEDICAL: Fitch Puts Bonds' 'BB' Ratings on Positive Watch
-----------------------------------------------------------------
Fitch Ratings places these bonds issued on behalf of Detroit
Medical Center, which are currently rated 'BB', on Rating Watch
Positive:

  -- $112,730,000 Michigan State Hospital Finance Authority series
     1993A;

  -- $132,285,000 Michigan State Hospital Finance Authority series
     1993B;

  -- $174,460,000 Michigan State Hospital Finance Authority series
     1997A;

  -- $108,650,000 Michigan State Hospital Finance Authority series
     1998A;

  -- $75,000,000 Michigan State Hospital Finance Authority series
     1995.

The decision to place the bonds on Rating Watch Positive is in
response to the March 19, 2010 announcement that Detroit Medical
Center and Vanguard Health Systems, Inc. (not rated by Fitch) have
entered into a non-binding Letter-of-Intent for substantially all
of the assets and liabilities of DMC to be acquired by Vanguard.
Should the acquisition of DMC by Vanguard be consummated, all of
the outstanding bonds listed above would be defeased
contemporaneously with the closing of the acquisition and all of
the bonds would be paid or redeemed within 90 days of the closing.

As outlined in the announcement, no assurance can be given that
the execution of the LOI will lead to the execution of a
definitive agreement for the acquisition or that an acquisition
will be completed in the form currently contemplated.  Among other
requirements:

  -- both parties must negotiate an acceptable definitive
     agreement that is approved by each party's' Board of
     Directors;

  -- the transaction must receive regulatory approvals;

  -- a Renaissance Zone must be established and encompass an area
     which includes DMC's central campus.

Fitch will monitor the negotiations and update the Rating Watch as
appropriate.

Detroit Medical Center operates eight hospitals, five of which are
located on the main campus west of downtown Detroit.  In 2009, on
a consolidated basis DMC had total revenues of approximately
$2.1 billion.  Vanguard Health Systems, Inc., is an investor owned
healthcare company that, as of Dec. 31, 2009, owned or operated 15
acute care hospitals in Texas, Arizona Illinois and Massachusetts.


EMPIRE HOME: Fitch Downgrades Ratings on 14 Classes to 'C'
----------------------------------------------------------
Fitch Ratings has downgraded to 'C' 14 classes in four Empire Home
Loan and two Keystone Owner Trust residential mortgage backed
security transactions listed below.  The affected classes have an
aggregate balance of approximately $9 million.

The downgrades are a result of the ongoing suspension of interest
and principal to bondholders by U.S. Bank National Association
(the Trustee).  Amounts otherwise payable to bondholders are being
retained in the trust pending further developments resulting from
litigation involving the transactions.  The revised ratings
reflect the increased likelihood of both permanent interest
shortfalls and principal writedowns.  Since bond loss amounts
cannot be estimated at this time Recovery Ratings have not been
assigned to the bonds.

As a result of the ongoing litigation and the possibility that the
Trust and the Trustee could be held liable for the alleged actions
of the originators, the Trustee has suspended all distributions to
holders as of October 2009 for Empire Home Loan Owner Trust and
January 2010 for Keystone Owner Trust pending further
developments.  This status continued to be in effect as of the
March 2010 remittance date.

At this time, it is undetermined when or if these transactions
will receive distributions of interest and principal.  In
addition, all funds that are retained will first be distributed as
a payment of fees and costs incurred by the Trustee in performing
its duties.  The fees and costs due to the Trustee will increase
the likelihood that the bonds will incur non-recoverable interest
shortfalls and/or principal writedowns resulting in a default.

Fitch will continue to monitor these transactions for ongoing
developments and their potential impact on the bonds' outstanding
ratings.

The various bonds affected by the actions are:

Empire Funding Home Loan Owner Trust 1997-2

  -- Class M1 downgraded to 'C' from 'AA'.

Empire Funding Home Loan Owner Trust 1997-3

  -- Class A7 downgraded to 'C' from 'AAA'.

Empire Funding Home Loan Owner Trust 1998-1

  -- Class A5 downgraded to 'C' from 'AAA';
  -- Class M1 downgraded to 'C' from 'AA'.

Empire Funding Home Loan Owner Trust 1998-2

  -- Class A5 downgraded to 'C' from 'AAA';
  -- Class M1 downgraded to 'C' from 'AA';
  -- Class M2 downgraded to 'C' from 'A';
  -- Class B1 downgraded to 'C' from 'BBB'.

Keystone Owner Trust 1998-P1

  -- Class A5 downgraded to 'C' from 'AAA';
  -- Class M1 downgraded to 'C' from 'AA+';
  -- Class M2 downgraded to 'C' from 'A';
  -- Class B1 downgraded to 'C' from 'BBB'.

Keystone Owner Trust 1998-P2

  -- Class A5 downgraded to 'C' from 'AAA';
  -- Class B1 downgraded to 'C' from 'BBB-'.


FMC REAL: Fitch Downgrades Ratings on All Classes of Notes
----------------------------------------------------------
Fitch Ratings has downgraded all classes of FMC Real Estate CDO
2005-1 Ltd. reflecting Fitch's base case loss expectation of
39.7%.  Fitch's performance expectation incorporates prospective
views regarding commercial real estate market value and cash flow
declines.

The transaction is collateralized by both senior and subordinate
commercial real estate debt: 43.4% are either whole loans or A-
notes and 54.3% are either B-notes or mezzanine loans.  Fitch
expects significant losses upon default for the subordinate
positions since they are generally highly leveraged debt classes.
Further, eight loans (27.8%) are currently defaulted and two loans
(6.8%) are considered Fitch Loans of Concern.  Fitch expects
partial to full losses on the delinquent assets and Loans of
Concern.

FMC 2005-1 is a $439.4 million CRE collateralized debt obligation
managed by SCFFI GP LLC, an affiliate of Five Mile Capital.  The
transaction has a five-year reinvestment period during which
principal proceeds may be used to invest in substitute collateral.
The reinvestment period ends in August 2010.

As of the February 2010 trustee report and per Fitch
categorizations, the CDO was substantially invested: CRE whole
loans/A-notes (43.4%), mezzanine loans (31.2%), and B-notes
(23.2%).  All overcollateralization and interest coverage ratios
have remained above their covenants as of the February 2010
trustee report, despite the CDO's above-average default rate.

Under Fitch's updated methodology, approximately 65.2% 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 11.8% from the most recent available cash
flows (generally from third or fourth quarter 2009).  Fitch
estimates that recoveries will average 39.2% in the base case.

The largest component of Fitch's base case loss expectation is a
mezzanine loan (6.1%) secured by ownership interests in a
portfolio of five resort hotels, with a total of 3,287 rooms.  The
properties are located in Wailea, Hawaii; La Quinta, California;
Phoenix, Arizona; Miami, Florida; and Berkeley, California.  The
portfolio's performance has been adversely affected by the recent
economic downturn, and the mezzanine position is highly leveraged.
As such, Fitch modeled a term default with a substantial loss in
its base case scenario.

The next largest component of Fitch's base case loss expectation
is a whole loan (7.7%) secured by three single-tenant
office/industrial buildings located in North San Jose, CA.  One
tenant, who had occupied 33% of total portfolio net rentable area,
recently vacated at the expiration of its lease.  Consequently,
two of the buildings are now vacant, while the other is occupied
by one tenant through 2015.  Fitch modeled a term default with a
partial loss as a result of the portfolio's weak overall current
occupancy rate of 29%.

The third largest component of Fitch's base case loss expectation
is a defaulted B-note (4.4%) secured by approximately 18 acres of
land located in Las Vegas, Nevada.  The property is located on Las
Vegas Boulevard, in close proximity to several popular
hotel/casinos.  The land is currently improved with a variety of
commercial buildings, including a limited-service hotel,
restaurants and retail space.  The sponsor's original plan was to
redevelop the site into an Elvis Presley themed hotel/casino.  The
plan stalled amid the economic downturn, and the loan defaulted in
January 2009.  Fitch modeled a complete loss on this subordinate
position.

This transaction was analyzed according to 'Surveillance Criteria
for U.S. Commercial Real Estate Loan CDOs,' which applies stresses
to property cash flows and uses debt service coverage ratio (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 credit characteristics of classes A-1 and A-2 are generally
consistent with the 'BBB' rating category.  The credit
characteristics of class B are generally consistent with the 'BB'
rating category, and the credit characteristics of class C are
generally consistent with the 'B' rating category.

The ratings for classes D through H are based on a deterministic
analysis, which considers Fitch's base case loss expectation for
the pool, and the current percentage of defaulted assets and Fitch
Loans of Concern factoring in anticipated recoveries relative to
each class' credit enhancement.

Based on this analysis, classes D through F are consistent with
the 'CCC' rating category, meaning default is a real possibility.
Fitch's base case loss expectation of 39.7% exceeds these classes'
respective current credit enhancement levels.  The ratings for
classes G and H are deemed to be consistent with the 'CC' rating
category, meaning default appears probable given that these
classes' credit enhancement levels are below the total losses
expected from the currently defaulted assets and Loans of Concern
in the pool.

Classes A through C were assigned a Negative Outlook reflecting
Fitch's expectation of further negative credit migration of the
underlying collateral.  These classes were also assigned Loss
Severity (LS) ratings ranging from 'LS4' to 'LS5' indicating 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 Outlooks or LS
ratings to classes rated 'CCC' or lower.

Classes D through H were assigned Recovery Ratings (RR) to provide
a forward-looking estimate of recoveries on currently distressed
or defaulted structured finance securities.  Recovery Ratings are
calculated using Fitch's cash flow model and incorporate Fitch's
current 'B' stress expectation for default and recovery rates
(65.2% and 39.2%, respectively), the 'B' stress US$ LIBOR up-
stress, and a 24-month recovery lag.  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 assignment of 'RR4' to class D reflects modeled recoveries of
50% of its outstanding balance.  The expected recovery proceeds
are broken down:

  -- Present value of expected principal recoveries
     ($12.1 million);

  -- Present value of expected interest payments ($5 million);

  -- Total present value of recoveries ($17.1 million);

  -- Sum of undiscounted recoveries ($29.3 million).

Classes E through H are assigned a Recovery Rating of 'RR6' as the
present value of the recoveries in each case is less than 10% of
each class's principal balance.

Fitch has downgraded, assigned LS and RR ratings and Outlooks to
these classes as indicated:

  -- $131,825,000 class A-1 to 'BBB/LS4' from 'AAA'; Outlook
     Negative;

  -- $43,941,000 class A-2 to 'BBB/LS5' from 'AAA'; Outlook
     Negative;

  -- $43,941,000 class B to 'BB/LS5' from 'AA'; Outlook Negative;

  -- $49,434,000 class C to 'B/LS5' from 'A'; Outlook Negative;

  -- $34,055,000 class D to 'CCC/RR4' from 'BBB+';

  -- $13,182,000 class E to 'CCC/RR6' from 'BBB';

  -- $21,970,000 class F to 'CCC/RR6' from 'BBB-';

  -- $35,153,000 class G to 'CC/RR6' from 'B';

  -- $12,084,000 class H to 'CC/RR6' from 'B'.

Additionally, all classes are removed from Rating Watch Negative.


GE COMMERCIAL: S&P Downgrades Ratings on 14 Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 14
classes of notes issued by GE Commercial Loan Trust's series 2006-
1, 2006-2, and 2006-3 and removed them from CreditWatch negative.
All three transactions are cash flow collateralized loan
obligation transactions collateralized in large part by middle
market and syndicated corporate loans.  The downgrades primarily
reflect the application of S&P's updated corporate collateralized
debt obligation criteria, in particular the application of the
largest obligor default test S&P introduced as part of its new
criteria.

Standard & Poor's updated corporate CDO criteria published on
Sept. 17, 2009, included two supplemental "outside the model"
tests intended to address event risk and model risk that may be
present in rated transactions.  The first test is a "largest
obligor default test."  This test assesses whether a CDO tranche
has sufficient credit enhancement (not counting excess spread) to
withstand specified combinations of underlying asset defaults
based on the ratings on the underlying assets, with a flat
recovery rate of 5%.  The second test is a "largest industry
default test," which assesses whether a CDO tranche rated 'AAA',
'AA+', 'AA', or 'AA-' has sufficient credit enhancement (not
counting excess spread) to withstand the default of all obligors
in the transaction's largest industry, with a flat recovery rate
of 17%, or otherwise meet an alternative largest industry default
test.  In addition to S&P's cash flow analysis for each
transaction, either of these tests may be a limited factor in its
rating on a CDO tranche.

Because the three GE Loan Commercial Trust transactions have a
payment structure that allows for pro rata payments to the various
classes of notes until a sequential pay event is triggered.
Because of losses incurred within the collateral pools to date,
the transactions currently have relatively concentrated asset
pools, while portions of their higher rated notes still remain
outstanding.  According to Standard & Poor's database of CDO
performance information and based on information the trustees
provided for the transactions, the class A-1 notes have paid down
in full for all three transactions, and the class A-2 notes have
paid down to less than 50% of their initial balance.  However, the
relatively small number of obligors remaining in all three
collateral pools has increased the exposure risk of the remaining
balances of the senior notes outstanding for each transaction.
According to S&P's records, all three transactions currently have
25 or fewer assets remaining in their collateral pools.  The top
10 obligors in all three deals represent more than 50% of the
total performing collateral.

Standard & Poor's had previously downgraded a number of ratings
across all three transactions on Sept. 29, 2008, as a result of
losses incurred after they triggered "required sale assets"
provisions outlined within their documents.  The transactions
triggered these provisions when the market value of some
securities in the portfolio breached prespecified limits,
necessitating the sale of the affected securities at less than par
value.  The sale of the affected collateral at prevailing market
prices reduced the par balance of each transaction's portfolio,
reducing the available credit enhancement.

All three transactions are currently paying down their notes
sequentially following a sequential pay event that occurred before
the January 2009 payment date (series 2006-1) and the October 2008
payment dates (for series 2006-2 and 2006-3).

      Ratings Lowered And Removed From Creditwatch Negative

              GE Commercial Loan Trust Series 2006-1

                                 Rating
                                 ------
          Class            To             From
          -----            --             ----
          A-2              BBB+           AAA/Watch Neg
          B                CCC+           A-/Watch Neg
          C                CCC-           BBB-/Watch Neg
          Pfd Tr Crt       CC             BB-/Watch Neg

              GE Commercial Loan Trust Series 2006-2

                                 Rating
                                 ------
          Class            To             From
          -----            --             ----
          A-2              BBB+           AAA/Watch Neg
          B                BB+            AA/Watch Neg
          C                CCC-           A-/Watch Neg
          D                CC             BB+/Watch Neg
          Pfd Trust        CC             BB-/Watch Neg

              GE Commercial Loan Trust Series 2006-3

                                 Rating
                                 ------
          Class            To             From
          -----            --             ----
          A-2              BB+            AAA/Watch Neg
          B                CCC-           AA/Watch Neg
          C                CC             A-/Watch Neg
          D                CC             BB+/Watch Neg
          Pfd Tr Cer       CC             BB-/Watch Neg



GLACIER FUNDING: Fitch Downgrades Ratings on Three Classes
----------------------------------------------------------
Fitch Ratings has downgraded three classes and affirmed two
classes of notes issued by Glacier Funding CDO III, Ltd./Inc., as
a result of continued credit deterioration in the portfolio since
Fitch's last rating action in August 2008.

The transaction entered an Event of Default on Jan. 21, 2010, due
to failure of the ratio of the collateral balance to be equal to
or greater than 100% of the Aggregate Outstanding Amount of the
Class A Notes.  On Feb. 3, 2010 a majority of the class A-1 notes
as the controlling class directed the trustee to declare the
principal of all the notes to be immediately due and payable
(acceleration of maturity).  The acceleration of maturity has not
changed payment priority for this transaction.

As of the February 2010 trustee report, the current balance of the
portfolio (including cash) is $214.2 million.  Approximately 77.2%
of the portfolio has been downgraded since the last review.
Defaulted securities, as defined in the transaction's governing
documents, now comprise 56% of the portfolio, compared to 11.2% at
last review.  The downgrades to the portfolio have left
approximately 55.3% of the portfolio (including defaults) with a
Fitch derived rating below investment grade and 36.8% with a
rating in the 'CCC' rating category or lower, compared to 48.3%
and 27.2%, respectively, at last review.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs'.  Due
to the magnitude of the collateral deterioration, Fitch believes
that the likelihood of default for all classes of notes can be
assessed without using the Structured Finance Portfolio Credit
Model and performing cash flow model analysis under the framework
described in the 'Global Criteria for Cash Flow Analysis in CDOs -
Amended' report.

Fitch compared the credit enhancement level of the class A-1 notes
with the amount of underlying assets considered distressed (rated
'CCC' and lower).  These assets have a high probability of default
and low expected recoveries upon default.  The credit enhancement
level of the class A-1 notes is 3%, as compared to the 36.8% of
the portfolio considered distressed.  Therefore, the class A-1
notes as well as the class A-2 and B notes have been downgraded to
'C' to indicate Fitch's belief that default is inevitable at or
prior to maturity.

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

Glacier III is a cash flow SF CDO that closed on July 29, 2005.
The portfolio was initially selected by Terwin Money Management,
LLC and is now monitored by Aventine Hill Capital, LLC.  The
portfolio is composed of residential mortgage-backed securities
(76.5%), commercial mortgage-backed securities (20.1%), real
estate investment trusts (3%), and asset-backed securities (0.4%).

Fitch has downgraded these classes:

  -- $207,755,289 class A-1 notes to 'C' from 'B';
  -- $61,342,561 class A-2 notes to 'C' from 'CCC';
  -- $38,850,289 class B notes to 'C' from 'CC'.

Fitch has affirmed these classes:

  -- $25,346,322 class C notes at 'C';
  -- $3,331,966 class D notes at 'C'.


GOLDMAN SACHS: Moody's Affirms Ratings on Seven 2006-GG8 Certs.
---------------------------------------------------------------
Moody's Investors Service affirmed the rating of seven classes and
downgraded 17 classes of Goldman Sachs Mortgage Securities
Corporation II, Commercial Mortgage Pass-Through Certificates,
Series 2006-GG8.  The downgrades are due to interest shortfalls,
higher expected losses for the pool resulting from anticipated
losses from specially serviced and highly leveraged watchlisted
loans and concerns about refinancing risk associated with loans
approaching maturity in an adverse environment.  Six loans,
representing 8% of the pool, mature within the next two years 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 debt service coverage ratio
and the Herfindahl Index, remaining within acceptable ranges.

On March 18, 2010, Moody's placed 17 classes on review for
possible downgrade due to higher expected losses for the pool
resulting from anticipated losses from loans in special servicing
and concerns about refinancing risk associated with loans
approaching maturity in an adverse environment.  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 March 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 2% to $4.20 billion
from $4.24 billion at securitization.  The Certificates are
collateralized by 160 mortgage loans ranging in size from less
than 1% to 5% of the pool, with the top ten loans representing 35%
of the pool.  At last review, the One Beacon Street Loan
($210.0 million -- 5.0% of the pool) and the Village of Merrick
Park Loan ($162.2 million -- 3.9% of the pool) had an underlying
rating.  However, because of a decline in performance resulting in
an increase in leverage, the loan is now analyzed as part of the
conduit.

Forty loans, representing 18% 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 since securitization,
resulting in a $21,400 realized loss (1% loss severity on
average).  Twenty-two loans, representing 11% of the pool, are
currently in special servicing.  The largest specially serviced
loan is the Ariel Preferred Retail Portfolio Loan ($91.8 million -
- 2.2% of the pool), which is secured by the borrower's interest
in a portfolio of six anchored retail centers located in suburban
markets in California, Georgia, Michigan, Minnesota, Montana and
Nevada.  The loan was transferred to special servicing in June
2009 due to monetary default and is currently in foreclosure.  An
August 2009 appraisal valued the property at $65.5 million
(compared to $136.9 million at securitization).  The servicer has
recognized a $39.7 million appraisal reduction for this loan.

The second largest specially serviced loan is the Gallery at
Cocowalk Loan ($79.4 million -- 1.9% of the pool), which is
secured by a 196,492 square foot anchored retail center located in
Coconut Grove, Florida.  The loan was transferred to special
servicing in October 2009 due to imminent monetary default.  The
borrower has stated that they lack the necessary funds to complete
tenant improvements to complete work relating to a vacant movie
theater.  Currently a loan modification agreement is under review
and a receiver hearing is set for May 2010.  The servicer has
recognized a $19.9 million appraisal reduction for this loan.

The third largest specially serviced loan is the Tower Place 200
Loan ($50.5 million -- 1.2% of the pool), which is secured by a
259,888 square foot office building located in Atlanta, Georgia.
The loan was transferred to special servicing in July 2009 due to
imminent default and is now real estate owned.  An August 2009
appraisal valued the property at $32.4 million (compared to
$66.0 million at securitization).  The servicer has recognized a
$22.3 million appraisal reduction for this loan.

The remaining 19 specially serviced loans are secured by a mix of
office, retail and hospitality properties.  Moody's estimates an
aggregate $189.3 million loss for 22 of the specially serviced
loans (41% loss severity on average).  The servicer has recognized
an aggregate $148.7 million appraisal reduction for 20 of the
specially serviced loans.

In addition to recognizing losses from specially serviced loans,
Moody's has assumed a high default probability on four loans which
represent 6.2% of the pool.  The largest troubled loan is the
Arizona Grand Resort Loan ($190.0 million -- 4.5% of the pool),
which is secured by a 640 unit luxury resort located in Phoenix,
Arizona.  The loan was returned to master servicing from the
special servicer after satisfying three consecutive months of debt
service payments as per the September 2009 loan modification
agreement.  Under the agreement, the original loan was split into
an A note ($100.0 million) and a B note ($90.0 million), both of
which remain included in the trust.  The A note will remain
interest only at 5.5% until March 2012 (at which point it will
amortize on a 360 month schedule at a 6.68% interest rate through
maturity).  The B note will bear no interest and is payable in
full at maturity.  A May 2009 appraisal valued the property at
$92.8 million (compared to $246.0 million at securitization).

Moody's has estimated an aggregate loss of $133.6 million (51%
loss severity on average) from these troubled loans.  Moody's
rating action recognizes potential uncertainty around the timing
and magnitude of loss from these troubled loans.

Moody's was provided with partial 2009 or full-year 2008 operating
results for 94% of the pool.  Moody's weighted average LTV ratio,
excluding the specially serviced and troubled loans, is 114.8%
compared to 144.6% 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.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCR are 1.29X and 0.94X, respectively, compared to
1.02X and 0.88X at last review.  Moody's actual DSCR is based on
Moody's net cash flow and the loan's actual debt service.  Moody's
stressed DSCR is based on Moody's NCF 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 46 compared to 48 at last review.

The top three performing conduit loans represent 9% of the
outstanding pool balance.  The largest loan is the One Beacon
Street Loan ($210.0 million -- 5.0% of the pool), which is secured
by a 1.01 million square foot class A office building located in
Boston, Massachusetts.  The property is a premiere asset with
excellent proximity to public transportation.  The largest tenants
include Mass Housing Finance Agency (12% of the net rentable area
(NRA); lease expiration March 2015), JP Morgan Chase (9% of the
NRA; lease expiration December 2019) and Skadden, Arps, Slate,
Meagher & Flom LLP (6% of the NRA; lease expiration March 2014).
The property was 90% leased as of December 2009 compared to 91% at
last review.  The property is also encumbered by a $98.0 million
mezzanine loan.  Moody's LTV and stressed DSCR are 81% and 1.17X,
respectively, compared to 89% and 1.10X at last review.

The second largest loan is the 222 South Riverside Plaza Loan
($202.0 million -- 4.8% of the pool), which is secured by two
Class A office buildings (1.2 million square feet) located in
Chicago, Illinois.  The largest tenants include Fifth Third Bank
(15% of the NRA; lease expiration December 2016), Deutsche
Investment Management (10% of the NRA; lease expiration December
2016) and Trading Technologies (10% of the NRA; lease expiration
January 2013).  The property was 96% leased as of December 2009
compared to 89% at last review.  Moody's LTV and stressed DSCR
are104% and 0.93X, respectively, compared to 151% and 0.66X at
last review.

The third largest loan is the 1441 Broadway Loan ($183.0 million -
- 4.4% of the pool), which is secured by a 470,563 square foot
class B office building located in the garment district of
Manhattan, New York.  The largest tenants include the headquarters
for Liz Claiborne, Inc (62% of the NRA; lease expiration December
2012) and Jones Denim Management Corp (14% of the NRA; lease
expiration June 2017).  The property was 99% leased as of December
2009 which is same as at last review Moody's LTV and stressed DSCR
are 126% and 0.77X, respectively, compared to 123% and 0.81X at
last review.

Moody's rating action is:

  -- Class A-1, $29,988,236, affirmed at Aaa; previously assigned
     Aaa on 11/8/2006

  -- Class A-1A, $195,336,263, affirmed at Aaa; previously
     assigned Aaa on 11/8/2006

  -- Class A-2, $940,740,000, affirmed at Aaa; previously assigned
     Aaa on 11/8/2006

  -- Class A-3, $52,875,000, affirmed at Aaa; previously assigned
     Aaa on 11/8/2006

  -- Class A-4, $1,598,772,000, affirmed at Aaa; previously
     assigned Aaa on 11/8/2006

  -- Class A-AB, $111,500,000, affirmed at Aaa; previously
     assigned Aaa on 11/8/2006

  -- Class X, Notional, affirmed at Aaa; previously assigned Aaa
     on 11/8/2006

  -- Class A-M, $424,288,000, downgraded to Aa3 from Aaa,
     previously placed on review for possible downgrade on
     3/18/2010

  -- Class A-J, $302,305,000, downgraded to Baa3 from Aa3,
     previously placed on review for possible downgrade on
     3/18/2010

  -- Class B, $26,518,000, downgraded to Ba1 from A1, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class C, $53,036,000, downgraded to B1 from A2, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class D, $37,125,000, downgraded to B3 from A3, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class E, $37,125,000, downgraded to Caa1 from Baa1,
     previously placed on review for possible downgrade on
     3/18/2010

  -- Class F, $42,429,000, downgraded to Caa3 from Baa2,
     previously placed on review for possible downgrade on
     3/18/2010

  -- Class G, $53,036,000, downgraded to Ca from Baa3, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class H, $47,733,000, downgraded to C from Ba2, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class J, $53,036,000, downgraded to C from B2 previously
     placed on review for possible downgrade on 3/18/2010

  -- Class K, $42,428,000, downgraded to C from B3, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class L, $26,518,000, downgraded to C from Caa1, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class M, $15,911,000, downgraded to C from Caa1, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class N, $15,911,000, downgraded to C from Caa2, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class O, $10,607,000, downgraded to C from Caa2, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class P, $10,607,000, downgraded to C from Caa3, previously
     placed on review for possible downgrade on 3/18/2010

  -- Class Q, $15,911,000, downgraded to C from Caa3, previously
     placed on review for possible downgrade on 3/18/2010


GREENWICH CAPITAL: Moody's Reviews Ratings on 15 2005-GG5 Certs.
----------------------------------------------------------------
Moody's Investors Service placed 15 classes of Greenwich Capital
Commercial Funding Corp., Commercial Mortgage Pass-Through
Certificates, Series 2005-GG5 on review for possible downgrade due
to higher expected losses for the pool resulting from anticipated
losses from loans in special servicing and increased credit
quality dispersion for the remainder of the pool.  The rating
action is the result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.

As of the March 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 3% to
$4.18 billion from $4.29 billion at securitization.  The
Certificates are collateralized by 172 mortgage loans ranging in
size from less than 1% to 8% of the pool, with the top ten loans
representing 42% of the pool.  The pool includes two loans with
underlying ratings, representing 3% of the pool.

Sixty-one 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.

One loan has been liquidated from the pool with a realized loss of
$3.7 million (55% loss severity).  Nineteen loans, representing
16% of the pool, are currently in special servicing.  At Moody's
last full review only three loans, representing less than 1% of
the pool, were in special servicing.  There has been a
$114 million appraisal reduction on 11 loans in special servicing.

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

Moody's rating action is:

  -- Class A-M, $429,515,000, currently rated Aaa, placed on
     review for possible downgrade; previously assigned at Aaa on
     1/17/2006

  -- Class A-J, $300,660,000, currently rated Aaa, placed on
     review for possible downgrade; previously assigned at Aaa on
     1/17/2006

  -- Class B, $96,641,000, currently rated Aa2, placed on review
     for possible downgrade; previously assigned at Aa2 on
     1/17/2006

  -- Class C, $37,583,000, currently rated Aa3 placed on review
     for possible downgrade; previously assigned at Aa3 on
     1/17/2006

  -- Class D, $80,534,000, currently rated A2, placed on review
     for possible downgrade; previously assigned at A2 on
     1/17/2006

  -- Class E, $37,582,000, currently rated A3, placed on review
     for possible downgrade; previously assigned at A3 on
     1/17/2006

  -- Class F, $53,690,000, currently rated Baa1, placed on review
     for possible downgrade; previously assigned at Baa1 on
     1/17/2006

  -- Class G, $42,951,000, currently rated Baa2, placed on review
     for possible downgrade; previously assigned at Baa2 on
     1/17/2006

  -- Class H, $48,321,000, currently rated Baa3, placed on review
     for possible downgrade; previously assigned at Baa3 on
     1/17/2006

  -- Class J, $21,476,000, currently rated Ba1, placed on review
     for possible downgrade; previously assigned at Ba1 on
     1/17/2006

  -- Class K, $21,475,000, currently rated Ba2, placed on review
     for possible downgrade; previously assigned at Ba2 on
     1/17/2006

  -- Class L, $21,476,000, currently rated Ba3, placed on review
     for possible downgrade; previously assigned at Ba3 on
     1/17/2006

  -- Class M, $5,369,000, currently rated B1, placed on review for
     possible downgrade; previously assigned at B1 on 1/17/2006

  -- Class N, $16,107,000, currently rated B2, placed on review
     for possible downgrade; previously assigned at B2 on
     1/17/2006

  -- Class O, $10,738,000, currently rated B3, placed on review
     for possible downgrade; previously assigned at B3 on
     1/17/2006


HARTFORD FINANCIAL: Fitch Assigns 'BB' Rating on $500 Mil. Stock
----------------------------------------------------------------
Fitch Ratings has assigned these ratings to Hartford Financial
Services Group, Inc.'s issuances:

Hartford Financial Services Group, Inc.

  -- $300 million 4.0% senior notes due 2015 'BBB-';

  -- $500 million 5.5% senior notes due 2020 'BBB-';

  -- $300 million 6.625% senior notes due 2040 'BBB-';

  -- $500 million 7.25% mandatory convertible preferred stock,
     series F 'BB'.

No action was taken on the ratings of HFSG and its primary life
and property/casualty insurance subsidiaries.  The Rating Outlook
remains Negative.

This capital, in addition to a $1.45 million issuance of common
stock and existing funds, will be utilized to repurchase HFSG's
$3.4 billion of perpetual preferred stock issued in June 2009
under the U.S. Treasury's Capital Purchase Program (CPP) and pre-
fund $675 million of debt maturities through 2012.  Fitch has
assigned a class E designation to the mandatory convertible
preferred stock that allocates 100% of the principal to equity in
evaluating financial leverage.

Overall, Fitch views the replacement of CPP funds with more
permanent capital market financing as marginally positive in that
it demonstrates an overall improved financial position and
increased access to capital markets, although having the CPP
capital on hand provided HFSG an additional cushion for near-term
uncertainties.  However, ultimately, it should reduce the
potential negative impact to HFSG's business position, franchise
value and management team, which are concerns for companies that
operate under federal government support and related restrictions.

HFSG's equity credit adjusted debt-to-total capital ratio
(including accumulated other comprehensive income) improved
significantly to 19.2% at Dec. 31, 2009, down from 31.7% at Dec.
31, 2008.  Following the $3.05 billion capital issuance and
redemption of CPP, pro forma debt-to-total-capital increases to
24.2%, but remains below Fitch's expected range of 25%-30%.  Fitch
also expects HFSG to maintain GAAP operating earnings interest
coverage of at least 3 times-5x.

HFSG maintains financial flexibility with approximately
$2.2 billion in holding company cash, fixed maturities and short-
term investments at year-end 2009, and expects to have in excess
of $1.8 billion following completion of the capital raise and CPP
redemption, in addition to a $1.9 billion revolving credit
facility and a $500 million contingent capital facility.


HOUSE OF EUROPE: Moody's Cuts Class A2 Notes to Ca
----------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of two classes of notes issued by House of Europe Funding
IV PLC.  The notes affected by the rating action are:

  -- EUR740,000,000 Class A1 House of Europe Funding IV PLC
     Floating Rate Notes due 2090 (current balance of
     588,380,058), Downgraded to Ba2; previously on September 1,
     2009 Downgraded to A2

  -- EUR130,000,000 Class A2 House of Europe Funding IV PLC
     Floating Rate Notes due 2090, Downgraded to Ca; previously on
     September 1, 2009 Downgraded to Caa3

House of Europe Funding IV PLC is a high-grade collateralized debt
obligation issuance backed by a diversified portfolio of euro-
denominated structured finance securities such as CMBS, RMBS, CDOs
of ABS and CLOs.  RMBS are approximately 38% of the underlying
portfolio, of which the majority were originated between 2005 and
2007.

According to Moody's, the rating downgrade actions are the result
of deterioration in the credit quality of the underlying
portfolio.  Such credit deterioration is observed through numerous
factors, including a decline in the average credit rating of the
portfolio (as measured by the weighted average rating factor), and
failure of the coverage tests.  In particular, the weighted
average rating factor, as reported by the trustee, increased from
581 in August 2009 to 680 in March 2010, and is failing the test
level of 90.  During the same time, the Class A/B/C
Overcollateralization ratio decreased from 89.6% to 86.5%, and the
Class A/B/C Interest Coverage ratio decreased from 136.7% to
99.3%.

The actions also take into consideration the risk of the
transaction experiencing an Event of Default.  An Event of Default
may occur due to a missed interest payment with respect to the
Class A, B or C Notes.  During the occurrence and continuance of
an Event of Default, certain parties to the transaction may be
entitled to direct the Trustee to take particular actions with
respect to the collateral and the notes, including the sale and
liquidation of the assets.  The severity of losses of certain
tranches may be different depending on the timing and outcome of a
liquidation.

Moody's continues to monitor this transaction using primarily the
methodology and its supplements for ABS CDOs as described in
Moody's Special Report below:

  -- Moody's Approach to Rating SF CDOs (August 2009)

In deriving its ratings, Moody's uses the collateral instrument's
current rating-based expected loss, Moody's recovery rate table,
and the original rating of the instrument along with its average
life to infer an unadjusted default probability.  In addition to
the quantitative factors that are explicitly modeled, qualitative
factors are part of rating committee considerations.  These
qualitative factors include the structural protections in each
transaction, the recent deal performance in the current market
environment, the legal environment, and specific documentation
features.  All information available to rating committees,
including macroeconomic forecasts, input from other Moody's
analytical groups, market factors, and judgments regarding the
nature and severity of credit stress on the transactions, may
influence the final rating decision.


HOUSE OF EUROPE FUNDING: Moody's Cuts Ratings on Two Classes to B1
------------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of two classes of Notes issued by House of Europe Funding
V PLC.  The Notes affected by the rating actions are:

  -- EUR200,000,000 Class A1 House of Europe Funding V PLC
     Delayed Draw Note due 2090; Downgraded to B1; Previously on
     March 18, 2009 Downgraded to Ba2;

  -- EUR580,000,000 Class A1 House of Europe Funding V PLC
     Floating Rate Notes due 2090; Downgraded to B1; Previously on
     March 18, 2009 Downgraded to Ba2.

House of Europe Funding V is a collateralized debt obligation
backed primarily by a portfolio of Euro denominated Structured
Finance securities, with approximately 30% of the portfolio
consisting of RMBS and 40% CMBS.  The rating downgrade actions
reflect deterioration in the credit quality of the underlying
portfolio as indicated by rating actions taken with respect to
underlying assets.  Credit deterioration of the collateral pool is
observed through a decline in the average credit rating (as
measured by an increase in the weighted average rating factor) and
failure of the coverage tests, among other measures.

The weighted average rating factor, as reported by the trustee,
has increased from 128 in February 2009 to 474 in March 2010.
During this same time, defaulted securities increased by
~EUR 9.8 million and the Class A/B Overcollateralization Ratio
decreased from 97.04% to 89.32%.  In excess of 11% of the ratings
assigned to underlying portfolio securities are currently on
review for downgrade and since last rating action more than 40% of
the portfolio has experienced negative downgrade action.


INFINITI SPC: S&P Downgrades Ratings on Class 7C-1 Notes to 'CC'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
7C-1 notes from Infiniti SPC Ltd.'s Kenmore Street Synthetic CDO
2006-2 to 'CC' from 'CCC-'.

The downgrade follows a number of recent write-downs on the
underlying reference entities, which have caused the notes to
incur partial principal losses.

                          Rating Lowered

                         Infiniti SPC Ltd.
               Kenmore Street Synthetic CDO 2006-2

                                    Rating
                                    ------
                    Class          To    From
                    -----          --    ----
                    7C-1           CC    CCC-


JP MORGAN: Fitch Takes Rating Actions on 2002-CIBC5 Notes
---------------------------------------------------------
Fitch Ratings takes various rating actions to JP Morgan Chase
Commercial Mortgage Securities Corporation's commercial mortgage
pass-through certificates, series 2002-CIBC5:

Fitch downgrades and assigns LS Ratings and Outlooks to these
classes:

  -- $8.8 million class M to 'B-/LS5' from 'B+'; Outlook Negative;
  -- $2.5 million class N to 'B-/LS5' from 'B'; Outlook Negative.

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

  -- $52.6 million class A-1 at 'AAA/LS1'; Outlook Stable;
  -- $487.2 million class A-2 at 'AAA/LS1'; Outlook Stable;
  -- Interest-only class X-1 at 'AAA'; Outlook Stable;
  -- Interest-only class X-1 at 'AAA'; Outlook Stable;
  -- $36.4 million class B at 'AAA/LS3'; Outlook Stable;
  -- $13.8 million class C at 'AAA/LS4'; Outlook Stable;
  -- $27.6 million class D at 'AAA/LS3'; Outlook Stable;
  -- $13.8 million class E at 'AAA/LS4'; Outlook Stable;
  -- $28.8 million class F at 'AA+/LS3'; Outlook Stable;
  -- $16.3 million class G at 'AA-/LS4'; Outlook Stable;
  -- $18.8 million class H at 'BBB+/LS4'; Outlook Stable;
  -- $12.6 million class J at 'BBB-/LS4'; Outlook Stable;
  -- $5 million class K at 'BB+/LS5'; Outlook Negative;
  -- $5 million class L at 'BB/LS5'; Outlook Negative.

Fitch does not rate class NR.

The downgrades are due to an increase in Fitch expected losses
upon the disposition of specially serviced assets along with
expected losses from Fitch's prospective review of potential
stresses.  Fitch expects losses of 2.1% of the remaining
transaction balance, or $15.7 million, from loans in special
servicing and loans that cannot refinance at maturity based on
Fitch's refinance test.  Rating Outlooks reflect the likely
direction of any changes to the ratings over the next one to two
years.

As of the March 2010 distribution date, the pool's certificate
balance has paid down 26% to $742.8 million from $1 billion at
issuance.

There are 97 of the original 116 loans remaining in transaction,
29 of which have defeased (29.2% of the current transaction
balance).  Fitch identified 14 Loans of Concern (9.4%) within the
pool, of which three (2.7%) are specially serviced.

The largest specially serviced loan (1.2%) is a 384-unit
multifamily property in Tallahassee, FL.  The loan transferred in
February 2009 for payment delinquency.  The property performance
has suffered as a result of a decline in enrollment at a nearby
university as well as increased competition in the market.  The
servicer reported year-end 2009 debt service coverage ratio was
0.22 times.  Losses are expected.

The second largest specially serviced asset (0.9%) is a 62,542
square foot retail property in Gilbert, AZ.  The loan transferred
in December 2009.  There servicer reported September 2009
occupancy was 54% and the DSCR was 0.82x.  The decrease in
occupancy is a result of Bally's vacating approximately 40% of the
net rentable area.

The third largest specially serviced asset (0.6%) is a 250 pad
manufactured housing community located in Grove City, OH.  The
loan transferred in October 2009 due to payment default.  The
borrower is in litigation with the county and EPA over allegations
that runoff from retention ponds and the water treatment plant
have dumped contaminants into a river adjacent to the property.

Fitch stressed the cash flow of the remaining non defeased loans
by applying a 10% reduction to 2008 fiscal year end net operating
income and applying an adjusted market cap rate between 7.5% and
10% to determine value.

Similar to Fitch's prospective analysis of recent vintage CMBS,
each loan also underwent a refinance test by applying an 8%
interest rate and 30-year amortization schedule based on the
stressed cash flow.  Loans that could refinance to a debt service
coverage ratio of 1.25 times or higher were considered to payoff
at maturity.  Seven loans did not pay off at maturity and three
loans incurred a minimal loss when compared to Fitch's stressed
value.


JPMORGAN CHASE: S&P Downgrades Ratings on Seven 2005-CIBC11 Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on seven
classes of commercial mortgage-backed securities from JPMorgan
Chase Commercial Mortgage Securities Corp.'s series 2005-CIBC11
and removed them from CreditWatch with negative implications.  In
addition, S&P affirmed its ratings on 15 other classes from the
same transaction and removed eight of them from CreditWatch with
negative implications (see list).

The rating actions follow S&P's analysis of the transaction using
its U.S. conduit and fusion CMBS criteria.  The downgrades of the
subordinate classes also reflect credit support erosion that S&P
anticipates will occur upon the eventual resolution of several
specially serviced loans.  S&P's analysis included a review of the
credit characteristics of all of the loans in the pool.  Using
servicer-provided financial information, Standard & Poor's
calculated an adjusted debt service coverage of 1.55x and a loan-
to-value ratio of 90.1%.  S&P further stressed the loans' cash
flows under S&P's 'AAA' scenario to yield a weighted average DSC
of 1.12x and an LTV of 116.1%.  The implied defaults and loss
severity under the 'AAA' scenario were 54.2% and 23.7%,
respectively.  All of the adjusted DSC and LTV calculations
excluded 11 ($78.0 million, 5.1%) of the 14 specially serviced
loans, and seven ($64.9 million, 4.2%) defeased loans.  S&P
separately estimated losses for these 11 specially serviced loans,
which S&P 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-
1 and X-2 interest-only certificates based on S&P's current
criteria.  S&P published a request for comment proposing changes
to the IO criteria on June 1, 2009.  After S&P finalizes its
criteria review, S&P may revise its current IO criteria, which may
affect outstanding ratings, including the ratings on the IO
certificates S&P affirmed.

                      Credit Considerations

As of the March 2010 remittance report, 14 loans ($93.0 million,
6.0%) were with the special servicer, J.E. Robert Co. Inc.  Ten of
these loans ($47.9 million, 3.1%) are more than 90 days
delinquent, and four ($45.1 million, 2.9%) are within their
respective grace periods.  Three of the specially serviced loans
have appraisal reduction amounts in effect totaling $3.1 million.

The West Valley Shopping Center loan ($23.8 million total
exposure, 1.5%) is the largest loan with the special servicer and
is secured by a 281,291-sq.-ft. anchored retail center in Saginaw,
Mich.  The loan was transferred to JER on Nov. 20, 2009, due to
imminent default.  Modification discussions have not been
successful, and JER is moving forward with receivership and
foreclosure.  As of the nine months ended Sept. 30, 2009, the
property had a DSC of 1.31x and an occupancy of 88.0%.  S&P
anticipate a moderate loss upon the resolution of this loan.

The 13 remaining specially serviced loans that were listed in the
March 2010 remittance report ($69.4 million, 4.5%) have balances
that individually represent less than 1.0% of the total pool
balance.  S&P estimated losses for 10 of these loans
($54.3 million, 3.5%), resulting in a weighted average loss
severity of 28.9%.  JER is reviewing possible modifications for
the three remaining loans ($15.0 million, 1.0%).

                       Transaction Summary

As of the March 2010 remittance report, the aggregate trust
balance was $1.54 billion, which represents 85.6% of the aggregate
pooled trust balance at issuance.  There are 140 assets in the
pool, down from 145 at issuance.  The master servicer for the
transaction is Berkadia Commercial Mortgage LLC.  The master
servicer provided financial information for 99.7% of the loans in
the pool, and 96.7% of the servicer-provided information was full-
year 2008, interim-2009, or full-year 2009 data.

S&P calculated a weighted average DSC of 1.56x for the pool based
on the reported figures.  S&P's adjusted DSC and LTV were 1.55x
and 90.1%, respectively, which exclude 11 specially serviced loans
($78.0 million, 5.1%).  Based on the servicer-reported DSC
figures, S&P calculated a weighted average DSC of 1.20x for 10 of
these 11 loans.  Data was not reported for one loan.  To date, the
transaction has realized $5.2 million of principal losses in
connection with two loans.  Twenty-five loans ($165.1 million,
10.7%), including the eighth-largest loan in the pool, are on the
master servicer's watchlist.  Twenty-three of these loans
($139.5 million, 9.0%) have a reported DSC of less than 1.10x, and
14 of these loans ($68.7 million, 4.5%) have a reported DSC of
less than 1.0x.

                     Summary Of Top 10 Loans

The top 10 nondefeased loans have an aggregate outstanding balance
of $655.7 million (42.6%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.67x for the top 10 loans.
S&P's adjusted DSC and LTV for the top 10 loans were 1.62x and
82.8%, respectively.  One of the top 10 loans, Southmont Center,
appears on the master servicer's watchlist due to a low DSC.

The Southmont Center loan ($34.3 million, 2.2%) is the eighth-
largest loan in the pool and is secured by a 228,467-sq.-ft.
anchored retail center in Bethlehem, Penn.  As of the nine months
ended Sept. 30, 2009, the property's reported DSC was 1.05x with
86.6% occupancy.  The vacant space at the property was formerly
occupied by a Circuit City store.  This space has since been
leased to Best Buy, bringing occupancy to 100.0% as of March 1,
2010.  Best Buy will commence paying rent in April 2010, and S&P
expects that DSC will increase once this occurs.

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

        JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2005-CIBC11

                 Rating
                 ------
    Class  To             From           Credit enhancement (%)
    -----  --             ----           ----------------------
    H      BB-            BBB-/Watch Neg                   3.69
    J      B              BB+/Watch Neg                    3.26
    K      CCC            BB/Watch Neg                     2.67
    L      CCC-           BB-/Watch Neg                    2.23
    M      CCC-           B+/Watch Neg                     1.94
    N      CCC-           B/Watch Neg                      1.65
    P      CCC-           CCC+/Watch Neg                   1.21

      Ratings Affirmed And Removed From Creditwatch Negative

       JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2005-CIBC11

                 Rating
                 ------
    Class  To             From           Credit enhancement (%)
    -----  --             ----           ----------------------
    A-J    AAA            AAA/Watch Neg                   15.38
    A-JFX  AAA            AAA/Watch Neg                   15.38
    B      AA             AA/Watch Neg                    12.46
    C      AA-            AA-/Watch Neg                   11.29
    D      A              A/Watch Neg                      9.54
    E      A-             A-/Watch Neg                     8.08
    F      BBB+           BBB+/Watch Neg                   6.47
    G      BBB            BBB/Watch Neg                    5.30

                         Ratings Affirmed

        JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2005-CIBC11

            Class  Rating        Credit enhancement (%)
            -----  ------        ----------------------
            A-2    AAA                            22.98
            A-3    AAA                            22.98
            A-4    AAA                            22.98
            A-SB   AAA                            22.98
            A-1A   AAA                            22.98
            X-1    AAA                              N/A
            X-2    AAA                              N/A

                      N/A -- Not applicable.


KATONAH IV: Moody's Reviews Ratings on Three Classes of Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has placed under
review for possible upgrade the ratings of these notes issued by
Katonah IV, Ltd.:

  -- US$265,000,000 Class A Floating Rate Notes Due 2015 (Current
     outstanding balance of $180,334,010), A2 Placed Under Review
     for Possible Upgrade, previously on May 28, 2009 Downgraded
     to A2;

  -- US$32,750,000 Class B Floating Rate Notes Due 2015, B2 Placed
     Under Review for Possible Upgrade, previously on May 28, 2009
     Downgraded to B2;

  -- US$14,000,000 Class C Floating Rate Notes Due 2015, Ca Placed
     Under Review for Possible Upgrade, previously on May 28, 2009
     Downgraded to Ca.

According to Moody's, the rating actions taken on the notes result
primarily from substantial delevering of the transaction over the
past year , improvement in the credit quality of the underlying
portfolio, and a significant increase in the overcollateralization
of the rated notes since the last rating action in May 2009.

Since the last rating action taken on May 28, 2009, the Class A
Notes were paid a total of about $47million, accounting for
roughly 20% of the total Class A outstanding balance reported in
April 2009.  Moody's expects continued delevering with the end of
the reinvestment period in March 2008.  Improvement in the credit
quality is observed through an increase in the average credit
rating (as measured through the weighted average rating factor)
and a decrease in the dollar amount of defaulted securities.  In
particular, the weighted average rating factor has decreased from
3368 as of the April 2009 trustee report to 3238 as of the last
trustee report dated February 12, 2010.  Based on the same report,
defaulted securities currently total about $22.7 million, which
has come down from the $29.6 million in defaulted collateral
reported in April 2009.  Additionally, overcollateralization of
the rated notes has increased significantly since the last rating
action in May 2009.  As of the February 2010 trustee report, the
Class A, Class B, and Class C overcollateralization test levels
are reported at 133.65%, 113.11%, and 106.14%, versus April 2009
levels of 124.52%, 108.81%, and 103.24 %, respectively.

On May 28, 2009, Moody's downgraded all Notes issued by Katonah IV
Ltd. as a result of the application of revised and updated key
modeling assumptions as well as the deterioration in the credit
quality of the transaction's underlying portfolio.

Katonah IV, Ltd., issued in February 2003, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.


KINGSLAND IV: Moody's Reviews Ratings on Three Classes of Notes
---------------------------------------------------------------
Moody's Investors Service announced that it has placed the ratings
of these notes issued by Kingsland IV, Ltd., under review for
possible upgrade:

  -- US$22,900,000 Class B Senior Secured Floating Rate Notes
     Due 2021, Baa3 Placed Under Review for Possible Upgrade;
     previously on September 24, 2009 Downgraded to Baa3;

  -- US$25,000,000 Class C Senior Secured Deferrable Floating
     Rate Notes Due 2021, B2 Placed Under Review for Possible
     Upgrade; previously on September 24, 2009 Downgraded to B2;

  -- US$18,000,000 Class D Senior Secured Deferrable Floating
     Rate Notes Due 2021, Caa3 Placed Under Review for Possible
     Upgrade; previously on September 24, 2009 Downgraded to Caa3.

According to Moody's, the rating actions taken on the notes result
primarily from improvement in the credit quality of the underlying
portfolio since the last rating action in September 2009.  In
Moody's view, these positive developments coincide with
reinvestment of sale proceeds into substitute assets with higher
par amounts and/or higher ratings.

Improvement in the credit quality is observed through a decrease
in the dollar amount of defaulted securities, an improvement in
the average credit rating (as measured by the weighted average
rating factor) and a decrease in the proportion of securities from
issuers rated Caa1 and below.  In particular, as of the last
trustee report dated February 15, 2010, defaulted securities total
about $9.5 million, which is significantly less than the
$22 million in defaulted securities reported in the July 2009
report.  Based on the same report, the weighted average rating
factor is currently 2359 compared to 2570 in July 2009, and
securities rated Caa1 or lower make up approximately 5.8% of the
underlying portfolio versus 10% in July 2009.

Kingsland IV, Ltd., issued in February 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.  On September 24, 2009, Moody's downgraded all the notes
issued by Kingsland IV, Ltd., as a result of the application of
revised and updated key modeling assumptions as well as the
deterioration in the credit quality of the transaction's
underlying portfolio.


KLEROS REAL: Moody's Downgrades Ratings on Class A-1 Notes
----------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of one class of notes issued by Kleros Real Estate CDO IV,
Ltd.  The notes affected by the rating action are:

  -- US$300,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Notes Due December 2050, Downgraded to Ca;
     previously on 2/6/2009 Downgraded to Ba1

Kleros Real Estate CDO IV, Ltd. is a collateralized debt
obligation issuance backed by a portfolio of primarily Residential
Mortgage-Backed Securities originated between 2004 and 2007, with
the majority originated in 2006.

According to Moody's, the rating downgrade actions are the result
of deterioration in the credit quality of the underlying
portfolio.  Such credit deterioration is observed through numerous
factors, including a decline in the average credit rating of the
portfolio (as measured by an increase in the weighted average
rating factor) and failure of the coverage tests.  The weighted
average rating factor, as reported by the trustee, has increased
from 3097 in February 2009 to 4023 in January 2010.  In addition,
the Trustee reports that the transaction is currently failing its
Overcollateralization test.

Moody's explained that in arriving at the rating action noted
above, the ratings of 2005-2007 subprime, Alt-A and Option-ARM
RMBS which are currently on review for possible downgrade were
stressed.  For purposes of monitoring its ratings of SF CDOs with
exposure to such 2005-2007 vintage RMBS, Moody's used certain
projections of the lifetime average cumulative losses as set forth
in Moody's press releases dated January 13 for subprime, January
14th for Alt-A, and January 27th for Option-ARM.  Based on the
anticipated ratings impact of the updated cumulative loss numbers,
the stress varied based on vintage, current rating, and RMBS asset
type.

For 2005 Alt-A and Option-ARM securities, securities that are
currently rated Aaa or Aa were stressed by eleven notches, and
securities currently rated A or Baa were stressed by eight
notches.  Those securities currently rated in the Ba or B range
were stressed to Caa3, while current Caa securities were treated
as Ca.  For 2006 and 2007 Alt-A and Option-ARM securities,
currently Aaa or Aa rated securities were stressed by eight
notches, and securities currently rated A, Baa or Ba were stressed
by five notches.  Those securities currently rated in the B range
were stressed to Caa3, while current Caa securities were treated
as Ca.

For 2005 subprime RMBS, those currently rated Aa, A or Baa were
stressed by five notches, Ba rated securities were stressed to
Caa3, and B or Caa securities were treated as Ca.  For subprime
RMBS originated in the first half of 2006, those currently rated
Aaa were stressed by four notches, while Aa, A and Baa rated
securities were stressed by eight notches.  Those securities
currently rated in the Ba range were stressed to Caa3, while
current B and Caa securities were treated as Ca.  For subprime
RMBS originated in the second half of 2006, those currently rated
Aa, A, Baa or Ba were stressed by four notches, currently B rated
securities were treated as Caa3, and currently Caa rated
securities were treated as Ca.  For 2007 subprime RMBS, currently
Ba rated securities were stressed by four notches, currently B
rated securities were treated as Caa3, and currently Caa rated
securities were treated as Ca.

Moody's noted that the stresses applicable to categories of 2005-
2007 subprime RMBS that are not listed above will be two notches
if the RMBS ratings are on review for possible downgrade.

Moody's further explained that these stresses are based on a
preliminary sample analysis of deals from a given vintage and
asset type, and that they will be utilized in its SF CDO rating
analysis while subprime, Alt-A and Option-ARM securities remain on
review for downgrade.  Current public ratings will be used for
securities that have undergone an in depth review by Moody's RMBS
team and are no longer on review for downgrade.


LB-UBS COMMERCIAL: Fitch Takes Rating Actions on 2003-C1 Notes
--------------------------------------------------------------
Fitch Ratings affirms, assigns Loss Severity ratings and Outlooks
to LB-UBS Commercial Mortgage Trust commercial mortgage pass-
through certificates, series 2003-C1:

  -- $72.9 million class A-3 at 'AAA/LS1'; Outlook Stable;
  -- $537.5 million class A-4 at 'AAA/LS1'; Outlook Stable;
  -- $97.3 million class A-1B at 'AAA/LS1'; Outlook Stable;
  -- Interest-only (I/O) classes X-CL and X-CP at 'AAA';
  -- $25.7 million class B at 'AAA/LS1'; Outlook Stable;
  -- $25.7 million class C at 'AAA/LS1'; Outlook Stable;
  -- $20.6 million class D at 'AAA/LS1'; Outlook Stable;
  -- $18.9 million class E at 'AAA/LS1'; Outlook Stable;
  -- $17.1 million class F to 'AAA/LS1'; Outlook Stable;
  -- $18.9 million class G to 'AAA/LS3'; Outlook Stable;
  -- $18.9 million class H to 'AA/LS3'; Outlook Stable;
  -- $12 million class J to 'A/LS3'; Outlook Stable;
  -- $10.3 million class K to 'A-/LS3'; Outlook Stable;
  -- $18.9 million class L to 'BBB/LS3'; Outlook Stable;
  -- $6.9 million class M to 'BBB-/LS4'; Outlook Stable;
  -- $6.9 million class N to 'BB/LS4'; Outlook Stable;
  -- $10.3 million class P at 'B+/LS5'; Outlook Negative;
  -- $5.1 million class Q at 'B/LS5'; Outlook Negative;
  -- $5.1 million class S at 'B-/LS5'; Outlook Negative.

Classes A-1 and A-2 have been paid in full.  Fitch does not rate
the $7.0 million class T.

Affirmations are due to the pool's stable performance and minimal
future expected losses following Fitch's prospective review of
potential stresses to the transaction.  Fitch expects 0.8% or
$7.3 million, of losses associated with loans currently in special
servicing and loans that cannot refinance at maturity based on
Fitch's refinance test.  As of the March 2010 distribution date,
the pool's certificate balance has paid down 31.8% to
$935.9 million from $1.4 billion at issuance.

There are 93 of the original 114 loans remaining in transaction,
16 of which have defeased (28.2% of the current transaction
balance).  There are five specially serviced loans of which, one
is real estate owned, two are in foreclosure, and two are recent
maturity defaults.  Fitch expects losses from loans currently in
special servicing to be absorbed by the unrated class M.

Fitch stressed the cash flow of the remaining non defeased loans
by applying a 10% reduction to 2008 fiscal year end net operating
income and applying an adjusted market cap rate between 7.25% and
10% to determine value.

Similar to Fitch's prospective analysis of recent vintage CMBS,
each loan also underwent a refinance test by applying an 8%
interest rate and 30-year amortization schedule based on the
stressed cash flow.  Loans that could refinance to a debt service
coverage ratio of 1.25 times or higher were considered to payoff
at maturity.  Seventeen loans did not payoff at maturity and one
loan incurred a minimal loss when compared to Fitch's stressed
value.


LIMEROCK CLO: Moody's Reviews Ratings on Various Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has placed the ratings
of these notes issued by Limerock CLO I under review for possible
upgrade:

  -- US$23,000,000 Class A-3b Floating Rate Notes Due 2023,
     Baa1 Placed Under Review for Possible Upgrade; previously on
     June 9, 2009 Downgraded to Baa1;

  -- US$29,000,000 Class A-4 Floating Rate Notes Due 2023,
     Baa3 Placed Under Review for Possible Upgrade; previously on
     June 9, 2009 Downgraded to Baa3;

  -- US$22,000,000 Class B Deferrable Floating Rate Notes Due
     2023, Ba3 Placed Under Review for Possible Upgrade;
     previously on June 9, 2009 Downgraded to Ba3;

  -- US$19,000,000 Class C Floating Rate Notes Due 2023, Caa2
     Placed Under Review for Possible Upgrade; previously on
     June 9, 2009 Downgraded to Caa2;

  -- US$20,000,000 Class D Floating Rate Notes Due 2023, C
     Placed Under Review for Possible Upgrade; previously on
     June 9, 2009 Downgraded to C;

  -- US$14,000,000 Class J Blended Securities (current Rated
     Balance of $12,303,931), Caa1 Placed Under Review for
     Possible Upgrade; previously on June 9, 2009 Downgraded to
     Caa1.

According to Moody's, the rating actions taken on the notes result
primarily from improvement in the credit quality of the underlying
portfolio and a significant increase in the overcollateralization
of the rated notes since the last rating action in June 2009.  In
Moody's view, these positive developments coincide with
reinvestment of principal repayments and sale proceeds into
substitute assets with higher par amounts and/or higher ratings.

Improvement in the credit quality is observed through a decrease
in the dollar amount of defaulted securities, an improvement in
the average credit rating (as measured by the weighted average
rating factor) and a decrease in the proportion of securities from
issuers rated Caa1 and below.  In particular, as of the last
trustee report dated February 10, 2010, defaulted securities total
about $28.3 million, which is significantly less than the
$46.7 million of defaulted collateral reported in the May 2009
report.  Based on the same report, the weighted average rating
factor is currently 2957 compared to 3069 in May, and securities
rated Caa1 or lower make up approximately 7.9% of the underlying
portfolio versus 14.7% in May.  Additionally, the
overcollateralization ratios of the rated notes have increased
significantly since the last rating action in June 2009, and
interest payments on the Class D Notes are no longer being
deferred as a result of the cure of the Class B and Class C
Overcollateralization Tests.  The Class A, Class B, Class C and
Class D Overcollateralization Ratios are reported at 120.76%,
114.35%, 109.33% and 104.51%, respectively versus May 2009 levels
of 110%, 104.2%, 99.7% and 95.2%, respectively, and are all
currently in compliance.  Moody's also notes that the transaction
has benefited from exposure to mezzanine and junior CLO tranches
whose recent credit qualities have stabilized or improved.

Limerock CLO I, issued in April 2007, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.  On June 9, 2009, Moody's downgraded all the Notes issued
by Limerock CLO I as a result of the application of revised and
updated key modeling assumptions as well as the deterioration in
the credit quality of the transaction's underlying portfolio.


LOUISIANA PUBLIC: S&P Affirms 'BB' Rating on Two Bonds
------------------------------------------------------
Standard & Poor's Ratings Services removed its rating on Louisiana
Public Facilities Authority's series 1993 and 1999 bonds, issued
for Touro Infirmary, from CreditWatch with negative implications,
where it had been placed on April 22, 2009, and assigned a
positive outlook to the rating.  At the same time, Standard &
Poor's affirmed its 'BB' long-term rating on the bonds.

"The positive outlook largely reflects the affiliation agreement
signed with Children's Hospital of New Orleans, under which Touro
expects to receive considerable funding," said Standard & Poor's
credit analyst Karl Propst.  "The outlook also reflects additional
committed Medicaid funds from the state."  A higher rating is
currently precluded by still weak operating performance, high
leverage, and limited liquidity.

Touro's affiliation agreement with Children's Hospital of New
Orleans and the Louisiana Children's Medical Center, parent of
Children's Hospital, became effective in July 2009.  The agreement
will supply Touro with capital needed to grow and renovate its
physical plant.  Management also expects the affiliation to create
group purchasing, insurance, and other synergies for the combined
system.  Children's pledged to contribute a minimum of
$100 million to Touro over the next five years for capital
improvements.  The amount was subsequently reduced to $88 million,
with the remainder to come from $25 million in special state of
Louisiana payments made to the hospital in 2009 and 2010.

For fiscal 2010 Touro has budgeted an operating loss of
$15.7 million (compared with $18.3 million in fiscal 2009) and
positive net excess of $19.5 million after the receipt of
$16.6 million of Medicaid Block Grant Funding and $14.5 million
from Children's Hospital.

Touro Infirmary and Subsidiaries operates as a diversified
provider of acute- and long-term care services to the New Orleans
market, principally to the uptown area on New Orleans' east bank,
in Orleans Parish.  Currently the hospital has 347 licensed beds,
of which 260 are staffed.


MAX CMBS: Moody's Reviews Ratings on 14 Classes of Notes
--------------------------------------------------------
Moody's Investors Service placed fourteen classes of Notes issued
by Max CMBS I Ltd. under review for possible downgrade due to
deterioration in the credit quality of the underlying portfolio as
evidenced by deterioration in the weighted average rating factor.
Two transactions are affected: Max CMBS I Ltd. and Max CBMS I
Ltd., Series 2008-1.  The rating action is the result of Moody's
on-going surveillance of commercial real estate collateralized
debt obligation transactions.

Series 2007-1 and Series 2008-1 are cross-collateralized static
cash CRE CDO transactions backed by a portfolio of commercial
mortgage backed securities (100% of the pool balance).  As of the
February 18, 2010 Trustee report, the aggregate Note balance of
the Series 2007-1 transaction was $2.097 billion, the same as that
at securitization; the aggregate Note balance of the Series 2008-1
transaction was $5.782 billion, the same as that at
securitization.

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

The rating action is:

Max CMBS I Ltd.

$2.097 Billion of Structured Securities Affected

  -- Class A-1, Aaa Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Confirmed at Aaa

Max CMBS I Ltd., Series 2008-1

$5.782 Billion of Structured Securities Affected

  -- Class A-1, Aaa Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Confirmed at Aaa

  -- Class A-2A, Aa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Aa3

  -- Class A-2B, Aa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Aa3

  -- Class X-W*, Aa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Aa3

  -- Class X-B*, Aa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Aa3

  -- Class X-C*, Aa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Aa3

  -- Class C, A2 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to A2

  -- Class E, A3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to A3

  -- Class F, Baa1 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Baa1

  -- Class G, Baa2 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Baa2

  -- Class H, Baa2 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Baa2

  -- Class J, Baa3 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Baa3

  -- Class K, Ba1 Placed Under Review for Possible Downgrade;
     previously on March 19, 2009 Downgraded to Ba1

  * Notional Class

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 19, 2009.


MORGAN STANLEY: Moody's Confirms Ratings on Two Classes of Notes
----------------------------------------------------------------
Moody's Investors Service announced that it has confirmed its
rating on 70% fixed recovery rate notes issued by Morgan Stanley
ACES SPC Series 2007-1, a collateralized debt obligation
transaction referencing a static portfolio of corporate loans.

The rating action is:

Issuer: Morgan Stanley ACES SPC, Series 2007-1

  -- US$10,000,000 Class B Secured Floating Rate Notes due
     2012, Confirmed at Baa2; previously on December 7, 2009 Baa2
     Placed Under Review for Possible Downgrade

  -- US$6,500,000 Class C Secured Floating Rate Notes due
     2012, Confirmed at Ba2; previously on December 7, 2009 Ba2
     Placed Under Review for Possible Downgrade

Moody's explained that the rating action taken is primarily the
result of the shorter time remaining to maturity of the deal which
is expected to offset the portfolio credit deterioration.  Since
the last downgrade of the transaction, the subordination of the
rated tranches has been reduced due to credit events on Charter
Communications Holdings LLC, Dex Media East LLC, Dex Media West
LLC, General Growth Properties Inc., HLI Operating Company Inc,
Lear Corporation, Six Flags Inc., Accuride Corporation, and MGM
Studios.  These credit events reduced subordination by
approximately 3.8%, which prompted Moody's to place the
transaction on watch for downgrade in December 2009, pending
further analysis.  Since then, among other analysis, Moody's
examined the sensitivity of the transaction's credit risk profile
to a decrease in the remaining time to maturity.  Other things
being equal, a reduction of time to maturity has a positive impact
which will increase over time.  In light of this effect, Moody's
believes that the current ratings on the notes are appropriate.

The portfolio has the highest industry concentrations in Hotel,
Gaming & Leisure (15%), Containers, Packaging & Glass (12%),
Media: Broadcasting & Subscription (11%), and Chemicals, Plastics,
& Rubber (9%).


MORGAN STANLEY: Moody's Downgrades Ratings on 2001-TOP3 Certs.
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of one class of
Morgan Stanley Dean Witter Capital I Trust 2001-TOP3, Commercial
Mortgage Pass-Through Certificates, Series 2001-TOP3 and placed
eight classes on review for possible downgrade.  Moody's
downgraded the rating of Class M because it has experienced an
aggregate $11.5 million realized loss from the liquidation of six
specially serviced loans (42% loss severity on average).

Eight classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from realized and
anticipated losses from loans in special servicing and concerns
about refinancing risk associated with loans approaching maturity
in an adverse environment.

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

As of the March 15, 2010 statement date, the transaction's
aggregate certificate balance has decreased 32% to $701.3 million
from $1.0 billion at securitization.  The certificates are
collateralized by 133 mortgage loans ranging in size from less
than 1% to 7% of the pool, with the top ten non-defeased loans
representing 32% of the pool.  The pool contains one loan,
representing 5% of the pool, with an underlying investment grade
rating.  Eighteen loans, representing 15% of the pool, have
defeased and are secured by U.S. Government securities.

Twenty-seven loans, representing 12% 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.

Five loans, representing 5% of the pool, are currently in special
servicing.  The largest specially serviced loan is the Detroit
Center Tool Building ($13.8 million -- 2% of the pool), which is
secured by an industrial building located in Sterling Heights,
Michigan.  The loan transferred into special servicing in December
2009 because the building's sole tenant vacated the property when
their lease expired.  The remaining four specially serviced loans
are secured by a mix industrial, unanchored retail centers, and
office properties.

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

Moody's rating action is:

  -- Class C, $28,273,000, currently rated Aa2; on review for
     possible downgrade; previously on 8/9/2007 upgraded to Aa2
     from A1

  -- Class D, $12,852,000, currently rated A1; on review for
     possible downgrade; previously on 8/9/2007 upgraded to A1
     from A3

  -- Class E, $17,992,000, currently rated Baa2; on review for
     possible downgrade; previously on 7/30/2001 assigned Baa2

  -- Class F, $11,566,000, currently rated Baa3; on review for
     possible downgrade; previously on 7/30/2001 assigned Baa3

  -- Class G, $11,566,000, currently rated Ba1; on review for
     possible downgrade; previously on 7/30/2001 assigned Ba1

  -- Class H, $10,281,000, currently rated Ba3; on review for
     possible downgrade; previously on 6/4/2009 downgraded to Ba3
     from Ba2

  -- Class J, $8,996,000, currently rated B3; on review for
     possible downgrade; previously on 6/4/2009 downgraded to B3
     from B1

  -- Class L, $5,140,000, currently rated Caa3; on review for
     possible downgrade; previously on 6/4/2009 downgraded to Caa3
     from B3

  -- Class M, $1,339,369, downgraded to C from Ca; previously on
     6/4/2009 downgraded to Ca from Caa1


MORGAN STANLEY: S&P Corrects Rating on Class A-11 Notes From 'BB+'
------------------------------------------------------------------
Standard & Poor's Ratings Services corrected its rating on Morgan
Stanley ACES SPC's secured fixed-rate class A-11 notes series
2006-8 $3 million by raising it to 'BBB-' from 'BB+' and removing
it from CreditWatch with positive implications, where it was
placed on Nov. 20, 2009.

The rating on the class A-11 notes is dependent on the lowest of
the ratings on the reference obligation, Rock-Tenn Co.'s
$250 million 8.2% senior secured notes due Aug. 15, 2011 ('BBB-');
Morgan Stanley ('A'), which acts as the swap payments guarantor;
and 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').

On Nov. 24, 2009, S&P raised its rating on Rock-Tenn Co.'s
$250 million 8.2% senior secured notes due Aug. 15, 2011, to 'BBB-
'from 'BB+' and removed it from CreditWatch with positive
implications.  However, due to an error, S&P did not
contemporaneously take rating action on the class A-11 notes.


MORGAN STANLEY: S&P Downgrades Ratings on Various Classes to 'CC'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on classes
IVA, IVB, and IVC from Morgan Stanley Managed ACES SPC's series
2006-6 to 'CC' from 'CCC-'.

The downgrades follow a number of credit events within the
portfolio of underlying corporate reference entities.  S&P
received final valuations on the credit events in the underlying
portfolio, which indicated that losses in the portfolio caused
these notes to incur partial principal losses.


PHOENIX CDO: Fitch Takes Rating Actions on Various Classes
----------------------------------------------------------
Fitch Ratings has affirmed three and downgraded one class of notes
issued by Phoenix CDO II, Ltd.

Since July 2003, the transaction has been in a technical event of
default due to the fact that the aggregate principal balance of
the collateral debt securities fell below the aggregate balance of
the rated notes.  In December 2003, the majority holders of the
senior class voted to accelerate the maturity of the transaction.
Therefore, since the March 2004 payment date all interest and
principal proceeds have been used to pay the class A interest and
principal and will continue to do so until the notes are paid in
full.

As of the February 2010 trustee report, the current balance of the
portfolio is $126.3 million.  Defaulted securities, as defined in
the transaction's governing documents, now comprise 20.3% of the
portfolio, compared to 14.2% at last review in March 2009.
Approximately 17.6% of the portfolio has been downgraded since
Fitch's last rating action, resulting in 35% of the portfolio with
a Fitch derived rating below investment grade and 29.9% with a
rating in the 'CCC' rating category or below, as compared to 17.1%
and 5.0%, 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 (SF PCM) for
projecting future default levels for the underlying portfolio.
These default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs -
Amended'.

Based on this analysis, the class A notes' breakeven rates are
generally consistent with the rating assigned below.  The
affirmation of the class A notes is attributed to the increase in
credit enhancement available to the notes resulting from principal
amortizations and the application of interest proceeds to pay down
class A notes' balance.  Since the last review, approximately
12.7% of the class A notes' balance amortized down thereby
offsetting the effect of the collateral deterioration.  The notes
received $40.1 million in 2009 following $37.7 million in paydowns
during 2008.  Presently the class A notes represent 26.3% of the
capital structure and have a credit enhancement of 69.9%.
According to the latest trustee report, only 48 assets remain in
the Phoenix II's portfolio.  To account for the increased
likelihood that the class A notes' performance may be adversely
impacted by a few assets that may underperform, Fitch revised the
Outlook to Negative.

Additionally, the class A notes are assigned a Loss Severity
rating of 'LS3'.  The LS rating indicates a tranche's potential
loss severity given default, as evidenced by the ratio of tranche
size to the base-case loss expectation for the collateral, as
explained in 'Criteria for Structured Finance Loss Severity
Ratings'.  Currently, for the class A notes this ratio is in the
range of 1.1 to 4.0.  The LS rating should always be considered in
conjunction with the probability of default for tranches.  Fitch
does not assign LS ratings and Outlooks for classes rated 'CCC'
and lower.

As a result of the acceleration of maturity, class B has missed
its interest payments since acceleration in 2003.  Because the
class B notes are rated to the timely receipt of interest, Fitch
considers this class to be in default on the payment of interest
and is therefore downgrading this class to 'D'.  As of the March
2010 payment date, the class B notes have accrued approximately
$9.7 million of defaulted interest payments and will continue to
accrue defaulted interest, as well as interest on the defaulted
interest, until the class A notes are paid in full.  However,
Fitch expects the class B investors to receive ultimate interest
and principal payments under the 'BB' stress scenarios by the
legal final maturity date.

The class C-1 and C-2 notes are no longer receiving interest
distributions and are not expected to receive any proceeds going
forward.

Phoenix CDO II is a cash flow collateralized debt obligation,
which closed on May 16, 2000, and is managed by Phoenix Investment
Partners, Ltd. The current portfolio is comprised of approximately
42% residential mortgage-backed securities, 30% commercial
mortgage-backed securities, 21.7% commercial asset-backed
securities, and 6.3% of consumer ABS.

Fitch has taken rating actions on the classes listed below:

  -- $37,966,444 class A notes affirmed at 'AAA', assigned LS3,
     Outlook revised to Negative from Stable;

  -- $39,000,000 class B notes downgraded to 'D' from 'BB',
     removed Outlook Stable;

  -- $29,586,433 class C-1 notes affirmed at 'C';

  -- $21,487,278 class C-2 notes affirmed at 'C'.


PYXIS MASTER: S&P Withdraws 'B-' Rating on Point Green II Units
---------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its rating on the
Point Green II units issued by Pyxis Master Trust's series 2007-
28, a synthetic corporate investment-grade collateralized debt
obligation transaction.

The rating withdrawal follows the complete redemption of the notes
pursuant to the notice dated Dec. 18, 2009.

                         Rating Withdrawn

                        Pyxis Master Trust
               Series 2007-28 Point Green II units

                    Rating                 Balance (mil. $)
                    ------                 ----------------
                  To      From          Current      Previous
                  --      ----          -------      --------
     Trust units  NR      B-              0.000        30.000

                          NR - Not rated.


REPACS TRUST: S&P Withdraws 'CCC-' Rating on Debt Units
-------------------------------------------------------
Standard & Poor's Ratings Services withdrew its 'CCC-' rating on
the debt units from REPACS Trust Series 2006 Mount Ventoux, a
synthetic corporate investment-grade collateralized debt
obligation transaction.

The rating withdrawal follows the cancellation of the debt units.

                         Rating Withdrawn

              REPACS Trust Series 2006 Mount Ventoux

                    Rating                   Balance (mil. $)
                    ------                   ----------------
                  To      From             Current      Previous
                  --      ----             -------      --------
  Debt Units      NR      CCC-               0.000        25.000

                          NR - Not rated.


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

  -- US$18,000,000 Class B Deferrable Note Rights Due 2015, B1
     Placed Under Review for Possible Upgrade; previously on
     June 9, 2009 Downgraded to B1;

  -- US$5,000,000 Class 2 Participation Notes Due 2015
     (current rated balance of $2,893,448), B2 Placed Under
     Review for Possible Upgrade; previously on June 9, 2009
     Downgraded to B2.

According to Moody's, the rating action taken on the Class B notes
results primarily from improvement in the credit quality of the
underlying portfolio and an increase in the overcollateralization
of the notes since the last rating action in June 2009.  The notes
also benefited from the delevering of the Class A-1, A-2 and A-3
notes, which have been paid down by approximately $20 million
since the last rating action.  Moody's expects delevering to
continue as a result of the end of the deal's reinvestment period
in October 2009.

Improvement in the credit quality is observed through a decrease
in the dollar amount of defaulted securities, an improvement in
the average credit rating (as measured by the weighted average
rating factor) and a decrease in the proportion of securities from
issuers rated Caa1 and below.  In particular, as of the latest
trustee report dated March 5, 2010, defaulted securities total
about $16.1 million, compared to $27.5 million of defaulted
collateral reported in the May 2009 report.  Based on the same
report, the weighted average rating factor is currently 2732
compared to 2893 in May 2009, and securities rated Caa1/CCC+ or
lower make up approximately 11.6% of the underlying portfolio
versus 17.4% in May 2009.  Additionally, the Class B
overcollateralization ratio increased to 111.44% from 105.09% in
May 2009.  Moody's also notes that the transaction has benefited
from exposure to mezzanine and junior CLO tranches whose recent
credit qualities have either stabilized or improved.

The rating action taken on the Class 2 Participation Notes
reflects the fact that interest payments on the Class B and Class
C Notes are no longer being deferred since October 2009 as a
result of the cure of the Class A and Class B
overcollateralization tests.

Sagamore CLO, Ltd., issued in October 2003, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.  On June 9, 2009, Moody's downgraded all the notes issued
by Sagamore CLO, Ltd., as a result of the application of revised
and updated key modeling assumptions as well as the deterioration
in the credit quality of the transaction's underlying portfolio.


VALLEJO PUBLIC: S&P Raises Rating on $10.8 Mil. Bonds From 'B'
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating and
underlying rating to 'BBB' from 'B' on Vallejo Public Financing
Authority, Calif.'s $10.8 million series 2003A local agency
revenue bonds, issued for Vallejo-Glen Cove Community Assessment
District No. 61.  Standard & Poor's also removed the rating and
SPUR from CreditWatch with developing implications, where they had
been placed on May 7, 2008, and assigned a stable outlook to the
rating and SPUR.

"The rating action is based on S&P's understanding that despite
the city's current Chapter 9 bankruptcy status, pledged assessment
revenues securing the bonds have been deemed restricted for debt
service by the courts, with all historical debt service payments
being made in a full and timely manner," said Standard & Poor's
credit analyst Paul Dyson.

The series 2003A bonds, issued pursuant to California's Marks-Roos
Local Bond Pooling Act of 1985, are special obligations of the
authority secured by revenues from the repayment of district's
1993A bonds and from a debt service reserve fund currently funded
at $1.08 million (10% of the original par amount).

Coverage of district debt service by fiscal 2010 assessments is
estimated by management at 1.04x, with coverage of series 2003
authority debt service by district debt service at 1.46x.  S&P
believes that dilution of coverage is unlikely due to provisions
against the district or the authority issuing additional bonds,
and given the bonds' short maturity (2011).  Further strengthening
the security of the revenue stream, in S&P's opinion, is the
diversity of the tax base -- the leading 10 taxpayers represent
just 2% of the total lien.  The short maturity on the outstanding
debt, combined with the debt service reserve fund, adds a
significant amount of credit comfort, in S&P's view, despite the
district's rising delinquencies and its large fiscal 2010 assessed
value decline; these factors also provide us with a degree of
comfort with regard any uncertainty related to the city's current
bankruptcy status.  Also, the direct value-to-lien ratio has grown
to what S&P considers an extremely strong 196 to 1 as of fiscal
2010.

The combination of a lack of reserves, the city's inability to
generate additional revenues, and the burden of fixed labor
contracts led to the city's decision to file for Chapter 9
bankruptcy in May 2008.  However, since that filing, court rulings
have deemed assessment district revenues as restricted for debt
service and protected from claims from various debtors of the
city, thus presenting a legal hurdle to the city appropriating
such revenues for other purposes.  As such, no debt service
payments have been delayed or missed to date, nor has a draw from
the debt service reserve fund occurred.

Assessment District No. 61, also known as Glen Cove, is a fully
developed residential community in the City of Vallejo that
contains 2,554 single-family parcels.


WACHOVIA BANK: Fitch Downgrades Ratings on Series 2003-C9 Certs.
----------------------------------------------------------------
Fitch Ratings has downgraded and assigned Rating Outlooks to
several classes of Wachovia Bank Commercial Mortgage Trust,
commercial mortgage pass-through certificates, series 2003-C9.
Fitch has also assigned Loss Severity ratings and Recovery Ratings
to numerous classes.

The downgrades are due to an increase in expected losses on
specially serviced assets coupled with expected losses following
Fitch's prospective review of potential stresses to the
transaction.  The majority of the total expected losses are
associated with loans currently in special servicing.

As of the February 2010 distribution date, the pool's certificate
balance has paid down 24.4% to $868.7 million from
$1,149.2 million at issuance.  Eleven loans are defeased (13% of
the current transaction balance).

There are six specially serviced loans in the pool (11.5%),
including the third (7%) and 11th (2%) largest loans.  Three loans
are delinquent, two are in foreclosure, and one is current.

The largest specially serviced asset (7%) is a 1.4 million sf
regional mall located n Lancaster, PA.  The loan transferred to
special servicing in April 2009 due to bankruptcy of the borrowing
entity.  The loan is current following three months of timely
payments by the borrower.  The special servicer and the borrower
agreed to a modification plan, and the loan is expected to return
to the master in April 2010.  Fitch does not expect a loss on this
loan due to strong performance (2008 NOI DSCR 2.40 times (x) with
occupancy of 97%).

The second largest specially serviced asset is a 360-unit
multifamily property located in Gainesville, FL.  The loan
transferred to special servicing in October 2009 due to monetary
default.  The special is in discussion with the borrower regarding
a loan modification.  The Gainesville apartment market is weak as
the property's current 67% occupancy reflects.

Fitch stressed the cash flow of the remaining non defeased loans
by applying a 10% reduction to 2008 fiscal year end net operating
income and applying an adjusted market cap rate between 7.5% and
10% to determine value.

Similar to Fitch's prospective analysis of recent vintage CMBS,
each loan also underwent a refinance test by applying an 8%
interest rate and 30-year amortization schedule based on the
stressed cash flow.  Loans that could refinance to a debt service
coverage ratio of 1.25 times or higher were considered to payoff
at maturity.  Of the non-defeased or non-specially serviced loans,
eleven loans (5.6% of the pool) incurred a loss when compared to
Fitch's stressed value.  Fitch expects losses of 3% of the
remaining transaction balance, or $26 million, from loans in
special servicing and loans that cannot refinance at maturity
based on Fitch's refinance test.

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

  -- $15.8 million class G to 'BB/LS5' from 'BBB+'; Outlook
     Negative;

  -- $15.8 million class H to 'B/LS5' from 'BBB-'; Outlook
     Negative;

  -- $8.6 million class J to 'B-/LS5' from 'BB+'; Outlook
     Negative';

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

  -- $4.3 million class L to 'B-/LS5' from 'BB-'; Outlook
     Negative';

  -- $4.3 million class M to 'B-/LS5' from 'B+'; Outlook
     Negative';

  -- $5.7 million class N to 'CC/RR6' from 'B';

  -- $2.9 million class O to 'CC/RR6' from 'B-'.

Classes J, K, L, M, N, and O have been removed from Rating Watch
Negative.

In addition, Fitch has affirmed, maintains or revises Outlooks and
assigns LS ratings to these classes as indicated:

  -- $172.3 million class A-3 at 'AAA/LS1'; Outlook Stable;

  -- $508.5 million class A-4 at 'AAA/LS1'; Outlook Stable;

  -- Interest-only classes XC and XP at 'AAA';

  -- $34.5 million class B at 'AAA/LS4'; Outlook Stable;

  -- $17.2 million class C at 'AAA/LS4'; Outlook Stable;

  -- $33 million class D at 'AA-/LS4'; Outlook Stable;

  -- $14.4 million class E at 'A/LS5'; Outlook revised to Stable
     from Negative;

  -- $15.8 million class F at 'A-/LS5'; Outlook Negative.

Fitch does not rate the $9.8 million class P.


WACHOVIA BANK: Fitch Takes Various Rating Actions on 2003-C3 Notes
------------------------------------------------------------------
Fitch Ratings takes various rating actions to Wachovia Bank
Commercial Trust's commercial mortgage pass-through certificates,
series 2003-C3:

Fitch downgrades, assigns LS ratings and Outlooks to these
classes:

  -- $12.9 million class H to 'BBB/LS5' from 'A'; Outlook
     Negative;

  -- $22.3 million class J to 'BB/LS4' from 'BBB'; Outlook
     Negative;

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

  -- $7.0 million class L to 'B-/LS5' from 'BB-'; Outlook
     Negative;

  -- $2.3 million class M to 'B-/LS5' from 'B+'; Outlook Negative;

In addition, Fitch downgrades and assigns Recovery Ratings to
these classes:

  -- $7.0 million class N to 'CCC/RR3' from 'B-';
  -- $4.7 million class O to 'CC/RR6' from 'CCC';

In addition, Fitch affirms these classes, assigns LS ratings, and
revises Outlooks as indicated:

  -- $10.5 million class F at 'AAA/LS5'; Outlook Negative;
  -- $12.9 million class G at 'AA/LS5'; Outlook Negative;

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

  -- $66.3 million class A-1 at 'AAA/LS1'; Outlook Stable;
  -- $477.8 million class A-2 at 'AAA/LS1'; Outlook Stable;
  -- Interest-only class IO-I at 'AAA'; Outlook Stable;
  -- Interest-only class IO-II at 'AAA'; Outlook Stable;
  -- $36.3 million class B at 'AAA/LS4'; Outlook Stable;
  -- $12.9 million class C at 'AAA/LS5'; Outlook Stable;
  -- 25.8 million class D at 'AAA/LS4'; Outlook Stable;
  -- 12.9 million class E at 'AAA/LS5'; Outlook Stable;

Fitch does not rate class P.

The downgrades are due to an increase in Fitch expected losses
(3.7% of the original deal balance) upon the disposition of
specially serviced assets along with expected losses from Fitch's
prospective review of potential stresses.  Rating Outlooks reflect
the likely direction of any changes to the ratings over the next
one to two years.

There are 117 of the original 130 loans remaining in transaction,
18 of which have defeased (18.5% of the current transaction
balance).  There are 10 specially serviced loans of which, five
are REO, one is 90+ days delinquent, two are 60+ days delinquent,
and two are 30+ days delinquent.

The largest specially serviced asset (2.9%) is a 208-unit
multifamily property in Tampa, FL.  The loan transferred Feb. 10,
2010 for payment default.  The borrower is seeking short-term
forbearance but has yet to submit a detailed proposal and property
performance report.

The second largest specially serviced asset (1.4%) is a 464-unit
multifamily property in San Antonio, TX.  The loan transferred
May 13, 2009 due to significant deferred maintenance.  The loan is
currently 30 days delinquent, and the lender will continue
monitoring the loan.

The third largest specially serviced asset (1.1%) is a 107,087
square foot office property in Aurora, IL.  The loan transferred
April 15, 2009 due to payment default, and the property is
currently REO.  The borrower was unable to pay the debt service
after losing the largest tenant, Hallmark, in January 2009.  The
borrower has been unable to fill the space previously occupied by
Hallmark.

Fitch stressed the cash flow of the remaining non defeased loans
by applying a 10% reduction to 2008 fiscal year end net operating
income and applying an adjusted market cap rate between 7.5% and
10% to determine value.

Similar to Fitch's prospective analysis of recent vintage CMBS,
each loan also underwent a refinance test by applying an 8%
interest rate and 30-year amortization schedule based on the
stressed cash flow.  Loans that could refinance to a debt service
coverage ratio of 1.25 times or higher were considered to payoff
at maturity.  Nineteen loans did not payoff at maturity and five
loans incurred a minimal loss when compared to Fitch's stressed
value.


WEBBERVILLE: S&P Downgrades Rating on Bonds to 'BB'
---------------------------------------------------
Standard & Poor's Ratings Services has lowered its long-term
rating on Webberville, Michigan's series 1994 water and sewer
revenue bonds to 'BB' from 'BB+' due to the village's failure to
follow through with planned rate increases, which resulted in a
decrease in coverage to 0.7x in fiscal 2009, and management's
expectation of similar coverage for fiscal 2010.  The outlook is
stable.

The rating is also based on Standard & Poor's opinion of these
credit factors:

* History of infrequent rate increases to address decreasing
  coverage;

* Combined rates that are currently above statewide averages for
  rated water and sewer utilities;

* Recently strong, albeit decreasing, liquidity, which fell to 482
  days' cash on hand in fiscal 2009, and management's expectation
  that the downward trend will continue in fiscal 2010.

These weaknesses are moderated by good income levels in the
village, as measured by median household effective buying income.

Although Standard & Poor's understood that the village board
planned to vote on a rate increase in April 2009 to address
management's projections that revenues for fiscal 2009 would fall
below 1x debt service coverage, well below the 1.2x rate covenant,
the village board decided not to hold the vote.  As a result,
rates remained at 2006 levels, creating stagnant operating revenue
for the system.  Consequently, in fiscal 2009, coverage fell to
0.7x, a level that Standard & Poor's considers to be insufficient.
The use of unrestricted cash reserves to cover the system's
increasing operating expenditures resulted in a liquidity decrease
to 482 days' cash on hand, or $309,000, in fiscal 2009 -- a level
that Standard & Poor's still considers to be strong -- from 816
days in fiscal 2008.  Management projects that fiscal 2010 (ending
March 31) will show similarly low coverage levels.  The village
previously fell below 1x coverage in fiscals 2003-2005, but a
monthly rate increase generated adequate debt service coverage in
fiscals 2006 and 2007.

"Maintenance of the rating and stable credit outlook depends on
the village's board taking the steps necessary to provide adequate
coverage and liquidity.  If management's efforts do not result in
improved coverage, or should liquidity decline below levels S&P
consider to be adequate, the rating could be lowered," said
Standard & Poor's credit analyst Sean Hughes.

The net revenues of the water and sewer system secure the bonds.


* Moody's Confirms Ratings on 13 Classes From Five CMBS Deals
-------------------------------------------------------------
Moody's Investors Service confirms 13 and downgrades two non-
pooled or rake classes from five CMBS transactions.  Moody's also
maintains 3 rake classes from one transaction on review for
downgrade.  Following the Chapter 11 bankruptcy filing of General
Growth Properties and affiliates on April 16, 2009, these classes
were initially watchlisted in April 2009 and maintained on review
in October 2009, due to Moody's concerns about potential non-
reimbursed interest shortfalls.  In November 2009, GGP reached
agreement on new loan terms with lenders and special servicers
that would allow for the transfer of CMBS affected loans back to
the respective master servicers.  Following discussions with the
special servicers regarding the loan modification terms and the
payment priorities stipulated within the respective inter-creditor
agreements, Moody's have concluded that interest shortfalls
resulting from servicing fees, legal expenses and other trust
expenses will be repaid in full in some cases, while non-
recoverable interest shortfalls due to work-out fees or trust
expenses will be incurred in others.

Specifically, Moody's are confirming these rake classes.  Four
rake classes associated with the Woodlands Mall loan (WBCMT 2006-
C26) and the GGP mall portfolio loan (GSMS 2001-GL3A) did not and
will not incur interest shortfalls due to the presence of non-
trust subordinate debt which is available to absorb various trust
expenses.  Three rake classes associated with the Ala Moana Center
loan (CGCMT 2006-C5) and one rake class associated with the
Northridge Fashion Center loan (GSMS 2001-GL3A) had incurred
interest shortfalls that were reimbursed.  Five rake classes
associated with the Boulevard Mall loan (GECMC 2003-C2) had
incurred interest shortfalls which were reimbursed, however a
minimal shortfall will remain outstanding on the lowest rated rake
class.

Moody's is downgrading these two rake classes.  One rake class
associated with the Northridge Fashion Center loan (GSMS 2001-
GL3A) had incurred interest shortfalls, the majority of which were
recovered.  However, the non-recoverable balance will result in an
expected recovery rate on the class which is not commensurate with
the existing rating level.  One rake class associated with the
Park Place loan (WBCMT 2004-C14) will incur additional interest
shortfalls in the future as a result of a 1% work-out fee being
charged by the special servicer on this deal.  This fee is
assessed on monthly interest and principal payment as well as any
balloon payment.  The fee is not expected to be recovered.  This
action concludes Moody's review of the above five transactions.

In the case of the Gallery at Harborplace loan (Gallery at
Harborplace 2000-C5C), Moody's is still assessing the extent of
the interest shortfalls and the potential for recovery and
therefore is continuing the review of this transaction.

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

Moody's rating action is:

Citigroup Commercial Mortgage Trust, Commercial Mortgage Pass-
Through Certificates, Series 2006-C5

  -- Class AMP-1, $39,865,411, Confirmed at Baa2; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

  -- Class AMP-2, $47,838,494, Confirmed at Baa3; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

  -- Class AMP-3, $26,909,153, Confirmed at Ba1; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

These classes are supported by a B note secured by the borrower's
interest in Ala Moana Center, a 2.0 million square foot regional
mall and office component located in Honolulu, Hawaii.  The Ala
Moana Center is the dominant retail center in its trade area and
is considered the world's largest open-air shopping center.  The
Ala Moana loan has been extended until June 2018.  Interest
shortfalls accrued to date have been recovered in full.  The
special servicer is not applying a 1% workout to this loan.  No
further interest shortfalls are expected.

Moody's prior review is summarized in a press release dated
February 9, 2009.

Gallery at Harborplace Mortgage Trust Commercial Mortgage Pass-
Through Certificates, Series 2000-C5C

  -- Class B-1, $3,200,000, Baa2 Placed Under Review for Possible
     Downgrade; previously on 10/22/2009 Placed Under Review for
     Possible Downgrade

  -- Class B-2, $5,100,000, Ba1 Placed Under Review for Possible
     Downgrade; previously on 10/22/2009 Placed Under Review for
     Possible Downgrade

  -- Class B-3, $2,200,000, Ba2 Placed Under Review for Possible
     Downgrade; previously on 10/22/2009 Ba2 Placed Under Review
     for Possible Downgrade

These classes are supported by a B note secured by the borrower's
interest in Gallery at Harborplace, a 404,000 square foot office
and retail mixed use complex located within the Inner Harbor
development in Baltimore, Maryland.  The property was developed in
1987 by The Rouse Company which was acquired by GGP in 2004.
Moody's is still assessing the extent of the interest shortfalls
and the potential for recoveries and is therefore continuing the
review of this transaction.

Moody's prior review is summarized in a press release dated
March 11, 2009.

GE Commercial Mortgage Corporation, Commercial Mortgage Pass-
Through Certificates, Series 2003-C2

  -- Class BLVD-1, $1,277,192, Confirmed at A2; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

  -- Class BLVD-2, $2,501,000, Confirmed at A3; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

  -- Class BLVD-3, $4,502,000, Confirmed at Baa1; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

  -- Class BLVD-4, $3,549,000, Confirmed at Baa2; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

  -- Class BLVD-5, $7,960,750, Confirmed at Baa3; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

These classes are supported by a B note secured by the borrower's
interest in Boulevard Mall, a 1.2 million square foot shopping
center located in Las Vegas, Nevada.  The center is anchored by
Sears, Dillard's, Macy's and J.C. Penney.  The Boulevard Mall loan
has been extended until July 2018.  Interest shortfalls accrued to
date are expected to be recovered except for a de minimus amount.
The special servicer is not applying a 1% workout fee to this
loan.  No further interest shortfalls are expected.

Moody's prior review is summarized in a press release dated
September 25, 2008.

GS Mortgage Securities Corporation II, Commercial Pass-Through
Certificates, Series 2001-GL III

  -- Class F-NFC, $10,460,000, Confirmed at Aa3; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

  -- Class G-NFC, $5,910,569, Downgraded to Baa2; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

These classes are supported by a B note secured by the borrower's
interest in Northridge Fashion Center, a 1.4 million square foot
regional mall located in Northridge, California.  The mall is
anchored by Macy's, Sears and J.C.  Penney.  The Northridge
Fashion Center loan has been extended until December 2014.  A
significant portion of the interest shortfalls accrued to date are
expected to be recovered, however the remaining portion consisting
of miscellaneous fees will be non-recoverable.  The non-
recoverable balance will result in an expected recovery rate on
the G-NFC class which is not commensurate with the existing rating
level.  The special servicer is not applying a 1% workout to this
loan.  No further interest shortfalls are expected.

GS Mortgage Securities Corporation II, Commercial Pass-Through
Certificates, Series 2001-GL III

  -- Class F-GGP, $5,960,000, Confirmed at A3; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

  -- Class G-GGP, $3,500,000, Confirmed at Baa1; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

  -- Class H-GGP, $3,480,000, Confirmed at Baa2; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

These classes are supported by a junior participation interest
in a first mortgage loan secured by the borrower's interest in
three regional shopping centers with total gross leasable area of
1.6 million square feet located in tertiary markets in Missouri,
Oregon and Kentucky.  The properties are: Capital Mall, located in
Jefferson City, Missouri, containing 392,028 square feet and
anchored by JC Penney, Dillard's, Sears, and an eight-screen movie
theater; Gateway Mall, located in Springfield, Oregon, containing
602,946 SF and anchored by JC Penney, Sears and two movie theaters
with a total of 12 screens; and Greenwood Mall in Bowling Green,
Kentucky, containing 558,434 SF and anchored by Dillard's, Macy's
and Sears.

The GGP Portfolio loan has been extended until October 2014.  No
interest has been shorted on the bonds due to the subordinate debt
outside of the trust.  The special servicer is applying at 1%
workout fee to this loan which will continue to accrue and is
expected to be absorbed by the non-trust subordinate debt.

Moody's prior full review is summarized in a press release dated
March 19, 2003.

Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-
Through Certificates, Series 2004-C14

  -- Class PP, $37,022,375, Downgraded to B2; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

The class is supported by a B note secured by the borrower's
interest in Park Place Mall, a 1.0 million square foot regional
mall located in Tucson, Arizona.  The center is anchored by Sears,
Dillard's and Macy's.

The Park Place Mall loan has been extended until January 2015.
Interest shortfalls accrued to date have been fully recovered.
However, the special servicer is applying at 1% workout fee to
this loan which will continue to accrue and is deemed non-
recoverable.  The expected shortfall will result in a recovery
rate on the class which is not commensurate with the existing
rating level.

Moody's prior full review is summarized in a press release dated
May 4, 2007.

Wachovia Bank Commercial Mortgage Trust 2006-C26, Commercial Pass-
Through Certificates, Series 2006-C26

  -- Class WM, $9,849,305, Confirmed at Baa3; previously on
     10/22/2009 Placed Under Review for Possible Downgrade

The class is supported by a B note secured by the borrower's
interest in Woodlands Mall, 1.4 million square foot mall located
in Woodlands, Texas.  The center is anchored by Dillard's,
Foley's, Sears and J.C. Penney.  The Woodlands Mall loan has been
extended until June 2016.  No interest has been shorted on the
bonds due to the subordinate debt outside of the trust.  The
special servicer is applying at 1% workout fee to this loan which
will continue to accrue and is expected to be absorbed by the
subordinate debt.

Moody's prior review is summarized in a press release dated
February 10, 2009.


* S&P Downgrades Ratings on 23 Tranches From Five CLO Transactions
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 23
tranches from five U.S. collateralized loan obligation
transactions and removed them from CreditWatch with negative
implications.  The affected tranches have a total issuance amount
of $3.180 billion.  At the same time, S&P affirmed its ratings on
nine tranches from four CLO transactions and removed them from
CreditWatch negative.

The downgrades reflect two primary factors:

* The application of S&P's updated corporate CDO criteria; and

* Deterioration in the credit quality of certain CDO tranches due
  to increased exposure to obligors that have either defaulted or
  experienced downgrades into the 'CCC' range.

The downgrades of two classes from two 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's analysis incorporated the asset recovery assumptions in its
new CDO criteria.  To provide additional transparency into the
assumptions S&P used in its analysis, S&P is providing the tiered
recovery rate S&P assumed for the cash flows generated for the
'AAA' liability rating for each transaction.

         Tiered Recovery Rate For 'AAA' Liability Rating

       Transaction                        Recovery rate (%)
       -----------                        -----------------
       1888 Fund Ltd.                                40.6
       A5 Funding L.P.                               45.9
       Ares VR CLO Ltd.                              40.0
       Ares XI CLO Ltd.                              40.2
       Golub International Loan Ltd. I               44.1
       Katonah VII CLO Ltd.                          44.5
       KKR Financial CLO 2007-A                      41.4

The affirmations reflect S&P's view that the tranches have
adequate credit support to maintain the current ratings according
to its updated criteria.

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
    -----------               -----     --     ----
    1888 Fund Ltd.            A-1       AA     AAA/Watch Neg
    1888 Fund Ltd.            A-2       AA     AAA/Watch Neg
    1888 Fund Ltd.            B         A+     A+/Watch Neg
    1888 Fund Ltd.            C         B+     BBB/Watch Neg
    A5 Funding L.P.            Term Nts  AAA    AAA/Watch Neg
    A5 Funding L.P.            Rev Nts   AAA    AAA/Watch Neg
    Ares VR CLO Ltd.          A-1       A+     AAA/Watch Neg
    Ares VR CLO Ltd.          A-2       A+     AAA/Watch Neg
    Ares VR CLO Ltd.          A-3       A+     AAA/Watch Neg
    Ares VR CLO Ltd.          B         A+     AA/Watch Neg
    Ares VR CLO Ltd.          C         BBB-   A-/Watch Neg
    Ares VR CLO Ltd.          D         CCC+   BB-/Watch Neg
    Ares XI CLO Ltd.          A-1a      AA+    AAA/Watch Neg
    Ares XI CLO Ltd.          A-1b      AA+    AAA/Watch Neg
    Ares XI CLO Ltd.          A-1c      AA-    AAA/Watch Neg
    Ares XI CLO Ltd.          A-2       AA-    AAA/Watch Neg
    Ares XI CLO Ltd.          B         A-     AA/Watch Neg
    Ares XI CLO Ltd.          C         BBB-   A/Watch Neg
    Ares XI CLO Ltd.          D         BB     BBB/Watch Neg
    Ares XI CLO Ltd.          E         BB-    BB+/Watch Neg
    Golub International Loan  A         AA-    AA-/Watch Neg
      Ltd. I
    Katonah VII CLO Ltd.      A-1       AA-    AAA/Watch Neg
    Katonah VII CLO Ltd.      A-2       AA-    AAA/Watch Neg
    Katonah VII CLO Ltd.      B         A+     AA/Watch Neg
    Katonah VII CLO Ltd.      C         BB+    A-/Watch Neg
    Katonah VII CLO Ltd.      D         CCC-   BB/Watch Neg
    KKR Financial CLO 2007-A  A         AA+    AAA/Watch Neg
    KKR Financial CLO 2007-A  B         AA     AA/Watch Neg
    KKR Financial CLO 2007-A  C         A      A/Watch Neg
    KKR Financial CLO 2007-A  D         BBB    BBB/Watch Neg
    KKR Financial CLO 2007-A  E         BB     BB/Watch Neg
    KKR Financial CLO 2007-A  F         B      B/Watch Neg


* S&P Downgrades Ratings on 24 Tranches From Eight CDO Deals
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 24
tranches from eight U.S. cash flow and hybrid collateralized debt
obligation transactions.  At the same time, S&P removed 15 of the
lowered ratings from CreditWatch with negative implications.
Additionally, S&P placed three of the lowered ratings on
CreditWatch negative, and its ratings on five of the downgraded
tranches remain on CreditWatch negative, indicating a significant
likelihood of further downgrades.  S&P also affirmed its ratings
on 18 other tranches.

The CDO downgrades reflect a number of factors, including credit
deterioration and S&P's negative rating actions on underlying U.S.
subprime residential mortgage-backed securities.  S&P's
CreditWatch placements primarily affect transactions for which a
significant portion of the collateral assets currently have
ratings on CreditWatch with negative implications or that have
significant exposure to assets rated in the 'CCC' category.

The 24 downgraded U.S. cash flow and hybrid tranches have a total
issuance amount of $4.584 billion.  Five of the eight affected
transactions are mezzanine structured finance CDOs of asset-backed
securities, which are collateralized in large part by mezzanine
tranches of RMBS and other SF securities.  The other three are
high-grade SF CDOs of ABS that were collateralized at origination
primarily by 'AAA' through 'A' rated tranches of RMBS and other SF
securities.

The affirmations reflect current credit support levels that S&P
believes are sufficient to maintain the current ratings.

Standard & Poor's will continue to monitor the CDO transactions it
rates and take rating actions, including CreditWatch placements,
when appropriate.

                           Rating Actions

                                       Rating
                                       ------
  Transaction             Class    To             From
  -----------             -----    --             ----
  C-Bass CBO XI           A        CCC-/Watch Neg AA+/Watch Neg
  C-Bass CBO XI           B        CC             A+/Watch Neg
  C-Bass CBO XI           C        CC             BBB-/Watch Neg
  C-Bass CBO XI           D        CC             B/Watch Neg
  C-Bass CBO XII          A        B/Watch Neg    AAA
  C-Bass CBO XII          B        CCC-/Watch Neg AA+
  C-Bass CBO XII          C        CC             BB+/Watch Neg
  C-Bass CBO XII          D        CC             B/Watch Neg
  Davis Square Funding VI A-1LTa   CC             BB-/Watch Neg
  Davis Square Funding VI A-1LT-b  CC             BB-/Watch Neg
  Davis Square Funding VI A-1LT-c  CC             BB-/Watch Neg
  Davis Square Funding VI A-2      CC             B-/Watch Neg
  Dawn CDO I              A        CCC/Watch Neg  BB
  Dawn CDO I              B        CC             CCC-
  Jupiter High Grade CDO  A-1A     B/Watch Neg    A-/Watch Neg
  Jupiter High Grade CDO  A-1B     B/Watch Neg    A-/Watch Neg
  Jupiter High Grade CDO  A-2      CC             B/Watch Neg
  Jupiter High Grade CDO  B        CC             CCC-/Watch Neg
  Neptune CDO 2004-1      A-1LA    CC             BBB-/Watch Neg
  Neptune CDO 2004-1      A-1LB    CC             CCC/Watch Neg
  Reservoir Funding       A-1-NV   CCC/Watch Neg  BBB-/Watch Neg
  Reservoir Funding       A-1-V    CCC/Watch Neg  BBB-/Watch Neg
  Summer Street 2004-1    A-1      CC             BBB/Watch Neg
  Summer Street 2004-1    A-2      CC             B/Watch Neg

                         Ratings Affirmed

             Transaction             Class    Rating
             -----------             -----    ------
             Davis Square Funding VI B        CC
             Davis Square Funding VI C        CC
             Davis Square Funding VI D        CC
             Jupiter High Grade CDO  C        CC
             Neptune CDO 2004-1      A-2L     CC
             Neptune CDO 2004-1      A-3L     CC
             Neptune CDO 2004-1      B-1L     CC
             Pascal CDO              A        CC
             Pascal CDO              C        CC
             Pascal CDO              ComboNts AAA
             Reservoir Funding       A-2      CC
             Reservoir Funding       B        CC
             Reservoir Funding       C        CC
             Reservoir Funding       D        CC
             Summer Street 2004-1    A-3      CC
             Summer Street 2004-1    B        CC
             Summer Street 2004-1    C        CC
             Summer Street 2004-1    DIncNts  CC

                     Other Outstanding Ratings

             Transaction             Class    Rating
             -----------             -----    ------
             Pascal CDO              B        D


* S&P Downgrades Ratings on 28 Classes From 13 RMBS Transactions
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 28
classes from 13 residential mortgage-backed securities
transactions backed by U.S. closed-end second-lien, home equity
line of credit, home improvement, and second-lien high combined
loan-to-value mortgage loan collateral issued from 1995 to 2007.
S&P removed 10 of the lowered ratings from CreditWatch negative.
S&P downgraded 10 classes to 'D' due to realized losses on the
certificate balances of those classes.  In addition, S&P affirmed
its ratings on 48 classes from 14 transactions and removed seven
of them from CreditWatch negative.

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

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

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.

A combination of subordination, excess spread, and
overcollateralization provide credit support for the affected
transactions.  The underlying pool of loans backing these
transactions consist of fixed- and adjustable-rate mortgage loans
that are secured by second liens on one- to four-family
residential properties.

                          Rating Actions

        Conseco Finance Home Improvement Loan Trust 2000-E
                        Series      2000-E

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        B-2        20846QEJ3     D                    B-

                            CWABS, Inc.
                        Series      2002-S1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-4        126671PU4     AAA                  AAA/Watch Neg
    A-5        126671PV2     AAA                  AAA/Watch Neg
    A-IO       126671PW0     AAA                  AAA/Watch Neg
    M-1        126671PP5     CC                   AA/Watch Neg

       CWHEQ Revolving Home Equity Loan Trust, Series 2007-G
                        Series      2007-G

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-7        23242JAH1     CC                   CCC
        M-8        23242JAJ7     CC                   CCC

       Fieldstone Mortgage Investment Trust, Series 2006-S1
                       Series      2006-S1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A          31659XAA4     CC                   CCC
        M1         31659XAB2     D                    CCC
        M2         31659XAC0     D                    CC
        M3         31659XAD8     D                    CC
        M4         31659XAE6     D                    CC
        M5         31659XAF3     D                    CC
        M6         31659XAG1     D                    CC
        B1         31659XAH9     D                    CC
        B2         31659XAJ5     D                    CC
        B3         31659XAK2     D                    CC

           First Franklin Mortgage Loan Trust 2003-FFA
                       Series      2003-FFA

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    I-B-1      22541ND48     AAA                  AAA/Watch Neg
    I-B-2      22541NF46     AAA                  AAA/Watch Neg
    I-B-3      22541ND55     B-                   AA/Watch Neg
    I-B-4      22541ND63     CC                   A+/Watch Neg

              GMACM Home Equity Loan Trust 2000-HE2
                       Series      2000-HE2

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1        361856AN7     BB+                  BBB+/Watch Neg
    A-2        361856AP2     BB+                  BBB+/Watch Neg

              GMACM Home Equity Loan Trust 2000-HE4
                       Series      2000-HE4

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1        361856AQ0     BB+                  BBB/Watch Neg
    A-2        361856AR8     BB+                  BBB/Watch Neg

              GMACM Home Equity Loan Trust 2006-HE5
                       Series      2006-HE5

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        I-A-1      38012EAA3     BB                   BBB-
        II-A-2     38012EAC9     BB                   BBB-

       GMACM Home Equity Notes 2004 Variable Funding Trust
                      Series      2004 NOTES

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        VFN        36186FAA4     BBB+                 AAA

                    Home Loan Trust 2003-HI2
                      Series      2003-HI2

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        B          76110VNK0     CC                   BB

                    Home Loan Trust 2004-HI1
                      Series      2004-HI1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        B          345454AB8     CC                   B

    Structured Asset Securities Corporation Mortgage Loan Trust
                       Series      2005-S7

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A2         863576DT8     AAA                  AAA/Watch Neg
    M1         863576DU5     AA                   AA/Watch Neg
    M2         863576DV3     B-                   BBB/Watch Neg
    M3         863576DW1     CC                   BB/Watch Neg

   Structured Asset Securities Corporation Mortgage Loan Trust
                       Series      2006-S1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A1         86359DXC6     BB                   AA/Watch Neg

                         Ratings Affirmed

            Bear Stearns Home Loan Owner Trust 2001-A
                        Series      2001-A

                  Class      CUSIP         Rating
                  -----      -----         ------
                  M-2        07384NAH3     BBB

        Conseco Finance Home Improvement Loan Trust 2000-E
                        Series      2000-E

                  Class      CUSIP         Rating
                  -----      -----         ------
                  M-1        20846QEF1     AA
                  M-2        20846QEG9     A
                  B-1        20846QEH7     BBB

      CWHEQ Revolving Home Equity Loan Trust, Series 2007-G
                        Series      2007-G

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A          23242JAA6     BB
                  M-1        23242JAB4     BB-
                  M-2        23242JAC2     B
                  M-3        23242JAD0     B-
                  M-4        23242JAE8     CCC
                  M-5        23242JAF5     CCC
                  M-6        23242JAG3     CCC

            Empire Funding Home Loan Owner Trust 1997-4
                       Series      1997-4

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A-5        291701BJ8     AAA

           Empire Funding Home Loan Owner Trust 1997-5
                        Series      1997-5

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A-4        291701BT6     AAA
                  M-1        291701BV1     AA

           Empire Funding Home Loan Owner Trust 1999-1
                        Series      1999-1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A-5        291701DA5     AAA
                  M-1        291701DB3     AA
                  M-2        291701DC1     A
                  B-1        291701DD9     BBB-

           First Franklin Mortgage Loan Trust 2003-FFA
                       Series      2003-FFA

                  Class      CUSIP         Rating
                  -----      -----         ------
                  P          22541NE88     AAA
                  II-M-2     22541NE62     AAA

            First Franklin Mortgage Loan Trust 2004-FFA
                       Series      2004-FFA

                  Class      CUSIP         Rating
                  -----      -----         ------
                  M3-A       32027NFU0     A
                  M3-F       32027NFV8     A
                  M4         32027NFW6     BBB+
                  M5         32027NFX4     BBB

                Home Improvement Loan Trust 1995-A
                       Series      1995-A

                  Class      CUSIP         Rating
                  -----      -----         ------
                  B          393505FR8     BB+

                    Home Loan Trust 2003-HI2
                      Series      2003-HI2

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A-6        76110VNE4     AAA
                  M-1        76110VNG9     AA
                  M-2        76110VNH7     A
                  M-3        76110VNJ3     BBB

                    Home Loan Trust 2003-HI4
                      Series      2003-HI4

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A-I-5      76110VPD4     AAA
                  A-II       76110VPF9     AAA
                  M-1        76110VPG7     AA
                  M-2        76110VPH5     A
                  M-3        76110VPJ1     BBB
                  B                        BB

                     Home Loan Trust 2004-HI1
                       Series      2004-HI1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A-5        76110VPR3     AAA
                  M-1        76110VPS1     AA
                  M-2        76110VPT9     A
                  M-3        76110VPU6     BBB+
                  M-4        76110VPV4     BBB
                  M-5        76110VPW2     BBB-


* S&P Downgrades Ratings on 78 Classes From Five RMBS Transactions
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 78
classes from five U.S. residential mortgage-backed securities
transactions backed by U.S. subprime and prime jumbo residential
mortgage loan collateral issued in 2005 and 2007.  Concurrently,
S&P removed 69 of the lowered classes from CreditWatch with
negative implications.  In addition, S&P affirmed its ratings on
39 classes from four of the downgraded transactions and one
additional deal.

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

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.

For subprime and Alt-A 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 150% for an 'AAA' rating.
For example, in general, S&P would assess whether one class could
withstand approximately 110% of its base-case loss assumptions to
maintain a 'BB' rating, while S&P would assess whether a different
class could withstand approximately 120% of S&P's base-case loss
assumptions to maintain a 'BBB' rating.  Each class with an
affirmed 'AAA' rating can, in S&P's view, withstand approximately
150% of its base-case loss assumptions under its analysis.

For the prime jumbo transactions, in order to maintain an 'AAA'
rating, S&P assessed whether the class could withstand
approximately 235% of its base-case loss assumptions, subject to
individual caps and qualitative factors applied to specific
transactions.  To maintain a rating in categories between 'B' (the
base case) and 'AAA', S&P assessed whether the class could
withstand losses exceeding the base-case assumption at a
percentage specific to each rating category, up to 235% for a
'AAA' rating.  For example, S&P would assess whether one class
could withstand approximately 130% of its base-case loss
assumptions to maintain a 'BB' rating, while S&P would assess
whether a different class could withstand approximately 155% of
its base-case loss assumptions to maintain a 'BBB' rating.

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

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

                          Rating Actions

           CWABS Asset-Backed Certificates Trust 2007-1
                        Series      2007-1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        23245CAA8     B-                   BB/Watch Neg
    2-A-1      23245CAB6     A                    AAA/Watch Neg
    2-A-2      23245CAC4     B                    AA/Watch Neg
    2-A-3      23245CAD2     B-                   BBB/Watch Neg
    2-A-4      23245CAE0     B-                   BB/Watch Neg
    M-1        23245CAF7     CCC                  B/Watch Neg
    M-6        23245CAL4     CC                   CCC
    M-7        23245CAM2     CC                   CCC
    M-8        23245CAN0     CC                   CCC

                 JPMorgan Mortgage Trust 2005-A6
                       Series      2005-A6

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A-1      466247TL7     B+                   A-/Watch Neg
    1-A-2      466247TM5     B+                   BBB+/Watch Neg
    1-A-3      466247TN3     B+                   AAA/Watch Neg
    1-A-4      466247TP8     B+                   BBB+/Watch Neg
    2-A-1      466247TQ6     B+                   AA+/Watch Neg
    2-A-2      466247TR4     BBB+                 AAA/Watch Neg
    2-A-3      466247TS2     B+                   AA+/Watch Neg
    2-A-4      466247TT0     B+                   AA+/Watch Neg
    2-A-5      466247TU7     B+                   BBB+/Watch Neg
    3-A-2      466247TW3     B+                   A+/Watch Neg
    3-A-3      466247TX1     B+                   A+/Watch Neg
    3-A-4      466247TY9     B+                   BBB+/Watch Neg
    4-A-1      466247TZ6     B+                   A-/Watch Neg
    5-A-1      466247UA9     B+                   A-/Watch Neg
    6-A-1      466247UB7     B+                   AAA/Watch Neg
    6-A-2      466247UC5     B+                   AAA/Watch Neg
    7-A-1      466247UG6     CCC                  BB/Watch Neg
    I-B-2      466247UE1     CC                   CCC
    II-B-2     466247UJ0     CC                   CCC
    I-B-3      466247UF8     CC                   CCC

       Structured Asset Securities Corporation Trust 2005-1
                        Series      2005-1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A1       86359B2R1     BBB+                 A/Watch Neg
    1-A2       86359B2S9     BBB+                 A/Watch Neg
    1-A3       86359B2T7     BBB+                 A/Watch Neg
    1-A4       86359B2U4     BBB+                 A/Watch Neg
    1-A5       86359B2V2     BBB+                 A/Watch Neg
    1-A6       86359B2W0     BBB+                 A/Watch Neg
    2-A1       86359B2X8     BBB+                 A/Watch Neg
    3-A1       86359B2Y6     BBB+                 AAA/Watch Neg
    4-A1       86359B2Z3     BBB+                 A/Watch Neg
    5-A1       86359B3A7     BBB                  A/Watch Neg
    6-A1       86359B3B5     BBB+                 A/Watch Neg
    7-A1       86359B3E9     BBB                  AAA/Watch Neg
    7-A2       86359B3F6     BBB                  AAA/Watch Neg
    7-A3       86359B3G4     BBB                  A/Watch Neg
    7-A4       86359B3H2     BBB                  A/Watch Neg
    7-A5       86359B3J8     BBB                  A/Watch Neg
    7-A6       86359B3K5     BBB                  A/Watch Neg
    7-A7       86359B3L3     BBB                  A/Watch Neg
    AP         86359B3M1     BBB                  A/Watch Neg
    AX         86359B3N9     BBB+                 AAA/Watch Neg
    PAX        86359B3P4     BBB+                 AAA/Watch Neg
    B2         86359B3R0     CC                   CCC

      Wachovia Mortgage Loan Trust, LLC Series 2005-B Trust
                        Series      2005-B

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A-1      92977YBN0     B+                   BBB+/Watch Neg
    1-A-2      92977YBS9     CCC                  BB+/Watch Neg
    2-A-1      92977YBP5     B                    A+/Watch Neg
    2-A-2      92977YBU4     B                    A+/Watch Neg
    2-A-3      92977YBV2     B                    A+/Watch Neg
    2-A-4      92977YBW0     B                    A+/Watch Neg
    2-A-5      92977YBX8     CCC                  BB+/Watch Neg
    3-A-1      92977YBQ3     BBB-                 AAA/Watch Neg
    3-A-2      92977YBY6     CCC                  BB+/Watch Neg
    4-A-1      92977YBR1     A-                   AAA/Watch Neg
    4-A-2      92977YBZ3     CCC                  BB+/Watch Neg
    B-1        92977YCA7     CC                   CCC
    B-2        92977YCB5     CC                   CCC

       Wells Fargo Mortgage Backed Securities 2007-8 Trust
                        Series      2007-8

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    I-A-3      94986AAC2     B-                   BB/Watch Neg
    I-A-10     94986AAK4     CCC                  B/Watch Neg
    I-A-13     94986AAN8     B-                   BB/Watch Neg
    I-A-14     94986AAP3     B-                   BB/Watch Neg
    I-A-16     94986AAR9     B-                   BB/Watch Neg
    I-A-22     94986AAX6     B-                   BB/Watch Neg
    II-A-7     94986ABG2     BB                   A/Watch Neg
    II-A-8     94986ABH0     BB                   A/Watch Neg
    II-A-9     94986ABJ6     BB                   A/Watch Neg
    II-A-11    94986ABL1     BB                   A/Watch Neg
    II-A-12    94986ABM9     BB                   A/Watch Neg
    II-A-16    94986ABR8     BB                   A/Watch Neg
    I-A-PO                   CCC                  BBB/Watch Neg
    II-A-2     94986ABB3     BB                   A/Watch Neg

                         Ratings Affirmed

           Chevy Chase Funding LLC Trust, Series 2006-1
                       Series      2006-1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A-1        16678RFB8     B-
                  A-2        16678RFC6     B-
                  A-NA       16678RIS9     B-
                  IO         16678RIV2     B-
                  NIO        16678RIW0     B-

           CWABS Asset-Backed Certificates Trust 2007-1
                        Series      2007-1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  M-2        23245CAG5     CCC
                  M-3        23245CAH3     CCC
                  M-4        23245CAJ9     CCC
                  M-5        23245CAK6     CCC

                 JPMorgan Mortgage Trust 2005-A6
                       Series      2005-A6

                  Class      CUSIP         Rating
                  -----      -----         ------
                  I-B-1      466247UD3     CCC
                  II-B-1     466247UH4     CCC

       Structured Asset Securities Corporation Trust 2005-1
                        Series      2005-1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  B1         86359B3Q2     CCC

        Wells Fargo Mortgage Backed Securities 2007-8 Trust
                        Series      2007-8

                  Class      CUSIP         Rating
                  -----      -----         ------
                  I-A-1      94986AAA6     CCC
                  I-A-2      94986AAB4     CCC
                  I-A-4      94986AAD0     CCC
                  I-A-5      94986AAE8     CCC
                  I-A-6      94986AAF5     CCC
                  I-A-7      94986AAG3     CCC
                  I-A-8      94986AAH1     CCC
                  I-A-9      94986AAJ7     CCC
                  I-A-11     94986AAL2     CCC
                  I-A-12     94986AAM0     CCC
                  I-A-15     94986AAQ1     CCC
                  I-A-17     94986AAS7     CCC
                  I-A-18     94986AAT5     CCC
                  I-A-19     94986AAU2     CCC
                  I-A-20     94986AAV0     CCC
                  I-A-21     94986AAW8     CCC
                  I-A-23     94986AAY4     CCC
                  II-A-1     94986ABA5     CCC
                  II-A-3     94986ABC1     CCC
                  II-A-4     94986ABD9     CCC
                  II-A-5     94986ABE7     CCC
                  II-A-6     94986ABF4     CCC
                  II-A-10    94986ABK3     CCC
                  II-A-14    94986ABP2     CCC
                  II-A-15    94986ABQ0     CCC
                  A-PO       94986ABS6     CCC
                  II-A-PO                  CCC


* S&P Downgrades Ratings on 95 Classes From 29 RMBS Transactions
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 95
classes from 29 residential mortgage-backed securities
transactions issued in 2005 and 2006 and removed 52 of them from
CreditWatch with negative implications.  In addition, S&P affirmed
its ratings on 291 classes from the downgraded transactions and 13
additional deals and removed 108 of the affirmed ratings from
CreditWatch negative.

Thirty-nine of the transactions are backed by U.S. subprime
mortgage collateral and three are backed by U.S. Alternative-A
(Alt-A) mortgage loan collateral.  Group 2 from Terwin Mortgage
Trust 2006-1 is backed by closed-end second-lien mortgage
collateral.

Standard & Poor's has revised its loss projections for each
transaction rated between 2005 and 2007.

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

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 its
view, a class could absorb the base-case loss assumptions S&P used
in its analysis.

For subprime, Alt-A, and closed-end second-lien transactions, in
order to maintain a rating higher than 'B', S&P assessed whether a
class could withstand losses exceeding its base-case loss
assumptions at a percentage specific to each rating category, up
to 150% for an 'AAA' rating.  For example, in general, S&P would
assess whether one class could withstand approximately 110% of its
base-case loss assumptions to maintain a 'BB' rating, while S&P
would assess whether a different class could withstand
approximately 120% of S&P's base-case loss assumptions to maintain
a 'BBB' rating.  Each class with an affirmed 'AAA' rating can, in
S&P's view, withstand approximately 150% of S&P's base-case loss
assumptions under its analysis.

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

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

                          Rating Actions

   Ace Securities Corp. Home Equity Loan Trust Series 2006-ASAP1
                       Series    2006-ASAP1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1        004421VS9     BB                   BB/Watch Neg
    A-2C       004421VV2     BBB                  AAA/Watch Neg
    A-2D       004421VW0     BB-                  BB-/Watch Neg

  Argent Securities Inc. Asset-Backed Pass-Through Certificates
                          Series 2005-W4

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-2C       040104PS4     AA+                  AAA

    Asset Backed Securities Corporation Home Equity Loan Trust
                       Series OOMC 2005-HE6

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A1A        04541GTE2     AAA                  AAA/Watch Neg
    A2C        04541GTH5     AAA                  AAA/Watch Neg
    A2D        04541GTJ1     AAA                  AAA/Watch Neg
    M1         04541GTK8     AA+                  AA+/Watch Neg
    M2         04541GTL6     AA                   AA/Watch Neg
    M3         04541GTM4     AA-                  AA-/Watch Neg
    M4         04541GTN2     A+                   A+/Watch Neg
    M5         04541GTP7     BB                   BB/Watch Neg

    Asset Backed Securities Corporation Home Equity Loan Trust
                       Series    2005-HE8

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1        04541GUX8     AAA                  AAA/Watch Neg
    A1A        04541GUY6     AAA                  AAA/Watch Neg
    A2         04541GUZ3     AAA                  AAA/Watch Neg
    A5         04541GUM2     AAA                  AAA/Watch Neg
    A6         04541GVA7     AAA                  AAA/Watch Neg
    M1         04541GUN0     A+                   A+/Watch Neg
    M2         04541GUP5     B+                   B+/Watch Neg
    M5         04541GUS9     CC                   CCC

      Bear Stearns Asset Backed Securities I Trust 2005-HE4
                        Series    2005-HE4

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    M-1        073879TT5     AA                   AA/Watch Neg
    M-2        073879TU2     A-                   A/Watch Neg
    M-3        073879TV0     B-                   A-/Watch Neg
    M-4        073879TW8     CCC                  BBB+/Watch Neg
    M-5        073879TX6     CC                   CCC

      Bear Stearns Asset Backed Securities I Trust 2005-HE9
                        Series    2005-HE9

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    I-A-3      073879Q92     AAA                  AAA/Watch Neg
    II-A-1     073879R26     AAA                  AAA/Watch Neg
    II-A-2     073879R34     AAA                  AAA/Watch Neg
    M-1        073879R42     AAA                  AAA/Watch Neg

      Bear Stearns Asset Backed Securities I Trust 2006-AC1
                        Series    2006-AC1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    I-A-1      07387UCE9     B-                   AAA/Watch Neg
    I-A-2      07387UCF6     B-                   AAA/Watch Neg
    I-M-1      07387UCG4     CCC                  B-/Watch Neg
    I-M-2      07387UCH2     CC                   CCC
    I-M-3      07387UCJ8     D                    CCC
    II-1A-2    07387UCU3     CC                   CCC
    II-1PO     07387UCW9     CC                   CCC
    II-2A-1    07387UCX7     CC                   CCC
    II-2A-2    07387UCY5     CC                   CCC
    II-2X      07387UCZ2     CC                   CCC
    II-2PO     07387UDA6     CC                   CCC

      Bear Stearns Asset-Backed Securities I Trust 2005-HE7
                        Series    2005-HE7

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    M-1        073879ZG6     AAA                  AAA/Watch Neg
    M-2        073879ZH4     AA                   AA/Watch Neg
    M-3        073879ZJ0     BB                   A/Watch Neg
    M-4        073879ZK7     CCC                  BB/Watch Neg
    M-5        073879ZL5     CC                   CCC

             Citigroup Mortgage Loan Trust 2006-WMC1
                       Series    2006 WMC1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-2C       17307GZ43     A-                   AA-

           CWABS Asset Backed Certificates Trust 2005-11
                        Series    2005-11

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    AF-3       126670CH9     B                    AAA/Watch Neg
    AF-4       126670CJ5     B                    AAA/Watch Neg
    AF-5A      126670CK2     B                    AAA/Watch Neg
    AF-5B      126670DR6     BB+                  AAA/Watch Neg
    AF-6       126670CL0     B                    AAA/Watch Neg
    2-AV-1     126670CW6     AAA                  AAA/Watch Neg
    3-AV-2     126670CY2     AAA                  AAA/Watch Neg
    3-AV-3     126670CZ9     AAA                  AAA/Watch Neg
    MV-1       126670DA3     A                    A/Watch Neg
    MV-2       126670DB1     B                    B/Watch Neg

          CWABS Asset Backed Certificates Trust 2005-13
                         Series    2005-13

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        MF-4       126670GX0     CC                   CCC
        3-AV-3     126670HG6     BB-                  BB

              CWABS Asset Backed Certificates Trust 2005-16
                        Series    2005-16

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    3-AV       126670PC6     BBB                  BBB/Watch Neg
    4-AV-3     126670PF9     BB                   BB/Watch Neg
    4-AV-4     126670PG7     BB                   BB/Watch Neg

           CWABS Asset Backed Certificates Trust 2005-7
                         Series    2005-7

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        AF-4       126673Y71     AA+                  AAA
        AF-5W      126673Y89     AA                   AAA
        AF-6       126673Y97     B                    AAA
        MF-1       126673Z21     B-                   B

           CWABS Asset-Backed Certificates Trust 2005-1
                         Series    2005-1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    AF-4       126673WB4     AAA                  AAA/Watch Neg
    AF-5A      126673WC2     AAA                  AAA/Watch Neg
    AF-5B      126673XN7     AAA                  AAA/Watch Neg
    AF-6       126673WD0     AAA                  AAA/Watch Neg
    MF-1       126673WE8     A                    A/Watch Neg
    MF-2       126673WF5     B                    B/Watch Neg
    MV-1       126673WX6     AA+                  AA+/Watch Neg
    MV-2       126673WY4     AA                   AA/Watch Neg
    MV-3       126673WZ1     AA-                  AA-/Watch Neg
    MV-4       126673XA5     BBB                  BBB/Watch Neg
    MV-5       126673XB3     B                    B/Watch Neg

           CWABS Asset-Backed Certificates Trust 2005-14
                         Series    2005-14

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A-1      126670LH9     AAA                  AAA/Watch Neg
    2-A-1      126670LJ5     AAA                  AAA/Watch Neg
    2-A-2      126670LK2     AAA                  AAA/Watch Neg
    3-A-2      126670LM8     AAA                  AAA/Watch Neg
    3-A-3      126670LN6     AAA                  AAA/Watch Neg
    M-1        126670LP1     A+                   AA+/Watch Neg
    M-2        126670LQ9     BB                   AA/Watch Neg
    M-3        126670LR7     B-                   AA-/Watch Neg
    M-5        126670LT3     CCC                  A/Watch Neg
    M-6        126670LU0     CCC                  A-/Watch Neg
    M-7        126670LV8     CCC                  BB/Watch Neg
    M-8        126670LW6     CC                   B-/Watch Neg
    B          126670LX4     CC                   CCC
    M-4        126670LS5     CCC                  A+/Watch Neg

          CWABS Asset-Backed Certificates Trust 2005-15
                        Series    2005-15

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-AF-3     126670MA3     AAA                  AAA/Watch Neg
    1-AF-4     126670MB1     AAA                  AAA/Watch Neg
    1-AF-5     126670MC9     AAA                  AAA/Watch Neg
    1-AF-6     126670MD7     AAA                  AAA/Watch Neg
    2-AV-2     126670MF2     AA-                  AAA/Watch Neg
    2-AV-3     126670MG0     A                    A/Watch Neg
    M-1        126670MH8     BB                   BB/Watch Neg

           CWABS Asset-Backed Certificates Trust 2005-3
                         Series    2005-3

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    AF-3       126673ZR6     AAA                  AAA/Watch Neg
    AF-4       126673ZS4     AA+                  AAA/Watch Neg
    AF-5A      126673ZT2     AA+                  AAA/Watch Neg
    AF-5B      126673D25     AA+                  AAA/Watch Neg
    AF-6       126673ZU9     AA+                  AAA/Watch Neg
    MF-1       126673ZV7     BB                   BB/Watch Neg
    MV-1       126673B43     AA+                  AA+/Watch Neg
    MV-2       126673B50     AA                   AA/Watch Neg
    MV-3       126673B68     A                    A/Watch Neg
    MV-4       126673B76     BB                   BB/Watch Neg
    MV-5       126673B84     B                    B/Watch Neg

           CWABS Asset-Backed Certificates Trust 2005-4
                         Series    2005-4

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    AF-3       126673N57     BBB                  AAA/Watch Neg
    AF-4       126673N65     BBB                  AAA/Watch Neg
    AF-5A      126673N73     BBB                  AAA/Watch Neg
    AF-5B      126673N81     BBB                  AAA/Watch Neg
    AF-6       126673N99     BBB                  AAA/Watch Neg
    MF-6       126673P71     CC                   CCC
    MF-7       126673P89     CC                   CCC
    2-AV-1     126673Q39     AAA                  AAA/Watch Neg
    3-AV-3     126673Q62     AAA                  AAA/Watch Neg
    MV-1       126673Q70     AA+                  AA+/Watch Neg
    MV-2       126673Q88     AA                   AA/Watch Neg
    MV-3       126673Q96     BBB                  BBB/Watch Neg
    MV-4       126673R20     B                    B/Watch Neg

          CWABS Asset-Backed Certificates Trust 2005-BC5
                        Series    2005-BC5

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        126670MY1     AAA                  AAA/Watch Neg
    2-A-1      126670MZ8     AA                   AA/Watch Neg
    2-A-2      126670NA2     AA                   AA/Watch Neg
    3-A-2      126670NC8     AAA                  AAA/Watch Neg
    3-A-3      126670ND6     AAA                  AAA/Watch Neg
    M-1        126670NE4     BBB                  BBB/Watch Neg
    M-2        126670NF1     B                    B/Watch Neg

   Deutsche Alt-B Securities Mortgage Loan Trust Series 2006-AB3
                        Series    2006-AB3

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1        25151EAA1     CC                   CCC
    A-2        25151EAB9     CC                   CCC
    A-3        25151EAC7     CC                   CCC
    A-4        25151EAD5     AAA                  AAA/Watch Neg
    A-5A       25151EAE3     AAA                  AAA/Watch Neg
    A-5B       25151EAF0     CC                   CCC
    A-6        25151EAG8     AAA                  AAA/Watch Neg
    A-8        25151EAJ2     CC                   CCC

                 FBR Securitization Trust 2005-1
                         Series    2005-1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1        30246QAA1     AAA                  AAA/Watch Neg
    A-2        30246QAB9     AAA                  AAA/Watch Neg

                   GSAA Home Equity Trust 2006-2
                         Series    2006-2

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1A1        3623415N5     B                    B+/Watch Neg
    1A2        3623415P0     B-                   B-/Watch Neg
    2A2        3623415R6     A-                   AAA/Watch Neg
    2A3        3623415S4     BB+                  AAA/Watch Neg
    2A4        362334AA2     B-                   B-/Watch Neg
    2A5        362334AB0     B-                   B-/Watch Neg
    M-2        3623415U9     CC                   CCC
    M-3        3623415V7     CC                   CCC

                       GSAMP Trust 2005-HE1
                        Series    2005-HE1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    M-1        36242DRW5     AA+                  AA+/Watch Neg
    M-3        36242DRY1     CC                   CCC

             Harborview Mortgage Loan Trust 2005-16
                        Series    2005-16

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        1-A1B      41161PYV9     CC                   CCC
        2-A1C      41161PYY3     CC                   CCC
        3-A1C      41161PZB2     CC                   CCC
        4-A1B      41161PZD8     CC                   CCC
        PO-B       41161PZP1     CC                   CCC

        IndyMac Residential Mortgage-Backed Trust 2005-L1
                         Series    2005-L1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A          456606HF2     BB                   BB/Watch Neg

              IXIS Real Estate Capital Trust 2005-HE3
                        Series    2005-HE3

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-4        45071KBW3     AAA                  AAA/Watch Neg
    M-1        45071KBX1     A                    AA+/Watch Neg
    M-2        45071KBY9     B-                   AA/Watch Neg
    M-3        45071KBZ6     CCC                  BB/Watch Neg
    M-5        45071KCB8     CC                   CCC

             Long Beach Mortgage Loan Trust 2005-WL3
                        Series    2005-WL3

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    I-A2       542514QB3     AAA                  AAA/Watch Neg
    I-A3       542514QC1     AAA                  AAA/Watch Neg
    I-A4       542514QD9     AAA                  AAA/Watch Neg
    II-A2B     542514PP3     AAA                  AAA/Watch Neg
    II-A3      542514PQ1     AAA                  AAA/Watch Neg
    M-1        542514PR9     B-                   B-/Watch Neg
    M-3        542514PT5     CC                   CCC

      Merrill Lynch Mortgage Investors Trust Series 2005-HE3
                        Series    2005-HE3

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1A       59020UY66     BB                   AAA/Watch Neg
    A-1B       59020UX75     CCC                  B-/Watch Neg
    A-2B       59020UX91     A                    A/Watch Neg
    A-2C       59020UY25     CCC                  B-/Watch Neg
    M-1        59020UY74     CC                   CCC

     Merrill Lynch Mortgage Investors Trust Series 2006-WMC1
                       Series    2006-WMC1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1A       59020U4L6     CCC                  B-/Watch Neg
    A-2C       59020U3X1     B-                   B+/Watch Neg
    M-2        59020U4A0     CC                   CCC

         Morgan Stanley ABS Capital I Inc. Trust 2005-WMC3
                        Series    2005-WMC3

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    M-2        61744CPY6     AA                   AA/Watch Neg
    M-3        61744CPZ3     AA-                  AA-/Watch Neg
    M-4        61744CQA7     A+                   A+/Watch Neg
    M-5        61744CQB5     A                    A/Watch Neg
    M-6        61744CQC3     B-                   A-/Watch Neg
    B-1        61744CQD1     CCC                  BBB+/Watch Neg
    B-2        61744CQE9     CC                   B-/Watch Neg

        Morgan Stanley ABS Capital I Inc. Trust 2006-WMC1
                       Series    2006-WMC1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1        61744CXJ0     BB                   BB/Watch Neg
    A-2b       61744CXL5     BBB-                 AAA/Watch Neg
    A-2c       61744CXM3     B-                   B-/Watch Neg
    M-2        61744CXP6     CC                   CCC

         New Century Home Equity Loan Trust Series 2005-A
                        Series    2005-A

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-3        64352VLX7     AAA                  AAA/Watch Neg
    A-4        64352VLY5     BBB                  AAA/Watch Neg
    A-4w       64352VMN8     AAA                  AAA/Watch Neg
    A-5        64352VLZ2     B                    AAA/Watch Neg
    A-5w       64352VMP3     AAA                  AAA/Watch Neg
    A-6        64352VMA6     B                    AAA/Watch Neg

        Nomura Home Equity Loan Inc. Home Equity Loan Trust
                          Series 2006-FM1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    I-A        65536HBT4     BBB-                 BBB-/Watch Neg
    II-A-3     65536HBW7     B-                   B-/Watch Neg
    II-A-4     65536HBX5     B-                   B-/Watch Neg
    M-2        65536HBZ0     CC                   CCC

     Securitized Asset Backed Receivables LLC Trust 2005-HE1
                        Series    2005-HE1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1A       81375WGM2     AAA                  AAA/Watch Neg
    A-1B       81375WGN0     BBB                  AAA/Watch Neg
    A-2        81375WGP5     AAA                  AAA/Watch Neg
    A-3C       81375WGE0     BB                   AAA/Watch Neg

                  Terwin Mortgage Trust 2005-2HE
                         Series    2005-2HE

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        881561PW8     B+                   BB-

                   Terwin Mortgage Trust 2006-1
                         Series    2006-1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    I-A-2      881561L93     AAA                  AAA/Watch Neg
    I-A-3      881561M27     A                    A/Watch Neg

            Terwin Mortgage Trust Series TMTS 2005-16HE
                       Series    2005-16HE

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        AF-3       881561ZB3     CCC                  B-

                         Ratings Affirmed

   Ace Securities Corp. Home Equity Loan Trust Series 2006-ASAP1
                       Series    2006-ASAP1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        004421VX8     CCC
                 M-2        004421VY6     CCC

                Argent Mortgage Loan Trust 2005-W1
                        Series    2005-W1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        040104MX6     CCC
                 A-2        040104MY4     CCC

  Argent Securities Inc. Asset-Backed Pass-Through Certificates
                        Series    2005-W4

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1A2      040104QG9     BB+
                 A-1A3      040104QH7     CCC
                 A-1B       040104QJ3     CCC
                 A-2D       040104PT2     CCC

    Asset Backed Securities Corporation Home Equity Loan Trust
                        Series    2005-HE6

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M6         04541GTQ5     CCC
                 M7         04541GTR3     CCC
                 M8         04541GTS1     CCC

    Asset Backed Securities Corporation Home Equity Loan Trust
                        Series    2005-HE8

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M3         04541GUQ3     CCC
                 M4         04541GUR1     CCC

      Bear Stearns Asset Backed Securities I Trust 2005-HE9
                        Series    2005-HE9

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-2        073879R59     CCC
                 M-3        073879R67     CCC

      Bear Stearns Asset Backed Securities I Trust 2006-AC1
                        Series    2006-AC1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 II-1A-1    07387UCT6     CCC
                 II-1X      07387UCV1     CCC

              Citigroup Mortgage Loan Trust 2006-WMC1
                        Series    2006 WMC1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        17307G2G2     A-
                 A-2D       17307GZ50     B
                 M-1        17307GZ68     CCC

           CWABS Asset Backed Certificates Trust 2005-11
                         Series    2005-11

                 Class      CUSIP         Rating
                 -----      -----         ------
                 MF-1       126670CM8     CCC
                 MF-2       126670CN6     CCC
                 MF-3       126670CP1     CCC
                 MF-4       126670CQ9     CCC
                 MF-5       126670CR7     CCC
                 MV-3       126670DC9     CCC
                 MV-4       126670DD7     CCC
                 MV-5       126670DE5     CCC
                 MV-6       126670DF2     CCC
                 MV-7       126670DG0     CCC

           CWABS Asset Backed Certificates Trust 2005-12
                         Series    2005-12

                 Class      CUSIP         Rating
                 -----      -----         ------
                 1-A-3      126670EA2     AAA
                 1-A-4      126670EB0     AAA
                 1-A-5      126670EC8     AAA
                 1-A-6      126670ED6     AAA
                 2-A-3      126670EG9     AAA
                 2-A-4      126670EH7     AAA
                 2-A-5      126670EJ3     AAA
                 3-A        126670EX2     AAA
                 4-A        126670EY0     AAA
                 M-1        126670EK0     A
                 M-2        126670EL8     BB
                 M-3        126670EM6     B
                 M-4        126670EN4     CCC
                 M-5        126670EP9     CCC
                 M-6        126670EQ7     CCC
                 M-7        126670ER5     CCC

           CWABS Asset Backed Certificates Trust 2005-13
                        Series    2005-13

                 Class      CUSIP         Rating
                 -----      -----         ------
                 AF-3       126670GQ5     CCC
                 AF-4       126670GR3     CCC
                 AF-5       126670GS1     BB+
                 AF-6       126670GT9     CCC
                 MF-1       126670GU6     CCC
                 MF-2       126670GV4     CCC
                 MF-3       126670GW2     CCC
                 2-AV-1     126670HD3     B
                 3-AV-4     126670HH4     B
                 MV-1       126670HJ0     CCC
                 MV-2       126670HK7     CCC
                 MV-3       126670HL5     CCC
                 MV-4       126670HM3     CCC

          CWABS Asset Backed Certificates Trust 2005-16
                         Series    2005-16

                 Class      CUSIP         Rating
                 -----      -----         ------
                 MV-1       126670PH5     CCC
                 MV-2       126670PJ1     CCC
                 MV-3       126670PK8     CCC
                 MV-4       126670PL6     CCC
                 MV-5       126670PM4     CCC
                 1-AF       126670NV6     CCC
                 2-AF-2     126670NX2     CCC
                 2-AF-3     126670NY0     CCC
                 2-AF-4     126670NZ7     CCC
                 2-AF-5     126670PA0     CCC

           CWABS Asset Backed Certificates Trust 2005-7
                         Series    2005-7

                 Class      CUSIP         Rating
                 -----      -----         ------
                 AF-3       126673Y63     AAA
                 MF-2       126673Z39     CCC
                 MF-3       126673Z47     CCC
                 MF-4       126673Z54     CCC
                 MF-5       126673Z62     CCC
                 MF-6       126673Z70     CCC
                 2-AV-1     1266732B7     AAA
                 2-AV-2     1266732C5     AAA
                 3-AV-3     1266732F8     AAA
                 MV-1       1266732G6     AA+
                 MV-2       1266732H4     A
                 MV-3       1266732J0     BBB
                 MV-4       1266732K7     B
                 MV-5       1266732L5     CCC
                 MV-6       1266732M3     CCC
                 MV-7       1266732N1     CCC
                 MV-8       1266732P6     CCC

           CWABS Asset-Backed Certificates Trust 2005-1
                         Series    2005-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 MF-3       126673WG3     CCC
                 MF-4       126673WH1     CCC
                 MF-5       126673WJ7     CCC
                 MF-6       126673WK4     CCC
                 MF-7       126673WL2     CCC
                 MV-6       126673XC1     CCC
                 MV-7       126673XD9     CCC
                 MV-8       126673XE7     CCC

           CWABS Asset-Backed Certificates Trust 2005-15
                        Series    2005-15

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-2        126670MJ4     CCC
                 M-3        126670MK1     CCC
                 M-4        126670ML9     CCC
                 M-5        126670MM7     CCC
                 M-6        126670MN5     CCC
                 M-7        126670MP0     CCC
                 M-8        126670MQ8     CCC

           CWABS Asset-Backed Certificates Trust 2005-17
                        Series    2005-17

                 Class      CUSIP         Rating
                 -----      -----         ------
                 2-AV       126670QX9     CCC
                 3-AV-1     126670QY7     BB
                 4-AV-2A    126670RB6     B
                 4-AV-2B    126670SK5     B
                 4-AV-3     126670RC4     CCC
                 MV-1       126670RD2     CCC
                 MV-2       126670RE0     CCC
                 MV-3       126670RF7     CCC
                 3-AV-2     126670QZ4     CCC

           CWABS Asset-Backed Certificates Trust 2005-3
                         Series    2005-3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 MF-2       126673ZW5     CCC
                 MF-3       126673ZX3     CCC
                 MF-4       126673ZY1     CCC
                 MF-5       126673ZZ8     CCC
                 MF-6       126673A28     CCC
                 MV-6       126673B92     CCC
                 MV-7       126673C26     CCC
                 MV-8       126673C34     CCC

           CWABS Asset-Backed Certificates Trust 2005-4
                         Series    2005-4

                 Class      CUSIP         Rating
                 -----      -----         ------
                 MF-1       126673P22     CCC
                 MF-2       126673P30     CCC
                 MF-3       126673P48     CCC
                 MF-4       126673P55     CCC
                 MF-5       126673P63     CCC
                 MV-5       126673R38     CCC
                 MV-6       126673R46     CCC
                 MV-7       126673R53     CCC
                 MV-8       126673R61     CCC

          CWABS Asset-Backed Certificates Trust 2005-BC5
                        Series    2005-BC5

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-3        126670NG9     CCC
                 M-4        126670NH7     CCC
                 M-5        126670NJ3     CCC
                 M-6        126670NK0     CCC

                  GSAA Home Equity Trust 2006-2
                         Series    2006-2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        3623415T2     CCC

                       GSAMP Trust 2005-HE1
                        Series    2005-HE1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-2        36242DRX3     CCC

              Harborview Mortgage Loan Trust 2005-16
                         Series    2005-16

                 Class      CUSIP         Rating
                 -----      -----         ------
                 1-A1A      41161PA52     CCC
                 2-A1A      41161PYW7     CCC
                 2-A1B      41161PYX5     CCC
                 3-A1A      41161PYZ0     CCC
                 3-A1B      41161PZA4     CCC
                 4-A1A      41161PZC0     CCC
                 X-1        41161PZE6     CCC
                 X-2        41161PZF3     CCC
                 X-3        41161PZG1     CCC
                 X-4        41161PZH9     CCC
                 PO-1       41161PZK2     CCC
                 PO-2       41161PZL0     CCC
                 PO-3       41161PZM8     CCC
                 PO-4       41161PZN6     CCC

              IXIS Real Estate Capital Trust 2005-HE3
                        Series    2005-HE3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-4        45071KCA0     CCC

              Long Beach Mortgage Loan Trust 2005-WL3
                        Series    2005-WL3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-2        542514PS7     CCC

      Merrill Lynch Mortgage Investors Trust Series 2006-WMC1
                       Series    2006-WMC1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1B       59020U4M4     CCC
                 A-2D       59020U3Y9     CCC
                 M-1        59020U3Z6     CCC

        Morgan Stanley ABS Capital I Inc. Trust 2006-WMC1
                       Series    2006-WMC1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        61744CXN1     CCC

         New Century Home Equity Loan Trust Series 2005-A
                         Series    2005-A

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        64352VMB4     CCC
                 M-2        64352VMC2     CCC

       Nomura Home Equity Loan Inc. Home Equity Loan Trust
                        Series    2006-FM1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        65536HBY3     CCC

     Securitized Asset Backed Receivables LLC Trust 2005-FR5
                        Series    2005-FR5

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1A       81375WFQ4     AAA
                 A-1B       81375WFR2     AAA
                 A-2B       81375WFT8     AAA
                 M-1        81375WFU5     CCC
                 M-2        81375WFV3     CCC

     Securitized Asset Backed Receivables LLC Trust 2005-HE1
                        Series    2005-HE1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        81375WGF7     CCC

          Structured Asset Investment Loan Trust 2005-5
                         Series    2005-5

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A1         86358ESW7     AAA
                 A3         86358ESY3     AAA
                 A4         86358ESZ0     AAA
                 A5         86358ETA4     AAA
                 A8         86358ETD8     AAA
                 A9         86358ETE6     AAA
                 M1         86358ETF3     AA+
                 M2         86358ETG1     AA
                 M3         86358ETH9     BBB-
                 M4         86358ETJ5     B-
                 M5         86358ETK2     CCC

                 Terwin Mortgage Trust 2005-2HE
                        Series    2005-2HE

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        881561PU2     AAA
                 S          881561PV0     AAA

                  Terwin Mortgage Trust 2006-1
                         Series    2006-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 I-M-1      881561M35     CCC
                 I-M-2      881561M43     CCC
                 II-A-1a    881561H80     CCC

            Terwin Mortgage Trust Series TMTS 2005-16HE
                       Series    2005-16HE

                 Class      CUSIP         Rating
                 -----      -----         ------
                 AF-2       881561ZA5     AAA
                 AF-4       881561ZC1     AAA
                 AF-5       881561ZD9     AAA
                 AV-2       881561ZF4     B-
                 AV-3       881561ZG2     CCC


* S&P Downgrades Ratings on 473 Classes of Certificates to 'D'
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D' on
473 classes of mortgage pass-through certificates from 396 U.S.
residential mortgage-backed securities transactions backed by a
variety of collateral types.  S&P removed one of the lowered
ratings from CreditWatch with negative implications.  In addition,
S&P placed four other ratings from RAMP Series 2003-RZ5 Trust on
CreditWatch with negative implications.  The ratings on 91
additional classes from two of the downgraded transactions remain
on CreditWatch with negative implications.

Approximately 82.66% of the defaulted classes were from
transactions backed by Alternative-A or subprime mortgage loan
collateral.  The 473 defaulted classes consisted of these:

* 283 classes were from Alt-A transactions (59.83% of all
  defaults);

* 108 were from subprime transactions (22.83% of all defaults);

* 64 were from prime jumbo transactions;

* Six were from reperforming transactions;

* Three were from first-lien high loan-to-value transactions;

* Two were from closed-end second-lien transactions;

* Two were from document-deficient transactions;

* Two were from re-REMIC transactions;

* One was from a home equity line of credit transaction;

* One was from an outside-the-guidelines transaction; and

* One was from a risk-transfer transaction.

The 473 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
99.58% of the ratings from the 'CCC' or 'CC' rating categories,
and S&P lowered 100% from a speculative-grade category.

S&P expects to resolve its CreditWatch placements affecting these
transactions after S&P complete 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 deem appropriate.



                           *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers'
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Wednesday's edition of the TCR. Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com/

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

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

For copies of court documents filed in the District of Delaware,
please contact Vito at Parcels, Inc., at 302-658-9911.  For
bankruptcy documents filed in cases pending outside the District
of Delaware, contact Ken Troubh at Nationwide Research &
Consulting at 207/791-2852.

                           *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors' Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Frederick, Maryland,
USA.  Marites Claro, Joy Agravante, Rousel Elaine Tumanda, Howard
C. Tolentino, Joseph Medel C. Martirez, Denise Marie Varquez,
Philline Reluya, Ronald C. Sy, Joel Anthony G. Lopez, Cecil R.
Villacampa, Sheryl Joy P. Olano, Carlo Fernandez, Christopher G.
Patalinghug, and Peter A. Chapman, Editors.

Copyright 2010.  All rights reserved.  ISSN: 1520-9474.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.  Information contained
herein is obtained from sources believed to be reliable, but is
not guaranteed.

The TCR subscription rate is $775 for 6 months delivered via e-
mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Christopher
Beard at 240/629-3300.

                  *** End of Transmission ***