TCR_Public/100801.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, August 1, 2010, Vol. 14, No. 211

                            Headlines

ABS CAPITAL: Moody's Downgrades Ratings on Two Classes of Notes
ALADDIN SYNTHETIC: S&P Downgrades Ratings on Notes to 'D'
AMRESCO-IFC SBA: Fitch Takes Rating Actions on Various Loan
ASSET SECURITIZATION: Fitch Affirms Ratings on Various Certs.
BALTIMORE MAYOR: S&P Affirms 'BB+' Rating on City Bonds

BANC OF AMERICA: S&P Downgrades Ratings on 10 Pooled Classes
BANC OF AMERICA: S&P Downgrades Ratings on 12 2002-PB2 Certs.
BEAR STEARNS: Fitch Affirms Ratings on 2004-BBA3 Certificates
BROOKLYN NAVY: Fitch Downgrades Ratings on Bonds to 'B+'
CALIFORNIA STATEWIDE: S&P Downgrades Ratings on 2002D-1 Bonds

CAPITAL ONE: Moody's Reviews Ratings on 47 Classes of Securities
CBA COMMERCIAL: S&P Downgrades Ratings on 2007-1 Certs. to 'D'
COLISEUM SPC: S&P Downgrades Ratings on 2007-1 Notes to 'D'
COMM 2004-RS1: Fitch Takes Rating Actions on Various Classes
COMM 2004-RS1: S&P Downgrades Ratings on Six Classes of Notes

COMM 2006-CNL2: Fitch Downgrades Ratings on 13 Classes of Certs.
COMM MORTGAGE: Fitch Upgrades Ratings on 2005-FL10 Certificates
COMSTOCK FUNDING: Moody's Upgrades Ratings on Various Classes
CWABS ASSET-BACKED: Moody's Downgrades Ratings on 15 Tranches
DEUTSCHE ALT-A: S&P Corrects Rating on class II-A-1 to 'CC'

DLJ 1999-CG2: Fitch Upgrades Ratings on Class B-3 Notes
DLJ COMMERCIAL: Fitch Downgrades Ratings on 2000-CKP1 Certs.
EATON VANCE: Moody's Downgrades Ratings on Class A to 'Ca'
EQUUS CAPITAL: S&P Downgrades Rating on Class B Notes to 'D'
FAIRFAX FINANCIAL: Fitch Assigns 'BB' Rating on Series G Shares

FORD AUTO: Moody's Assigns Rating on Series 2010-L2 Fixed Notes
FORT POINT: Fitch Downgrades Ratings on Five Classes of Notes
FORT POINT: S&P Downgrades Rating on Five Classes to 'D'
GALAXY CLO: Moody's Upgrades Ratings on Various Classes of Notes
INDYMAC INDX: Moody's Junks Rating on Class A2-B Notes From 'B1'

JP MORGAN: Fitch Affirms Ratings on Various 2000-C10 Certs.
JP MORGAN: Fitch Downgrades Ratings on 2001-CIBC1 Certificates
KEYCORP STUDENT: Moody's Reviews Ratings on 18 Classes of Notes
L2L EDUCATION: S&P Puts Note Ratings on CreditWatch Negative
LB COMMERCIAL: Fitch Affirms 'D/RR2' Rating on Certificates

LB COMMERCIAL: Fitch Downgrades Ratings on 1998-C1 Certs.
LIBERTY SQUARE: Moody's Upgrades Ratings on Various Notes
LONE STAR: Moody's Upgrades Class B Notes to 'Ba1' from 'Ba3'
MANUFACTURED HOUSING: S&P Corrects Ratings on Three Certs. to 'D'
MERRILL LYNCH: Fitch Downgrades Ratings on 1998-C1-CTL Certs.

MINT 2005-1: DBRS Confirms Series B & C Notes at 'C'
MORGAN STANLEY: Fitch Affirms Ratings on 1998-HF2 Certificates
MORGAN STANLEY: Fitch Downgrades Ratings on 18 2005-RR6 Notes
MORGAN STANLEY: Fitch Upgrades Ratings on 1999-CAM1 Certs.
MORGAN STANLEY: S&P Downgrades Ratings on Various Notes to 'CC'

NATIONAL COLLEGIATE: Fitch Maintains Negative Watch on Ratings
PENNSYLVANIA: Moody's Assigns 'Caa3' Rating on Bonds
PRIMUS CLO: Moody's Upgrades Ratings on Class D Notes to 'Caa3'
PRIMUS CLO: Moody's Upgrades Ratings on Various Classes of Notes
RACE POINT: Moody's Raises Ratings on Various Classes of Notes

RFSC SERIES: Moody's Downgrades Ratings on Series 2002-RM1 Tranche
SALOMON BROS: S&P Downgrades Ratings on Seven 2000-C1 Notes
SANTANDER CONSUMER: Moody's Upgrades Ratings on Four Tranches
SLATE CDO: Fitch Downgrades Ratings on Five Classes of Certs.
STRUCTURED INVESTMENTS: S&P Downgrades Ratings on Notes to 'CC'

TRIAXX FUNDING: Moody's Withdraws Ratings on Various Classes
WEST NEW YORK: S&P Keeps BB Ratings on General Obligation Bonds

* Fitch Takes Various Rating Actions From 12 SF CDO Transactions
* Moody's Affirms 'Ba2' Rating on Housing & Redevelopment Bonds
* Moody's Downgrades Ratings on 10 Tranches From Six US SF CDOs
* S&P Affirms Ratings on 54 Certs. From Seven Re-Remic Deals
* S&P Assigns 'CCC+' Rating on Pennsylvania's Revenue Bonds

* S&P Downgrades Ratings on 27 Notes From Four Hybrid CDOs to 'D'
* S&P Downgrades Ratings on 35 Classes of Certificates
* S&P Downgrades Ratings on 60 Tranches From 18 Preferred CDOs
* S&P Downgrades Ratings on Six Certificates From Six RMBS Deals
* S&P Takes Various Rating Actions on 116 Classes From 44 Deals

                            *********

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

  -- $225,000,000 Class A-1 Floating Rate Term Notes, Due 2037,
     Downgraded to Ca; previously on 2/4/2009 Downgraded to Caa3;

  -- $20,000,000 Class A-2 Floating Rate Term Notes, Due 2037,
     Downgraded to Caa3; previously on 11/2/2009 Downgraded to
     Caa1.

ABS Capital Funding II, Ltd., is a collateralized debt obligation
issuance backed by a portfolio of primarily Residential Mortgage-
Backed Securities originated between 2001 and 2004.

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 the number of assets that are currently on
review for possible downgrade and failure of the coverage tests.
In April, approximately $27 million of pre-2005 RMBS within the
underlying portfolio were placed on review for possible downgrade
as a result of Moody's updated loss projections.  In addition, the
Trustee reports that the transaction is currently failing its
Class A/B principal and interest coverage tests.

Moody's explained that in arriving at the rating action noted
above, the ratings of 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
pre-2005 vintage RMBS, Moody's considered the various factors
indicating continued negative performance that were described in
Moody's press releases dated April 8th for subprime, April 12 for
Option-ARM and April 13 for Alt-A.  Such seasoned deals will have
varying stress based on RMBS asset type.

For pre-2005 Alt-A, Aaa rated securities were stressed by four
notches, Aa rated securities by six notches, and A or Baa rated
securities by nine notches.  Pre-2005 Option-ARM securities
currently rated Aaa were stressed by two notches, Aa and A by six
notches, and Baa by nine notches.

For pre-2005 subprime, Aaa and Aa rated securities were stressed
by two notches, A rated securities were stressed by six notches,
and Baa rated securities were stressed by nine notches.

All subprime, Alt-A and Option-ARM RMBS securities which
originated prior to 2005, are currently rated Ba or below, and are
also currently on review for possible downgrade have been stressed
to Ca.

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 that are no longer on review for downgrade.

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


ALADDIN SYNTHETIC: S&P Downgrades Ratings on Notes to 'D'
---------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on series
A-2, B-1, and C-1 from Aladdin Synthetic CDO II SPC, a synthetic
collateralized debt obligation transaction, to 'D' from 'CC' due
to principal losses on the notes.

The downgrades follow a number of credit events within the
underlying portfolios, which have reduced the notional amounts on
the affected tranches to zero.

                         Ratings Lowered

                   Aladdin Synthetic CDO II SPC

                                Rating
                                ------
                   Series     To       From
                   ------     --       ----
                   A-2        D        CC
                   B-1        D        CC
                   C-1        D        CC


AMRESCO-IFC SBA: Fitch Takes Rating Actions on Various Loan
-----------------------------------------------------------
Fitch Ratings takes these rating actions on Amresco-IFC SBA loan
backed adjustable rate certificates and assigns Rating Outlooks as
indicated:

AMRESCO-IFC SBA Loan-Backed Adjustable Rate Certificates:

Series 1999-1

  -- Class A affirmed at 'AAA'; Outlook Stable;
  -- Class M at affirmed at 'A'; Outlook Stable.

Series 2000-1

  -- Class A downgraded to 'A' from 'AAA'; Outlook Stable;
  -- Class M downgraded to 'BB+' from 'BBB+'; Outlook Stable.

The downgrades in the 2000-1 series reflect continued
deterioration in performance since Fitch's last review.  As of the
July 2010 reporting period, total delinquencies currently
represent 14.82% and cumulative net losses total 14.22%.
Furthermore, based on Fitch's analysis detailed below, loss
coverage was found to be limited due to the asset deterioration.
Additionally, large obligor concentrations within the transaction
may have a more pronounced negative impact on loss coverage should
additional obligors default.

The affirmations for the 1999-1 series reflect relatively stable
performance within the transaction.  Although losses have
increased since Fitch's last review, currently totaling 9.64%, the
transaction has experienced a decline in delinquency roll rates.
Total delinquencies currently represent 0.16% of the pool.  Based
on Fitch's analysis, detailed below, credit support remains
sufficient at current rating levels.

The Stable Rating Outlook designation for all applicable notes
reflects Fitch's view that ratings are not expected to change
within the next 12 months, based on current performance.

In reviewing the transactions, Fitch took into account analytical
considerations outlined in Fitch's 'Global Structured Finance
Rating Criteria', issued Sept. 30, 2009, including asset quality,
credit enhancement, financial structure, legal structure, and
originator and servicer quality.

Fitch's analysis incorporated a review of collateral
characteristics, in particular, focusing on delinquent and
defaulted loans within the pool.  All loans over 60 days
delinquent were deemed defaulted loans.  The defaulted loans were
applied loss and recovery expectations based on collateral type
and historical recovery performance to establish an expected net
loss assumption for the transaction.  Fitch stressed the cash
flows generated by the underlying assets by applying its expected
net loss assumption.  Furthermore, Fitch applied a loss multiplier
to evaluate break-even cash flow runs to determine the level of
expected cumulative losses the structure can withstand at a given
rating level.  The loss multiplier scale utilized is consistent
with that of other commercial asset backed security (ABS)
transactions.

Additionally, to review possible concentration risks within the
pool, Fitch evaluated the impact of the default of the largest
performing obligors.  Similar to the analysis detailed above,
Fitch applied loss and recovery expectations to the performing
obligors based on collateral type and historical recovery
performance.  The expected loss assumption was then compared to
the credit support available to the outstanding notes given
Fitch's expected losses on the currently defaulted loans.
Consistent with the obligor approach detailed in 'Rating US
Equipment Lease and Loan Securitizations', dated June 16, 2008,
Fitch applied losses from the largest performing obligors
commensurate with the individual rating category.  The number of
obligors ranges from 5-6 at 'AAA' to 1.5 at 'BB'.

Fitch will continue to closely monitor these transactions and may
take additional rating action in the event of changes in
performance and credit enhancement measures.


ASSET SECURITIZATION: Fitch Affirms Ratings on Various Certs.
-------------------------------------------------------------
Fitch Ratings affirms Asset Securitization Corp, series 1997-D5,
and assigns Loss Severity ratings and Rating Outlooks as
indicated:

  -- $16.9 million class A-1D at 'AAA/LS1'; Outlook Stable;
  -- $52.6 million class A-1E at 'AAA/LS1'; Outlook Stable;
  -- $87.7 million class A-2 at 'AAA/LS3'; Outlook Stable;
  -- $52.6 million class A-3 at 'AAA/LS3'; Outlook Stable;
  -- $26.3 million class A-4 at 'AAA/LS3'; Outlook Stable;
  -- $39.5 million class A-5 at 'AA/LS3'; Outlook Stable;
  -- $43.9 million class A-6 at 'BBB+/LS3'; Outlook Stable;
  -- $21.9 million class A-7 at 'BB+/LS3'; Outlook Negative;
  -- $39.5 million class B-1 at 'B/LS3'; Outlook Negative.

In addition, Fitch affirms this class and revises the Recovery
Rating as indicated:

  -- $9.9 million class B-2 at 'D/RR5'.

Fitch withdraws the rating of the interest-only class PS-1.

Ratings on classes B-3, B-4, B-5, and B-6 are withdrawn.  Classes
A-1A, A-1B, A-1C, and A-CS1 are paid in full.  Fitch does not rate
classes B-7, B-7H, or A-8Z.

The rating actions are due to Fitch expected losses (1.2% of the
current 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 44 of the original 162 loans remaining in transaction,
21 of which have defeased (28.6% of the current transaction
balance).  There are three specially serviced loans in the pool.

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.  Six loans did not pay off at maturity and two loans
incurred a loss when compared to Fitch's stressed value.


BALTIMORE MAYOR: S&P Affirms 'BB+' Rating on City Bonds
-------------------------------------------------------
Standard & Poor's Ratings Services said it affirmed its 'BB+'
rating on the Baltimore Mayor and City Council, Md.'s
$298.97 million convention center hotel senior revenue series
2006A bonds At the same time, S&P affirmed its 'BB' rating on the
$53.44 million convention center hotel subordinate revenue series
2006B bonds.  S&P also assigned a '3' recovery rating to the 2006
series A debt, reflecting expectations of meaningful recovery
(50%-70%) if a payment default occurs, and S&P's '6' recovery
rating to the 2006 B series debt, indicating negligible recovery
(0%-10%).  S&P is retaining the stable outlook on Series 2006A and
the negative outlook on series 2006B.

The City of Baltimore issued both series for the Baltimore Hotel
Corp. Bond proceeds funded the hotel's construction, which reached
a substantial completion date on Aug. 9, 2008, and opened to the
public on Aug. 22, 2008.

The hotel's net revenues and city revenues secure the bonds.  The
city revenues include a $7 million annual guarantee funded through
a second lien on the citywide hotel occupancy tax revenue.  It
also includes a pledge of site-specific hotel occupancy tax
revenue, which will vary based on the project's occupancy levels
and the tax increment payment, which is equal to the hotel's
property tax payment.

These credit concerns limit the ratings:

* Exposure to the cyclical and competitive conference center and
  lodging market, particularly in competitive downtown Baltimore.
  Revenue per available room of the competitive set declined 17%
  in 2009 over 2008 but is beginning to rebound, with RevPAR over
  the past three months up 11.2% through June 2010.  While the
  project has a slight premium to the market, its performance is
  well below the initial forecasts.

* Uncertainties about the operational and financial performance of
  a start-up hotel.  These include the project's ability to meet
  expectations during the critical ramp-up period before the hotel
  reaches stabilization and debt service payments increase by 12%
  in 2012 as principal repayment begins.

* The need for the Baltimore Convention Center to continue to
  attract events and maintain or increase attendance has grown
  little since the center expanded in 1998.

* The long, 30-year bond term exposes lenders to increasing
  competition and the facility's deteriorating physical condition.

The ratings also reflect these credit strengths:

* The hotel's location in downtown Baltimore's Inner Harbor area.

  The project enjoys the advantage of serving as the convention
  center headquarters hotel, which should allow it to achieve
  market occupancy levels as long as the convention center can
  continue to attract events.

* Support from the city.  The $7 million annual guarantee of the
  citywide hotel occupancy tax revenue represents about 25% of
  maximum annual senior and subordinate debt service.  A
  dditionally, under an aggressive base case, the site-specific
  hotel revenues represent about 23% of annual debt service.

* Hotel management by Hilton Hotels Corp. brings considerable
  experience and a strong marketing program and reservation
  system.  Hilton has also contributed a $25 million senior debt-
  service guarantee, which is available during the ramp-up period.

S&P bases the stable outlook on the 2006A series bonds on the
hotel's continued operational improvements during ramp-up, a
slight rebound in the Baltimore market and cash flow stability
provided by the first lien on nonproject revenues.  S&P could
lower the rating on the series 2006B bonds, which have a negative
outlook, if the coverage levels for all project debt remains below
1.4x for more than two years as a result of a prolonged economic
slowdown, or other competitive factors that reduce net hotel
revenues, especially in 2012 when annual debt service obligations
grow.  S&P could revise the outlook to stable if the current
market trends prove to be sustainable, resulting in a predictable
operating and financial performance whereby debt service coverage
levels of all debt are more than 1.6x.


BANC OF AMERICA: S&P Downgrades Ratings on 10 Pooled Classes
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 10
pooled classes of commercial mortgage-backed securities from Banc
of America Commercial Mortgage Inc.'s series 2004-3 and removed
them from CreditWatch with negative implications.  S&P lowered two
of these ratings to 'D'.  Concurrently, S&P affirmed its ratings
on seven other pooled classes from the same transaction and
removed one of them from CreditWatch negative.  In addition, S&P
raised six ratings and affirmed three ratings on the class "UH"
raked certificates.  S&P also affirmed three ratings on the class
"SS" raked certificates.

The downgrades and affirmations of the pooled certificates follow
S&P's analysis of the transaction using its U.S. conduit and
fusion CMBS criteria.  The negative actions on the subordinate
classes also reflect credit support erosion that S&P anticipate
will occur upon the eventual resolution of several specially
serviced loans, as well as concerns about the susceptibility of
those classes to interest shortfalls.  Current interest
shortfalls, primarily due to appraisal subordinate entitlement
reductions and special servicing fees, prompted us to lower S&P's
ratings on classes N and O to 'D'.  S&P expects these interest
shortfalls to continue for the foreseeable future.

S&P's analysis included a review of the credit characteristics of
all of the loans in the transaction.  Using servicer-provided
financial information, Standard & Poor's calculated an adjusted
debt service coverage of 1.67x and a loan-to-value ratio of 73.6%
in the pool.  S&P further stressed the loans' cash flows under
S&P's 'AAA' scenario to yield a weighted average DSC of 1.17x and
an LTV of 87.2%.  The implied defaults and loss severity under the
'AAA' scenario were 31.2% and 26.5%, respectively.  All of the
adjusted DSC and LTV calculations excluded four of the six
specially serviced assets ($48.7 million, 5.1%) and seven defeased
loans ($46.0 million, 4.8%).  S&P separately estimated losses for
the specially serviced assets, which S&P included in its 'AAA'
scenario implied default and loss figures.

The upgrades and affirmations of the nonpooled class "UH"
certificates reflect S&P's analysis of the U-Haul Portfolio loan,
which is the sole source of cash flow for the class "UH"
certificates.  The affirmations on the nonpooled class "SS"
certificates reflect S&P's analysis of the 17 State Street loan,
which is the sole source of cash flow for the class "SS"
certificates.  S&P discusses both of these loans in detail below.

S&P affirmed its rating on the class X interest-only certificates
based on its current criteria.

                      Credit Considerations

Six assets ($135.0 million, 14.2%), including the second- and
eighth-largest loans in the pool, are with the special servicer,
Midland Loan Services Inc. (Midland).  Two of these assets
($41.7 million, 4.4%) are in foreclosure, two ($7.0 million, 0.7%)
are more than 90 days delinquent, and two ($96.3 million, 10.1%)
are within their respective grace periods.  S&P estimated losses
ranging from 30.0% to 71.3% for four ($48.7 million, 5.1%) of the
six assets.  Appraisal reduction amounts are in effect against
three of the specially serviced assets totaling $30.6 million.

The 17 State Street loan is the largest loan with the special
servicer and the second-largest loan in the pool, and is secured
by a 531,521-sq.-ft.  office building in downtown Manhattan.  The
whole loan has an outstanding principal balance of $104.8 million,
which consists of a $71.0 million pooled senior A note, a
$12.8 million nonpooled junior A note, and a $21.0 million B note,
which is held outside the trust.  The "SS" raked certificates
derive 100% of their cash flows from the $12.8 million nonpooled
junior A note portion of this loan.  The loan was transferred to
Midland on June 29, 2010, due to imminent default.  It is S&P's
understanding that the B note portion of the 17 State Street loan
will absorb any fees incurred in connection with the loan's
transfer to the special servicer.  As of Dec. 31, 2009, the A note
DSC for the property was 2.82x, and the whole-loan DSC for the
property was 1.75x.  Based on S&P's current valuation using an
adjusted net cash flow, its adjusted whole loan-to-value ratio is
64.0%.  Occupancy was 94.3% as of March 31, 2010.  This loan was
recently transferred to the special servicer, who has indicated
that it is still developing a workout strategy.  S&P based its
affirmations of the "SS" certificates on its analysis of the loan.
S&P will reevaluate the analysis if the terms of the loan change
due to a modification.

The St. Clair Estates Manufactured Home Community loan ($25.3
million, 2.6%) is the second-largest loan with the special
servicer and the eighth-largest loan in the pool.  The loan is
secured by a 628-pad mobile home park in Clinton Township, Mich.,
and was transferred to Midland on May 1, 2009, due to payment
default.  An ARA of $22.4 million is currently in effect for this
loan.  The loan is currently in foreclosure and a court-appointed
receiver is in place.  Midland expects that the property will be
sold in the third quarter of 2010.  Standard & Poor's anticipates
a significant loss upon the eventual resolution of this asset.

The four remaining specially serviced loans ($38.7 million,
4.1%) have balances that individually represent less than 1.7%
of the total pool balance.  S&P estimated losses for three
($23.4 million, 2.5%) of these four loans, with a weighted
average loss severity of 42.3%.  The fourth loan was a recent
transfer due to its pending maturity in August 2010.  The property
is 74% occupied as of March 2010 and the reported DSC was 1.25x as
of year-end 2009.

                       Transaction Summary

As of the July 2010 remittance report, the aggregate pooled trust
balance was $872.8 million, which represents 81.7% of the
aggregate pooled trust balance at issuance.  There are 78 assets
in the pool, down from 94 at issuance.  The master servicer for
the transaction, Bank of America N.A., provided financial
information for 99.4% of the pool, and 100.0% of the servicer-
provided information was full-year 2008 or interim-2009 data.

S&P calculated a weighted average DSC of 1.74x for the pool based
on the reported figures.  S&P's adjusted DSC and LTV were 1.67x
and 73.6%, respectively, which exclude four specially serviced
assets ($48.7 million, 5.1%) for which S&P has estimated losses
separately.  Based on the servicer-reported DSC figures, S&P
calculated a weighted average DSC of 0.79x for three of these four
loans.  The master servicer did not report financial information
for the remaining loan.  Seventeen loans ($100.2 million, 10.5%)
are on the master servicer's watchlist.  Thirteen loans
($109.0 million, 11.5%) have a reported DSC of less than 1.10x,
and 10 of these loans ($66.6 million, 7.0%) have a reported DSC of
less than 1.0x.  Seven loans ($46.0 million, 4.8%) have been
defeased.  To date, the transaction has realized one principal
loss totaling $57,909.

                     Summary of Top 10 Loans

The top 10 exposures secured by real estate have an aggregate
outstanding pooled balance of $397.5 million (50.0%).  Using
servicer-reported numbers, S&P calculated a weighted average
DSC of 1.98x for the top 10 loans.  S&P's adjusted DSC and LTV
for the top 10 loans were 1.83x and 63.4%, respectively.  Two
($96.3 million pooled loan balance, 10.1%) of the top 10 exposures
are currently with the special servicer (S&P discussed these two
loans in the Credit Considerations section above), and none of the
top 10 loans appear on the master servicer's watchlist.

The U-Haul Portfolio loan is the largest loan in the pool with
a whole-loan balance of $161.9 million, which consists of a
$97.1 million senior pooled balance, and a $64.8 million
subordinate, nonpooled balance.  The raised and affirmed ratings
on the "UH" raked certificates reflect S&P's analysis of the U-
Haul Portfolio junior nonpooled portion of the loan, from which
the raked certificates derive 100% of their cash flows.  The loan
is secured by a 78-property, 44,931-unit self-storage portfolio
located throughout the country.  As of the nine months ended
Sept. 30, 2009, the portfolio had a DSC of 2.24x and was 82.0%
occupied.  The upgrades and affirmations of the "UH" certificates
reflect this performance, as well as significant deleveraging that
has occurred on the loan.  Since issuance, the loan has paid down
by 11.3%.  Based on S&P's current valuation using an adjusted net
cash flow, its adjusted LTV ratio on the whole loan is 56.6%.

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

      Ratings Lowered And Removed From Creditwatch Negative
                       (Pooled Certificates)

             Banc of America Commercial Mortgage Inc.
       Commercial mortgage pass-through certificates 2004-3

                 Rating
                 ------
    Class  To              From          Credit enhancement (%)
    -----  --              ----          ----------------------
    E      BBB+            A-/Watch Neg                   10.09
    F      BBB-            BBB+/Watch Neg                  8.27
    G      BB              BBB/Watch Neg                   6.94
    H      B+              BBB-/Watch Neg                  5.12
    J      B-              BB+/Watch Neg                   4.63
    K      CCC+            BB/Watch Neg                    3.96
    L      CCC-            BB-/Watch Neg                   3.30
    M      CCC-            B+/Watch Neg                    2.81
    N      D               B/Watch Neg                     2.48
    O      D               B-/Watch Neg                    2.14

      Rating Affirmed And Removed From Creditwatch Negative
                       (Pooled Certificate)

             Banc of America Commercial Mortgage Inc.
       Commercial mortgage pass-through certificates 2004-3

                 Rating
                 ------
    Class  To              From          Credit enhancement (%)
    -----  --              ----          ----------------------
    D      A               A/Watch Neg                    11.41

              Ratings Affirmed (Pooled Certificates)

             Banc of America Commercial Mortgage Inc.
       Commercial mortgage pass-through certificates 2004-3

           Class  Rating        Credit enhancement (%)
           -----  ------        ----------------------
           A-4    AAA                            18.85
           A-5    AAA                            18.85
           A-1A   AAA                            18.85
           B      AA+                            15.55
           C      AA                             14.22
           X      AAA                              N/A

              Ratings Raised (Nonpooled Certificates)

             Banc of America Commercial Mortgage Inc.
       Commercial mortgage pass-through certificates 2004-3

                                 Rating
                                 ------
                     Class     To      From
                     -----     --      ----
                     UH-D      AAA     AA+
                     UH-E      AAA     AA
                     UH-F      AA+     AA-
                     UF-G      AA-     A
                     UH-H      A       A-
                     UH-J      BBB+    BBB

             Ratings Affirmed (Nonpooled Certificates)

             Banc of America Commercial Mortgage Inc.
       Commercial mortgage pass-through certificates 2004-3

                        Class     Rating
                        -----     ------
                        UH-A      AAA
                        UH-B      AAA
                        UH-C      AAA
                        SS-B      BBB+
                        SS-C      BBB
                        SS-D      BBB-

                       N/A - Not applicable.


BANC OF AMERICA: S&P Downgrades Ratings on 12 2002-PB2 Certs.
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 12
classes of commercial mortgage-backed securities from Banc of
America Commercial Mortgage Inc.'s series 2002-PB2 and removed
seven of them from CreditWatch with negative implications.  In
addition, S&P affirmed S&P's ratings on four other classes from
the same transaction.

The downgrades follow S&P's analysis of the transaction using its
U.S. conduit and fusion CMBS criteria.  The lowered ratings on the
mezzanine and subordinate classes also reflect anticipated credit
support erosion upon the eventual resolution of eight specially
serviced loans.  S&P's analysis included a review of the credit
characteristics of all of the loans in the pool.  Using servicer-
provided financial information, S&P calculated an adjusted debt
service coverage of 1.16x and a loan-to-value ratio of 109.1%.
S&P further stressed the loans' cash flows under S&P's 'AAA'
scenario to yield a weighted average DSC of 0.85x and an LTV ratio
of 122.9%.  The implied defaults and loss severity under the 'AAA'
scenario were 37.1% and 49.3%, respectively.  The DSC and LTV
calculations S&P noted above exclude eight ($72.3 million; 9.3%)
of the 10 specially serviced assets, and 20 ($167.9 million;
21.7%) defeased loans.  S&P separately estimated losses for the
eight specially serviced assets, which S&P included in S&P's 'AAA'
scenario implied default and loss severity figures.

The affirmations of S&P's ratings on the principal and interest
certificates reflect subordination levels that are consistent with
the outstanding ratings.  S&P affirmed its ratings on the class X-
C interest-only certificates based on its current criteria.

                      Credit Considerations

As of the July 12, 2010, remittance report, nine assets
($99.5 million; 12.9%) in the pool were with the special servicer,
LNR Partners Inc.  Following the remittance date, one additional
asset ($5.5 million; 0.7%) was transferred to LNR.  Six of the
assets are 90-plus-days delinquent ($38.0 million; 4.9%), one is
60 days delinquent ($5.5 million; 0.7%), two are less than 30 days
delinquent ($53.2 million; 6.9%), and one is late but within its
grace period ($8.3 million; 1.1%).  Five of the specially serviced
assets have appraisal reduction amounts in effect totaling
$7.9 million.  The three largest loans with the special servicer
are top 10 loans, and S&P discuss those below.

The 880 Troy Corporate Center loan ($28.1 million; 3.6%), the
largest loan with the special servicer and the fourth-largest loan
in the pool, is secured by a 186,565-sq.-ft. office building built
in 1999 in Troy, Mich.  This loan was transferred to special
servicing on Jan. 7, 2010, due to imminent default.  The property
is currently 100% leased to the InterOne Marketing Group, and the
special servicer reports that the sole tenant is in the process of
exercising its termination option.  S&P expects a moderate loss
upon the resolution of this loan.

The 840 Troy Corporate Center loan ($25.2 million; 3.3%), the
second-largest loan with the special servicer and the sixth-
largest loan in the pool, is also secured by a 186,565-sq.-ft.
office building built in 1999 in Troy, Mich.  This loan was also
transferred to the special servicer on Jan. 7, 2010, due to
imminent default.  This property is a multitenanted building, and
for year-end 2009, the occupancy and DSC were 97.5% and 1.59x,
respectively.  Subsequently, various tenants have vacated the
property, causing occupancy to decline to 56% as of the April 2010
rent roll.  With the decline in occupancy S&P estimate a DSC of
0.53x.

The Gainesville Place loan ($15.9 million; 2.1%), the third-
largest loan with the special servicer and the ninth-largest loan
in the pool, is secured by a 168-unit property in Gainesville,
Fla., that was built in 2000.  This loan was transferred to the
special servicer on Jan. 1, 2010, due to a payment default and is
currently 90 days delinquent.  For year-end 2009, the occupancy
and DSC were 76% and 0.98x, respectively.  S&P expects a moderate
loss upon the resolution of this asset.

S&P expects the fourth-largest loan with the special servicer, the
Columbiana Lakes Apartments loan ($8.3 million; 1.1%), to be
repaid in full.  This loan is secured by a 204-unit apartment
building built in 1996 in Columbia, S.C.  For year-end 2008, the
occupancy and DSC were 90% and 0.88x, respectively.

The six remaining specially serviced loans ($27.5 million, 3.5%)
have balances that individually represent 1.0% or less of the
total pool balance.  S&P separately estimated losses ranging from
10.8% to 74.5% for five of these loans ($23.7 million; 3.1%).  The
sixth loan ($5.5 million; 0.7%) is in the process of being
modified.

A significant portion of the pool matures in 2011 and 2012.
Excluding both defeased and specially serviced loans, there are 39
of these loans ($277.4 million; 35.8%).

                       Transaction Summary

As of the July 12, 2010, remittance report, the transaction had an
aggregate trust balance of $773.9 million (92 loans), compared
with $1.1 billion (118 loans) at issuance.  Bank of America Corp.,
the master servicer, provided financial information for 98.9% of
the pool balance.  All but 2% of this servicer-provided financial
information was partial-year 2009 or full-year 2009 data.

S&P calculated a weighted average DSC of 1.28x for the loans in
the pool based on the reported figures.  S&P's adjusted DSC and
LTV were 1.16x and 109.1%, respectively.  These calculations
exclude eight ($72.3 million; 9.3%) specially serviced loans and
20 ($167.9 million; 21.7%) defeased loans.  S&P separately
estimated losses for the eight specially serviced loans.  The
weighted average DSC based upon reported information for year-end
2008 and 2009 was 1.21x.  Twenty loans ($201.1 million; 26.0%),
including the largest, seventh-largest, and 10th-largest loans in
the pool, are on the master servicer's watchlist.  Five loans
($32.9 million, 4.2%) have a reported DSC between 1.0x and 1.1x,
and 17 loans ($166.8 million, 21.6%) have a reported DSC of less
than 1.0x.  To date, the trust has experienced principal losses of
$17.4 million relating to eight assets.

                     Summary of Top 10 Loans

The top 10 assets secured by real estate have an aggregate
outstanding balance of $296.8 million (38.4%).  Using servicer-
reported information, S&P calculated a weighted average DSC of
1.28x.  S&P's adjusted DSC and LTV figures for the top 10 assets
secured by real estate were 1.01x and 136.6%, respectively.  These
figures exclude the 880 Troy Corporate Center loan, the fourth-
largest loan in the pool ($28.1 million; 3.6%), as well as the
Gainesville Place loan, the ninth-largest loan in the pool
($15.9 million; 2.1%).  Both of these loans are with the special
servicer and were discussed above.  Three other top 10 loan
exposures are on the master servicer's watchlist, which S&P
discuss below.

The Regency Square loan ($73.4 million; 9.5%), the largest loan in
the pool, is secured by 231,371 sq. ft. of in-line space in an
818,083-sq.-ft. regional mall in Richmond, Va., that was
originally constructed in 1975 and renovated in 1987.  It appears
on the master servicer's watchlist due to a low DSC.  For year-end
2009, the reported occupancy and DSC were 100.0% and 0.75x,
respectively.  The reported DSC is low because the borrower has
adjusted rents to provide relief to certain tenants, some of which
are paying only percentage rent (equivalent to a stipulated
percentage of sales).  Based on an April 2010 rent roll, the
occupancy of the in-line space has declined to 79%.  As a result,
S&P estimated a DSC of 0.44x based on the lower occupancy.
According the inspection provided by the master servicer dated
Feb. 15, 2010, the property is considered to be in "fair"
condition.  S&P's analysis of the market indicates that the
property's performance has suffered due to new competition in the
market, which has drawn former shoppers to new locations.

The Vornado Industrial - 901, 903-906 Murray Road loan
($24.6 million; 3.2%), the seventh-largest loan in the pool
secured by real estate, is secured by five separate warehouse
buildings totaling 942,206 sq. ft. in East Hanover, N.J., that
were built in 1963.  The loan appears on the master servicer's
watchlist due to tenant rollover.  For year-end 2009, the reported
occupancy and DSC were 89.4% and 1.41x, respectively.  The
property is currently 63% leased, and based on this occupancy, S&P
estimates a current DSC of 0.75x.

The Rio Grande Industrial exposure ($15.9 million; 2.1%), the
10th-largest in the pool secured by real estate, consists of two
cross-collateralized and cross-defaulted mortgage loans.  It
appears on the watchlist due to a low DSC.  The Rio Grande
Industrial Portfolio (Roll-Up) loan ($14.3 million; 1.9%) is
secured by four industrial buildings that total 661,696 sq. ft.
Three of the buildings (643,216 sq. ft.) are in Brownsville,
Texas, and were built between 1977 and 1983.  One of the three
buildings (536,016 sq. ft.) was renovated in 1997, and another
(16,500 sq. ft.) was renovated in 1989.  The fourth building
(18,480 sq. ft.) is in Edinburg, Texas, and was built in 1983.
The Rio Grande Industrial Center #4 loan ($1.6 million, 0.2%) is
secured by a 90,000-sq.-ft. industrial building also built in 1983
in Brownsville, Texas.  For year-end 2009, the reported DSC and
occupancy were 0.98x and 80.4%, respectively, for the Rio Grande
Industrial (Roll-Up) loan and were 1.35x and 66.7% for the Rio
Grande Industrial Center #4 loan.  The blended DSC and occupancy
were 1.02x and 78.4%, respectively.  Based on the current leasing
status, S&P estimates a current blended DSC of 1.27x.

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

      Ratings Lowered And Removed From Creditwatch Negative

             Banc of America Commercial Mortgage Inc.
   Commercial mortgage pass-through certificates series 2002-PB2

                   Rating
                   ------
       Class     To     From          Credit enhancement (%)
       -----     --     ----          ----------------------
       J         BB-   A-/Watch Neg                  10.09
       K         B+    BBB+/Watch Neg                 7.92
       L         B-    BB+/Watch Neg                  5.37
       M         CCC+  BB-/Watch Neg                  4.28
       N         CCC-  B+/Watch Neg                   2.57
       O         CCC-  B-/Watch Neg                   1.63
       P         CCC-  CCC+/Watch Neg                 1.01

                         Ratings Lowered

             Banc of America Commercial Mortgage Inc.
   Commercial mortgage pass-through certificates series 2002-PB2

                       Rating
                       ------
          Class     To     From   Credit enhancement (%)
          -----     --     ----   ----------------------
          D         AA-    AAA                    19.90
          E         BBB    AAA                    17.36
          F         BBB-   AAA                    15.91
          G         BB+    AA+                    14.09
          H         BB     A+                     11.91

                         Ratings Affirmed

             Banc of America Commercial Mortgage Inc.
   Commercial mortgage pass-through certificates series 2002-PB2

             Class     Rating   Credit enhancement (%)
             -----     ------   ----------------------
             A4        AAA                       30.43
             B         AAA                       23.90
             C         AAA                       21.72
             X-C       AAA                         N/A

                       N/A - Not applicable.


BEAR STEARNS: Fitch Affirms Ratings on 2004-BBA3 Certificates
-------------------------------------------------------------
Fitch Ratings has affirmed Bear Stearns Commercial Mortgage
Securities, Inc. commercial mortgage pass-through certificates,
series 2004-BBA3.  Fitch does not expect losses to the remaining
loan in the base case, and there are no expected future fees due
to the special servicer.  The revision of the Rating Outlook to
Stable on class K reflects Fitch's expectation that the class will
pay in full.  The Negative Outlook assigned to class B reflects
additional sensitivity analysis related to further negative credit
migration of the underlying collateral.

The remaining loan in the transaction is the $24.7 million
Riverside Center.  Under Fitch's updated analysis, the loan was
modeled to default in the base case stress scenario, defined as
the 'B' stress.  In this scenario, the modeled cash flow decline
was 10.4%, which was applied to the most recent servicer-reported
financial information, with full credit given to newly signed
leases.  Fitch analyzed servicer-reported operating statements,
rent rolls, in addition to other information received from the
master servicer.

The loan is collateralized by a 705,331 retail power center
located in Utica, Oneida County, NY.  Property anchors include
Wal-Mart, BJ's Wholesale Club and Lowe's Home Center.  With the
exception of the anchors, a total of six tenants occupy the
property: Burlington Coat Factory, Famous Labels, Tractor Supply,
Adirondack Furniture, Applebee's Bar & Grill, and Pearle Vision.

The loan has returned to the master servicer as of December 2009
after being in special servicing since September 2008.  The
borrower was unable to refinance at the original final maturity
date in November 2008 due to the loss of Linens-N-Things, Steve &
Barry's and AC Moore (a combined 85,000 sf).  Occupancy was
reduced to approximately 69% as of December 2008.  As of September
2009, a new lease with Burlington Coat Factory took effect and the
store is currently open.  Adirondack Furniture's lease commenced
in November 2009.  Occupancy is currently 87.2%.

The loan has been extended to January 2011.  The borrower
deposited $2.45 million into a reserve fund, of which $950,000 was
used to pay down the A note, and $1.5 million was placed into a
TI/LC fund which was used for the new Burlington Coat Factory
space.  In addition, a full cash flow sweep was instituted whereby
all excess cash flow is lender controlled.  The borrower paid a
modification fee to the special servicer and per the master
servicer; no future fees are due on the loan.

Per the May 2010 rent roll, the property is 87.2% occupied.  The
anchor tenants lease expirations are: Wal-Mart, Feb. 28, 2020;
Lowe's, Nov. 10, 2017; BJ's Wholesale Club, Nov. 30, 2013.  As a
percent of the total sf, the lease rollover is: 2011: 0.6%; 2013:
16.2%; 2014: 9.5%; 2017: 18.4%; 2019: 9.9%; beyond 2019: 32.7%.

Fitch removes from Rating Watch Negative, affirms, and assigns a
Rating Outlook to this certificate:

  -- $18.7 million class L at 'B'; Outlook Negative.

Fitch affirms and revises the Rating Outlook on these
certificates:

  -- $6 million class K at 'AAA'; Outlook Stable.

Fitch withdraws the ratings of the interest-only class X-1B.

Classes A-1A through J and X-2 through X-5 have paid in full.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. Commercial Real Estate Loan CDOs'.  It applies
stresses to property cash flows and uses debt service coverage
ratio tests to project future default levels for the underlying
portfolio.  Recoveries are based on stressed cash flows and
Fitch's long-term capitalization rates.  This methodology was used
to review this transaction as floating-rate CMBS loan pools are
concentrated and similar in composition to CREL CDO pools.  In
many cases, the CMBS notes are senior portions of notes held in
CDO transactions.  The assets are generally transitional in
nature, frequently underwritten with pro forma income assumptions
that have not materialized as expected.  Overrides to this
methodology were applied on a loan-by-loan basis if the property
specific performance warranted an alternative analysis.

For bonds rated 'B-' or better, the current credit enhancement
levels were compared to the expected losses generated in each
rating category divided by the total deal size.  These classes
were assigned Loss Severity ratings, which indicate each tranche's
potential loss severity given default, as evidenced by the ratio
of tranche size to the expected losses for the collateral in the
'B' stress.  LS ratings should always be considered in conjunction
with probability of default indicated by a class' long-term credit
rating.  Fitch does not assign Rating Outlooks or LS ratings to
classes rated 'CCC' and lower.

Rating Outlooks were determined by further stressing the cash
flows and fully recognizing all maturity defaults in all ratings
stresses.  The credit enhancements were then compared to the
expected losses generated in each rating category to determine
potential credit migration over the next two years.  If the Rating
Outlook scenario would imply a lower rating, then the class was
assigned a Negative Outlook.

The ratings for bonds rated 'CCC' or lower, are based on a
deterministic analysis.  Bonds are rated 'C' when the expected
losses on currently defaulted loans exceed a classes' respective
credit enhancement level.  Bonds are rated 'CC' when the combined
base case expected losses on the currently defaulted loans and
loans likely to default exceed a classes' respective credit
enhancement level.  Bonds are rated 'CCC' when the base case
expected loss exceeds a classes' respective credit enhancement
level.

Bonds rated 'CCC' and below were assigned Recovery Ratings (RR) in
order to provide a forward-looking estimate of recoveries on
currently distressed or defaulted structured finance securities.
Recovery Ratings are calculated by subtracting the base case
expected losses in reverse sequential order from the pooled and
non-pooled rake certificates.  Any principal recoveries first pay
interest shortfalls on the bonds and then sequentially through the
classes.  The remaining bond principal amount is divided by the
current outstanding bond balance.  The resulting percentage is
used to assign the Recovery Ratings on the bonds.

In addition to the CREL CDO methodology, Fitch reviewed the
transaction in conjunction with its 'Rating U.S. Single-Borrower
Commercial Mortgage Transactions,' as there is one remaining loan.
This review included reviewing insurance requirements and borrower
structure.  As there is no current criteria for assigning Loss
Severity ratings to single-borrower deals, none were assigned to
this transaction's classes.


BROOKLYN NAVY: Fitch Downgrades Ratings on Bonds to 'B+'
--------------------------------------------------------
Fitch Ratings has downgraded to 'B+' from 'BB' these bonds of
Brooklyn Navy Yard Cogeneration Partners:

  -- $58.9 million of taxable senior secured notes issued by BNY;

  -- $307 million of tax-exempt senior secured bonds issued by the
     New York City Industrial Development Agency on behalf of BNY.

The Rating Outlook has been revised to Negative from Evolving.

The rating downgrade reflects the project's increasing operating
costs, exposure to natural gas price volatility (fuel and
transportation), and increasing tax liability.  Based upon Fitch's
estimate, all of these factors pressure projected cash flows to
nearly breakeven debt service coverage ratios (DSCR of 1.0 times
[x]) under mild financial stress of just 2%-2.5% reduction in
revenues.

Although management has made investments to improve operations,
the Negative Outlook reflects that BNY remains vulnerable to
outages that could materially reduce DSCRs.  With unstable
operating performance in recent years, BNY has relied on
restricted reserve funds to support operations.  BNY overhauled
combustion turbines and a steam turbine in 2008 and 2009,
respectively.  However, based upon the sponsor's projection of
1.13x DSCR, which was verified by an independent engineer, a
reduction of only 2% in budgeted revenues could result in DSCRs
below 1.0x in 2010.  Additionally, Fitch expects expenses to
remain high as the project absorbs a nearly 42% increase in one of
its gas transportation contracts and increased water costs from
the City of New York, further pressuring financial cushion.

BNY also remains entangled with the City and State of New York
over BNY's past and future tax obligations.  The exemption from
property taxes related to the payment in lieu of taxes (PILOT)
expired in 2009 and will be phased in over a 10-year period but
BNY remains in discussions with city officials regarding its
future PILOT obligations.  Depending upon the outcome of a
possible settlement with the City and State, past sales and use
taxes may have to be spread over time and absorbed by operating
cash flow.  If the decision is adverse, BNY may lack sufficient
liquidity to meet such an obligation.  Favorably, Fitch notes that
BNY is able to pass future sales and use taxes to Consolidated
Edison (ConEd, rated 'BBB+/F2' with a Stable Outlook by Fitch) in
which the 2010 Budget estimates 82% reimbursement.  Also of note,
on May 18, 2010, the Public Services Commission issued an order
permitting ConEd rate recovery of BNY's (and other independent
power providers') costs associated with the Regional Greenhouse
Gas Initiative.

Credit strengths that continue to support the rating include:

  -- BNY is a relevant component of ConEd's power supply and
     comprises 17% of the utility's delivered steam output.

  -- The long-term energy sales agreement with off-taker ConEd
     coincides with the term of BNY's 40-year debt, maturing in
     2036.

What could trigger a return to a Stable Outlook?

  -- Sustained improvement in operational performance, including
     favorable results of combustion and steam turbine inspections
     scheduled to occur in 2010 and 2011, respectively.

  -- Actual DSCR results consistently and considerably exceed
     1.0x.

  -- Ability to absorb potential tax liabilities without material
     degradation in cash flow.

Brooklyn Navy Yard is a nominally rated 286 megawatt natural gas-
fired cogeneration facility located in New York City, NY.  The
facility is designed to provide 220 MWs of electricity year-round
and steam ranging from 550,000 lbs/hour in the summer to 800,000
lbs/hour in the winter.  Under an Electric Sales Agreement, BNY
sells nearly its entire output of electrical and steam energy to
ConEd.


CALIFORNIA STATEWIDE: S&P Downgrades Ratings on 2002D-1 Bonds
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on
California Statewide Communities Development Authority's (Citrus
Gardens Apartments project) multifamily housing revenue refunding
bonds series 2002D-1 (senior) and 2002D-3 (junior) to 'BBB' and
'BB' from 'A' and 'BBB', respectively.  The outlook is stable.

The ratings reflect S&P's opinion of declining debt service
coverage level of 1.28x maximum annual debt service (MADS) on the
senior bonds and 1.15x on the junior bonds, based on 2009 audited
statements; decrease in net occupancy to 90% in 2009 from 93% in
2008; increasing vacancy in the project's submarket; and high
loan-to-value ratio of 98% based on 2009 operating income and the
project's rated debt.

However, the above weaknesses are partially offset by S&P's
opinion of a debt service reserve fund funded at 12 months' MADS.

"The stable outlook reflects S&P's view of the property's ability
to generate sufficient rental income at the current rating level,"
said Standard & Poor's credit analyst Mikiyon Alexander.

Citrus Gardens is a 200-unit, garden-style multifamily apartment
complex that was constructed in 1987.  It is located at 8600
Citrus Ave., Fontana, Calif., on a quiet secondary street, in a
residential community that is primarily single-family residential
in nature, but contains a few multifamily residential projects.
The project consists of 56 one-bedroom apartments and 144 two-
bedroom apartments.


CAPITAL ONE: Moody's Reviews Ratings on 47 Classes of Securities
----------------------------------------------------------------
Moody's Investors Service has placed on review for possible
downgrade 47 classes of asset-backed securities issued out of the
Capital One Multi-asset Execution Trust.  These securities are
backed by a $42.4 billion revolving pool of consumer and small
business credit card receivables originated by Capital One Bank
(USA), N.A.

                             Rationale

This action follows Moody's announcement on July 27 that it is
reviewing for possible downgrade, among other ratings, the short-
term and long-term unsecured ratings of Capital One Bank (Prime-1
and A2 respectively).  The ratings under review have benefited
from Moody's increased expectation of government support since
2009.  Specifically, the A2 long-term unsecured rating benefits
from one notch of systemic support.  None of the bank's
unsupported ratings, such as its bank financial strength rating,
are on review.  Capital One Bank is the seller/servicer of the
Trust.

The financial strength of the seller/servicer is an important
factor in Moody's determination of card ABS ratings, as an
issuer's ongoing willingness and ability to maintain card utility
(i.e. the purchase rate) is a significant driver of trust
collateral performance in an early amortization scenario.  ABS
maturing within the next six months (i.e. before February 2011)
were excluded from this rating action due to the low probability
of early amortization in the very near future.

Moody's performance expectations for the Trust are unchanged.  The
current expected range for the gross charge-off rate is 9.5%-
12.5%, for the principal payment rate is 14%-17%, and for the
yield is 20%-23%.  Performance of these metrics has been generally
inside these ranges over the past 18 months.

These performance expectations indicate Moody's forward-looking
view of the likely range of performance over the medium term.
From time to time, Moody's may, if warranted, change these
expectations.  Performance that falls outside a given range may
indicate that the collateral's credit quality is stronger or
weaker than anticipated when the related securities were rated.
Even so, a deviation from the expected range will not necessarily
result in a rating action nor does performance within expectations
preclude such actions.  The decision to take (or not take) a
rating action is dependent on an assessment of a range of factors
including, but not exclusively, the performance metrics.

During the review process, which typically takes up to 90 days,
Moody's will reassess whether Capital One's ability and
willingness to maintain card utility under stress scenarios are
consistent with the current credit enhancement and ratings on the
ABS.  A downgrade, if any, is not likely to exceed two notches.

The complete rating actions are:

Issuer: Capital One Multi-asset Execution Trust

  -- $500,000,000 Class A (2004-1) Aaa Placed on Review for
     Possible Downgrade; previously on February 26, 2004 assigned
     Aaa

  -- $500,000,000 Class A (2004-4) Aaa Placed on Review for
     Possible Downgrade; previously on June 10, 2004 assigned Aaa

  -- $200,000,000 Class A (2004-5) Aaa Placed on Review for
     Possible Downgrade; previously on June 10, 2004 assigned Aaa

  -- $500,000,000 Class A (2004-7) Aaa Placed on Review for
     Possible Downgrade; previously on September 9, 2004 assigned
     Aaa

  -- $500,000,000 Class A (2004-8) Aaa Placed on Review for
     Possible Downgrade; previously on November 10, 2004 assigned
     Aaa

  -- $750,000,000 Class A (2005-1) Aaa Placed on Review for
     Possible Downgrade; previously on April 1, 2005 assigned Aaa

  -- $455,000,000 Class A (2005-6) Aaa Placed on Review for
     Possible Downgrade; previously on July 28, 2005 assigned Aaa

  -- $500,000,000 Class A (2005-7) Aaa Placed on Review for
     Possible Downgrade; previously on August 18, 2005 assigned
     Aaa

  -- $325,000,000 Class A (2005-9) Aaa Placed on Review for
     Possible Downgrade; previously on October 19, 2005 assigned
     Aaa

  -- $500,000,000 Class A (2005-10) Aaa Placed on Review for
     Possible Downgrade; previously on November 15, 2005 assigned
     Aaa

  -- $500,000,000 Class A (2006-1) Aaa Placed on Review for
     Possible Downgrade; previously on January 20, 2006 assigned
     Aaa

  -- $400,000,000 Class A (2006-3) Aaa Placed on Review for
     Possible Downgrade; previously on March 1, 2006 assigned Aaa

  -- $1,000,000,000 Class A (2006-4) Aaa Placed on Review for
     Possible Downgrade; previously on March 8, 2006 assigned Aaa

  -- $500,000,000 Class A (2006-5) Aaa Placed on Review for
     Possible Downgrade; previously on April 4, 2006 assigned Aaa

  -- $500,000,000 Class A (2006-6) Aaa Placed on Review for
     Possible Downgrade; previously on April 25, 2006 assigned Aaa

  -- $1,000,000,000 Class A (2006-7) Aaa Placed on Review for
     Possible Downgrade; previously on May 17, 2006 assigned Aaa

  -- $300,000,000 Class A (2006-8) Aaa Placed on Review for
     Possible Downgrade; previously on June 30, 2006 assigned Aaa

  -- $500,000,000 Class A (2006-10) Aaa Placed on Review for
     Possible Downgrade; previously on August 25, 2006 assigned
     Aaa

  -- $750,000,000 Class A (2006-11) Aaa Placed on Review for
     Possible Downgrade; previously on September 1, 2006 assigned
     Aaa

  -- $500,000,000 Class A (2006-12) Aaa Placed on Review for
     Possible Downgrade; previously on October 5, 2006 assigned
     Aaa

  -- $625,000,000 Class A (2007-1) Aaa Placed on Review for
     Possible Downgrade; previously on January 26, 2007 assigned
     Aaa

  -- $700,000,000 Class A (2007-2) Aaa Placed on Review for
     Possible Downgrade; previously on February 27, 2007 assigned
     Aaa

  -- $750,000,000 Class A (2007-4) Aaa Placed on Review for
     Possible Downgrade; previously on May 23, 2007 assigned Aaa

  -- $600,000,000 Class A (2007-5) Aaa Placed on Review for
     Possible Downgrade; previously on June 22, 2007 assigned Aaa

  -- $1,000,000,000 Class A (2007-7) Aaa Placed on Review for
     Possible Downgrade; previously on September 28, 2007 assigned
     Aaa

  -- $500,000,000 Class A (2007-8) Aaa Placed on Review for
     Possible Downgrade; previously on October 11, 2007 assigned
     Aaa

  -- $200,000,000 Class A (2007-A) Aaa Placed on Review for
     Possible Downgrade; previously on May 4, 2007 assigned Aaa

  -- $500,000,000 Class A (2008-B) Aaa Placed on Review for
     Possible Downgrade; previously on July 11, 2008 assigned Aaa

  -- $600,000,000 Class A (2008-3) Aaa Placed on Review for
     Possible Downgrade; previously on April 16, 2008 assigned Aaa

  -- $750,000,000 Class A (2008-5) Aaa Placed on Review for
     Possible Downgrade; previously on May 12, 2008 assigned Aaa

  -- $500,000,000 Class A (2008-6) Aaa Placed on Review for
     Possible Downgrade; previously on May 30, 2008 assigned Aaa

  -- $1,000,000,000 Class A (2009-2) Aaa Placed on Review for
     Possible Downgrade; previously on June 16, 2009 assigned Aaa

  -- $150,000,000 Class B (2004-3) A2 Placed on Review for
     Possible Downgrade; previously on April 14, 2004 assigned A2

  -- $184,605,000 Class B (2004-7)A2 Placed on Review for Possible
     Downgrade; previously on October 27, 2004 assigned A2

  -- $175,000,000 Class B (2005-1) A2 Placed on Review for
     Possible Downgrade; previously on March 3, 2005 assigned A2

  -- $100,000,000 Class B (2005-3) A2 Placed on Review for
     Possible Downgrade; previously on August 4, 2005 assigned A2

  -- $175,000,000 Class B (2006-1) A2 Placed on Review for
     Possible Downgrade; previously on April 6, 2006 assigned A2

  -- $350,000,000 Class B (2007-1) A2 Placed on Review for
     Possible Downgrade; previously on January 26, 2007 assigned
     A2

  -- $250,000,000 Class C (2003-3) Ba1 Placed on Review for
     Possible Downgrade; previously on July 1, 2009 downgraded to
     Ba1 from Baa2

  -- $100,000,000 Class C (2004-2) Ba1 Placed on Review for
     Possible Downgrade, previously on July 1, 2009 downgraded to
     Ba1 from Baa2

  -- $367,500,000 Class C (2004-3) Ba1 Placed on Review for
     Possible Downgrade; previously on July 1, 2009 downgraded to
     Ba1 from Baa2

  -- $175,000,000 Class C (2006-1) Ba1 Placed on Review for
     Possible Downgrade; previously on July 1, 2009 downgraded to
     Ba1 from Baa2

  -- $100,000,000 Class C (2006-2) Ba1 Placed on Review for
     Possible Downgrade; previously on July 1, 2009 downgraded to
     Ba1 from Baa2

  -- $125,000,000 Class C (2006-3) Ba1 Placed on Review for
     Possible Downgrade; previously on July 1, 2009 downgraded to
     Ba1 from Baa2

  -- $300,000,000 Class C (2007-1) Ba1 Placed on Review for
     Possible Downgrade; previously on July 1, 2009 downgraded to
     Ba1 from Baa2

  -- $250,000,000 Class C (2007-2) Ba1 Placed on Review for
     Possible Downgrade; previously on July 1, 2009 downgraded to
     Ba1 from Baa2

  -- $350,000,000 Class C (2007-4) Ba1 Placed on Review for
     Possible Downgrade; previously on July 1, 2009 downgraded to
     Ba1 from Baa2


CBA COMMERCIAL: S&P Downgrades Ratings on 2007-1 Certs. to 'D'
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class M-4 and M-5 commercial mortgage pass-through certificates
from CBA Commercial Assets' series 2007-1 to 'D' from 'CCC-'.

The downgrades of the M-4 and M-5 classes follow principal losses
as reflected on the July 26, 2010, remittance report.  The M-4
class realized a 49.8% loss to its opening balance of $1,436,000.
The M-5 class realized a 100% loss to its opening balance of
$1,755,000.

As of the July 2010 remittance report, the collateral pool
consisted of 178 loans and nine real estate owned assets with an
aggregate trust balance of $99.9 million, down from 237 loans
totaling $127.6 million at issuance.  There are currently 49 loans
totaling $30.3 million (30.3%) with the special servicer.  Nine of
the assets in the pool are REO (6.7%), 28 are in foreclosure
(14.9%), five are 90-plus-days delinquent (2.6%), and 10 are 30-
plus-days delinquent (7.6%).  To date, the trust has experienced
losses on 19 loans.  The total losses to the trust are
$9.2 million as per the July 26, 2010, remittance report.

                         Ratings Lowered

                      CBA Commercial Assets
    Commercial mortgage pass-through certificates series 2007-1

                  Rating
                  ------
    Class       To          From             Credit enhancement
    -----       --          ----             ------------------
    M-4         D           CCC-                            N/A
    M-5         D           CCC-                            N/A

                      N/A - Not applicable.


COLISEUM SPC: S&P Downgrades Ratings on 2007-1 Notes to 'D'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the notes
issued by Coliseum SPC, acting for the account of Chalfont 2007-1
Segregated Portfolio to 'D' from 'CC'.

The transaction is a total return swap, and the rating is directly
linked to the rating on the class I notes issued from Stack 2006-1
Ltd., which Standard & Poor's lowered to 'D' on May 18, 2010.

                          Rating Lowered

      Coliseum SPC acting for the account of Chalfont 2007-1
                       Segregated Portfolio

                                  Rating
                                  ------
                     Tranche    To       From
                     -------    --       ----
                     Notes      D        CC


COMM 2004-RS1: Fitch Takes Rating Actions on Various Classes
------------------------------------------------------------
Fitch Ratings has affirmed one class and downgraded 13 classes of
COMM 2004-RS1 Ltd./Corp. due to negative credit migration on the
underlying collateral.

Since Fitch's last rating action in January 2009, the credit
quality of the portfolio has declined to a current weighted
average Fitch derived rating of 'BBB-/BB+', down from 'A/A-' at
last review.  The portfolio's concentration is high with only 12
obligors, one of which, Marquee 2004-1, comprises 75.4% of the
pool.  Marquee 2004-1 is a repack of one mezzanine class of CMCMT
1998-C1, a commercial mortgage-backed securities resecuritization.
The current weighted average Fitch derived rating of CMCMT 1998-C1
is 'B-/CCC+', down from 'B/B-' at last review.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  Given the significant concentration
of Marquee 2004-1 within the portfolio, Fitch assigned shadow
ratings to the Marquee 2004-1 classes based on an analysis of the
CMCMT 1998-C1 portfolio using the PCM.  Based on this analysis,
the credit characteristics of classes A through G are generally
consistent with the ratings assigned below.

Classes H through N do not pass at the 'CCC' stress, which is
PCM's lowest stress scenario.  Therefore, these classes have been
downgraded to 'CC' indicating that default is probable.  The
credit enhancement to these classes is minimal, thus any future
portfolio losses could cause these classes to default.

The Negative Rating Outlooks on classes A through C reflect
Fitch's expectation that underlying CMBS loans will continue to
face refinance risk at maturity.  Fitch also assigned Loss
Severity ratings to the notes.  The LS ratings indicate each
tranche's potential loss severity given default, as evidenced by
the ratio of tranche size to the expected loss for the collateral
under the 'B' stress.  The LS rating should always be considered
in conjunction with probability of default indicated by a class's
long-term credit rating.  Fitch does not assign Rating Outlooks or
LS ratings to classes rated 'CCC' or lower.

COMM 2004-RS1 is a CMBS mezzanine resecuritization that closed in
November 2004.  Currently, 75.4% of the portfolio is composed of
six classes of Marquee 2004-1, 22.4% is CMBS, and 2.2% is CMBS
rake bonds secured by a defeased loan.

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

  -- $219,953,797 class A at 'BBB/LS2'; Outlook to Negative from
     Stable;

  -- $39,020,000 class B-1 to 'B/LS3' from 'BB+'; Outlook to
     Negative from Stable;

  -- $41,298,000 class B-2 to 'B/LS3' from 'BB+'; Outlook to
     Negative from Stable;

  -- $13,386,000 class C to 'B/LS5' from 'BB'; Outlook to Negative
     from Stable;

  -- $12,955,000 class D to 'CCC' from 'BB-';

  -- $4,318,000 class E to 'CCC' from 'B+';

  -- $3,023,000 class F to 'CCC' from 'B+';

  -- $2,056,000 class G to 'CCC' from 'B';

  -- $2,176,000 class H to 'CC' from 'B';

  -- $725,000 class J to 'CC' from 'B';

  -- $1,313,000 class K to 'CC' from 'B-';

  -- $1,520,000 class L to 'CC' from 'B-';

  -- $622,000 class M to 'CC' from 'B-';

  -- $2,384,528 class N to 'CC' from 'CCC'.

The Rating Outlooks for classes D through M were Stable prior to
the downgrades.

Fitch withdrew the ratings of the interest only classes IO-1 and
IO-2.


COMM 2004-RS1: S&P Downgrades Ratings on Six Classes of Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes from COMM 2004-RS1.  At the same time, S&P affirmed its
ratings on 10 classes from the same transaction.  S&P also removed
all 16 ratings from CreditWatch negative.

The downgrades and affirmations reflect S&P's analysis of the
transaction following the downgrade of four classes of commercial
mortgage-backed securities that serve as collateral for COMM 2004-
RS1.  The underlying securities are from three transactions and
total $23.1 million (6.7% of the total asset balance).  S&P also
lowered its credit estimates on classes G, H, and J from GE
Capital Commercial Mortgage Corp. series 2004-C2 ($14.1 million,
4.1%), which S&P does not rate.

According to the July 6, 2010, trustee report, COMM 2004-RS1 was
collateralized by 19 CMBS classes ($84.7 million, 24.6%) from 11
distinct transactions issued in either 2001 or 2004.  The current
assets also include six classes ($260 million, 75.4%) of
commercial real estate collateralized debt obligation bonds from
Marquee 2004-1 Ltd., which Standard & Poor's does not rate.  COMM
2004-RS1 has exposure to these transactions that Standard & Poor's
has downgraded:

* GMAC Commercial Mortgage Securities Inc.'s series 2004-C2
  (classes F, G, and H; $12.2 million, 3.5%);

* LB-UBS Commercial Mortgage Trust 2004-C2 (class K; $6 million,
  1.7%); and

* Banc of America Commercial Mortgage Inc.'s series 2004-3 (class
  H; $4.9 million, 1.4%).

Standard & Poor's analyzed COMM 2004-RS1 and its underlying
collateral according to its current criteria.  S&P's analysis is
consistent with its lowered and affirmed ratings.

       Ratings Lowered And Removed From Creditwatch Negative

                          COMM 2004-RS1

                                Rating
                                ------
           Class          To               From
           -----          --               ----
           G              BB               BB+/Watch Neg
           H              B+               BB/Watch Neg
           J              B                BB-/Watch Neg
           K              CCC              B+/Watch Neg
           L              CCC-             B-/Watch Neg
           M              CCC-             B-/Watch Neg

      Ratings Affirmed And Removed From Creditwatch Negative

                           COMM 2004-RS1

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


COMM 2006-CNL2: Fitch Downgrades Ratings on 13 Classes of Certs.
----------------------------------------------------------------
Fitch Ratings has downgraded 13 classes of COMM 2006-CNL2,
reflecting Fitch's base case loss expectation of 7.3%.  Fitch's
performance expectation incorporates prospective views regarding
commercial real estate market value and cash flow declines.  The
Negative Rating Outlooks reflect additional sensitivity analysis
related to further negative credit migration of the underlying
collateral.

The pool is collateralized by a single portfolio loan, CNL Hotels
& Resorts.  The loan is secured by five luxury resort/hotels,
including the Waldorf=Astoria Grand Wailea Resort & Spa (40.5% of
allocated loan amount), Waldorf=Astoria La Quinta Resort & Club
(24.2%), Waldorf=Astoria Arizona Biltmore (20.6%), Marriott Doral
Golf Resort & Spa (10.2%), and the Claremont Resort & Spa (4.5%).

The loan transferred to special servicing in October 2009 due to
imminent default.  The borrower anticipated difficulty paying
future debt service obligations, as well as repayment of the loan
at the February 2011 maturity.  The five properties securing the
loan have experienced declines in cash flow, largely due to the
economy-driven lower travel demand by both the business and
leisure sectors.  The portfolio's net operating income declined
27.6% between 2007 and 2008, and an additional 44.5% from 2008 to
2009.  While the performance declines have been significant, the
properties are expected to recover to a level more inline with
long-term historical performance.  Comparing 2010 performance for
the first five months (ending May) with the same time period for
2009, the NOI has improved 5%.  As partial-year cash flow may be
affected by seasonality, full-year 2010 cash flow is expected to
show greater improvement over the full-year 2009 performance.

The loan remains current, and the borrower continues to pay all
fees related to the workout.  The servicer continues to discuss
workout options with the borrower.

The loan is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the cash flow
decline is 25%, from the near-peak 2006 cash flow.  In its review,
Fitch analyzed servicer reported operating statements, borrower
financials, and hotel market reports.  Fitch estimates that
recoveries in the 'B' stress base case will be approximately 92%.
The luxury hotel sector, after being one of the most severely
impacted sub-sectors by the recession, has posted strong
recoveries in the last two quarters and continues to outpace the
overall U.S. hotel market recovery.

Fitch downgrades and revises Rating Outlooks on these classes as
indicated:

  -- $90 million class A-JFX to 'AA' from 'AAA'; Outlook to
     Negative from Stable;

  -- $49.5 million class A-JFL to 'AA' from 'AAA'; Outlook to
     Negative from Stable;

  -- $33.5 million class BFX to 'A' from 'AA+'; Outlook to
     Negative from Stable;

  -- $33.5 million class BFL to 'A' from 'AA+'; Outlook to
     Negative from Stable;

  -- $21 million class CFX to 'A' from 'AA'; Outlook to Negative
     from Stable;

  -- $21 million class CFL to 'A' from 'AA'; Outlook to Negative
     from Stable;

  -- $36.5 million class D to 'BBB' from 'AA-'; Outlook to
     Negative from Stable;

  -- $36.5 million class E to 'BBB' from 'A+'; Outlook to Negative
     from Stable;

  -- $36.5 million lass F to 'BBB' from 'A'; Outlook to Negative
     from Stable;

  -- $36 million class G to 'BB' from 'A-'; Outlook to Negative
     from Stable;

  -- $48.5 million class H to 'BB' from 'BBB+'; Outlook to
     Negative from Stable.

In addition, Fitch has downgraded and removed these classes from
Rating Watch Negative, and assigned an Outlook and Recovery Rating
as indicated:

  -- $65 million class J to 'B' from 'BBB'; Outlook Negative;
  -- $74 million class K to 'CCC/RR1' from 'BBB-'.

In addition, Fitch affirms these classes:

  -- $50 million class A-1 at 'AAA'; Outlook Stable;
  -- $184.2 million class A-2FL at 'AAA'; Outlook Stable;
  -- $184.2 million class A-2FX at 'AAA'; Outlook Stable.

Fitch withdraws the ratings on the interest-only classes X-1 and
X-2.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. Commercial Real Estate Loan CDOs'.  It applies
stresses to property cash flows and uses debt service coverage
ratio tests to project future default levels for the underlying
portfolio.  Recoveries are based on stressed cash flows and
Fitch's long-term capitalization rates.  As the transaction is a
U.S. CMBS single-borrower transaction, in addition to the CREL CDO
methodology, Fitch reviewed the deal in conjunction with its
'Rating U.S. Single-Borrower Commercial Mortgage Transactions,'
including reviewing insurance requirements and borrower structure.
As there is not current criteria for assigning loss severity
ratings to single-borrower deals, none were assigned to this
transaction's classes.

Outlooks were determined by further stressing the cash flows and
fully recognizing all maturity defaults in all ratings stresses.
The credit enhancements were then compared to the expected losses
generated in each rating category to determine potential credit
migration over the next two years.  If the Outlook scenario would
imply a lower rating, then the class was assigned a Negative
Outlook.

The ratings for bonds rated 'CCC' or lower, are based on a
deterministic analysis.  Bonds are rated 'C' when the expected
losses on currently defaulted loans exceed a classes' respective
credit enhancement level.  Bonds are rated 'CC' when the combined
base case expected losses on the currently defaulted loans and
loans likely to default exceed a classes' respective credit
enhancement level.  Bonds are rated 'CCC' when the base case
expected loss exceeds a classes' respective credit enhancement
level.

Bonds rated 'CCC' and below were assigned Recovery Ratings in
order to provide a forward-looking estimate of recoveries on
currently distressed or defaulted structured finance securities.
Recovery Ratings are calculated by subtracting the base case
expected losses in reverse sequential order from the pooled
certificates.  Any principal recoveries first pay interest
shortfalls on the bonds and then sequentially through the classes.
The remaining bond principal amount is divided by the current
outstanding bond balance.  The resulting percentage is used to
assign the Recovery Ratings on the bonds.


COMM MORTGAGE: Fitch Upgrades Ratings on 2005-FL10 Certificates
---------------------------------------------------------------
Fitch Ratings has upgraded three non-pooled junior participation
certificates of COMM Mortgage Trust 2005-FL10.  The upgrades are
due to additional information on the loan workout provided by the
special servicer and the issuer.  The details provided include
specific information regarding the cash flow sweep, which is
expected to deleverage the Palisades Center loan on a quarterly
basis through maturity.  Fitch's performance expectation
incorporates prospective views regarding commercial real estate
values and cash flow declines.  A detailed list of rating actions
follows at the end of this release.

The Palisades Center, interest  -- only loan is collateralized by
approximately 2 million square feet of a 2.3 million sf, four-
story super regional mall located in West Nyack, NY.  The subject
is located approximately 18 miles north of Midtown Manhattan.  The
mall is considered one of the premier shopping destinations for
Rockland County, Westchester County, and Bergen County, NY.  The
collateral consists of approximately 893,927 sf of in-line space
and 1.4 million sf of anchor/major tenant space.  The loan
transferred to special servicing in January 2010 due to an
imminent final maturity default.  The loan has been extended to
Feb.  9, 2012 and as a condition of the loan modification, the
loan was paid down approximately $6.5 million.  In addition, a
cash flow sweep has been implemented and is expected to deleverage
the loan on a quarterly basis.

Fitch upgrades and assigns a Rating Outlook to this non-pooled
class:

  -- $3.9 million class N-PC to 'B' from 'CCC/RR6'; Outlook
     Negative.

Fitch upgrades these non-pooled classes:

  -- $12.5 million class P-PC to 'CCC/RR6' from 'CC/RR6';
  -- $8.5 million class Q-PC to 'CCC/RR6' from 'CC/RR6'.

In addition, Fitch revises the Recovery Rating on this class:

  -- $12.5 million class O-PC to 'CCC/RR2' from 'CCC/RR6'.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. Commercial Real Estate Loan CDOs'.  It applies
stresses to property cash flows and uses debt service coverage
ratio tests to project future default levels for the underlying
portfolio.  Recoveries are based on stressed cash flows and
Fitch's long-term capitalization rates.  This methodology was used
to review this transaction as floating-rate commercial mortgage
backed security loan pools are concentrated and similar in
composition to CREL CDO pools.  In many cases, the CMBS notes are
senior portions of notes held in CDO transactions.  The assets are
generally transitional in nature, frequently underwritten with pro
forma income assumptions that have not materialized as expected.
Overrides to this methodology were applied on a loan-by-loan basis
if the property specific performance warranted an alternative
analysis.

For bonds rated 'B-' or better, the current credit enhancement
levels were compared to the expected losses generated in each
rating category divided by the total deal size.  These classes
were assigned Loss Severity ratings, which indicate each tranche's
potential loss severity given default, as evidenced by the ratio
of tranche size to the expected losses for the collateral in the
'B' stress.  LS ratings should always be considered in conjunction
with probability of default indicated by a class' long-term credit
rating.  Fitch does not assign Rating Outlooks or LS ratings to
classes rated 'CCC' and lower.

Rating Outlooks were determined by further stressing the cash
flows and fully recognizing all maturity defaults in all ratings
stresses.  The credit enhancements were then compared to the
expected losses generated in each rating category to determine
potential credit migration over the next two years.  If the Rating
Outlook scenario would imply a lower rating, then the class was
assigned a Negative Outlook.

The ratings for bonds rated 'CCC' or lower, are based on a
deterministic analysis.  Bonds are rated 'C' when the expected
losses on currently defaulted loans exceed a classes' respective
credit enhancement level.  Bonds are rated 'CC' when the combined
base case expected losses on the currently defaulted loans and
loans likely to default exceed a classes' respective credit
enhancement level.  Bonds are rated 'CCC' when the base case
expected loss exceeds a classes' respective credit enhancement
level.

Bonds rated 'CCC' and below were assigned Recovery Ratings in
order to provide a forward-looking estimate of recoveries on
currently distressed or defaulted structured finance securities.
Recovery Ratings are calculated by subtracting the base case
expected losses in reverse sequential order from the pooled and
non-pooled rake certificates.  Any principal recoveries first pay
interest shortfalls on the bonds and then sequentially through the
classes.  The remaining bond principal amount is divided by the
current outstanding bond balance.  The resulting percentage is
used to assign the Recovery Ratings on the bonds.

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


COMSTOCK FUNDING: Moody's Upgrades Ratings on Various Classes
-------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Comstock Funding Ltd.:

  -- US$45,000,000 Class A-1A Floating Rate Senior Revolving Notes
     Due 2020 (current balance of $38,806,387), Upgraded to Aa1;
     previously on June 18, 2009 Downgraded to Aa2;

  -- US$280,500,000 Class A-1B Floating Rate Senior Notes Due 2020
     (current balance of $241,893,147), Upgraded to Aa1;
     previously on June 18, 2009 Downgraded to Aa2;

  -- US$22,500,000 Class A-2 Floating Rate Senior Notes Due 2020,
     Upgraded to Aa3; previously on June 18, 2009 Downgraded to
     A3;

  -- US$19,000,000 Class A-3 Floating Rate Senior Notes Due 2020,
     Upgraded to A2; previously on June 18, 2009 Downgraded to
     Baa2;

  -- US$23,000,000 Class B Floating Rate Deferrable Senior
     Subordinate Notes Due 2020, Upgraded to Ba1; previously on
     June 18, 2009 Downgraded to Ba3;

  -- US$25,000,000 Class C Floating Rate Deferrable Senior
     Subordinate Notes Due 2020, Upgraded to Caa1; previously on
     June 18, 2009 Downgraded to Caa3;

  -- US$14,000,000 Class D Floating Rate Deferrable Subordinate
     Notes Due 2020 (current balance of $13,383,707), Upgraded to
     Ca; previously on June 18, 2009 Downgraded to C.

According to Moody's, the rating actions taken on the notes result
primarily from a significant increase in the overcollateralization
of the rated notes since the last rating action in June 2009.
Based on the latest trustee report dated June 15, 2010, the Class
A, Class B, Class C and Class D Overcollateralization Ratios are
reported at 120.02%, 112.02%, 104.46% and 100.81%, respectively
versus May 2009 levels of 109.71%, 103.24%, 97.02% and 93.86%,
respectively.  Interest payments on the Class B, Class C and Class
D Notes are no longer being deferred as a result of the cure of
the Class A, Class B and Class C Overcollateralization Tests.  The
increase in overcollateralization is largely driven by prior
delevering of the Class A notes due to OC failures, sales of
defaulted securities at recoveries higher than previously
anticipated, and exposure to mezzanine and junior CLO tranches
whose credit qualities have stabilized or improved since the
previous rating action.  Moody's notes that as of June 2010,
defaulted and deferring interest securities total about $16.9
million, which is significantly less than the $34.2 million of
defaulted and deferring interest collateral reported in the May
2009 report.  Due to the impact of revised and updated key
assumptions referenced in "Moody's Approach to Rating
Collateralized Loan Obligations" and "Annual Sector Review (2009):
Global CLOs," key model inputs used by Moody's in its analysis,
such as par, weighted average rating factor, diversity score, and
weighted average recovery rate, may be different from the
trustee's reported numbers.

Comstock Funding Ltd., issued in June 2006, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.


CWABS ASSET-BACKED: Moody's Downgrades Ratings on 15 Tranches
-------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 15
tranches, upgraded ratings of 14 tranches and confirmed ratings of
11 tranches from 9 RMBS transactions, backed by Alt-A loans,
issued by Impac and Countrywide.  Countrywide issued RMBS
transactions are backed by mortgage loans originated by Impac
Funding Corporation.

The collateral backing these transactions consists primarily of
first-lien, fixed and adjustable-rate, Alt-A residential mortgage
loans.  The actions are a result of the rapidly deteriorating
performance of Alt-A pools in conjunction with macroeconomic
conditions that remain under duress.  The actions reflect Moody's
updated loss expectations on Alt-A pools issued from 2005 to 2007.

In addition, ratings on Class A-4 in Impac Secured Assets Corp.
Mortgage Pass-Through Certificates Series 2006-3; Class A-2A and
Class A-2B in Impac Secured Assets Corp. Mortgage Pass-Through
Certificates Series 2006-4; and Class A-1, Class A-2, and Class A-
3 in Impac Secured Assets Corp. Mortgage Pass-Through Certificates
Series 2007-1 have also been adjusted to reflect the fact that, as
per the Pooling and Servicing Agreement, the principal payment
waterfall continues to be sequential after credit support
depletion date.  Previous ratings on these tranches were based on
conflicting language in the Prospectus Supplement which denotes
pro-rata principal payment to senior bonds after CSDD.  The
subordinate bonds in these transactions have been depleted and the
Trustee is allocating principal sequentially to the senior
certificates in accordance with the PSA, and Moody's has adjusted
its analysis accordingly.

To assess the rating implications of the updated loss levels on
Alt-A RMBS, each individual pool was run through a variety of
scenarios in the Structured Finance Workstation(R), the cash flow
model developed by Moody's Wall Street Analytics.  This individual
pool level analysis incorporates performance variances across the
different pools and the structural features of the transaction
including priorities of payment distribution among the different
tranches, average life of the tranches, current balances of the
tranches and future cash flows under expected and stressed
scenarios.  The scenarios include ninety-six different
combinations comprising of six loss levels, four loss timing
curves and four prepayment curves.  The volatility in losses
experienced by a tranche due to small increments in losses on the
underlying mortgage pool is taken into consideration when
assigning ratings.

Tranches Cl. A-1, Cl. 1-AM, and Cl. AM issued by Impac Secured
Assets Corp. Mortgage Pass-Through Certificates Series 2006-3,
Impac Secured Assets Corp. Mortgage Pass-Through Certificates
Series 2007-2, and Impac Secured Assets Corp. Mortgage Pass-
Through Certificates Series 2007-3 respectively are wrapped by
Ambac Assurance Corporation (Segregated Account - Unrated).  For
securities insured by a financial guarantor, the rating on the
securities is the higher of (i) the guarantor's financial strength
rating and (ii) the current underlying rating (i.e., absent
consideration of the guaranty) on the security.  The principal
methodology used in determining the underlying rating is the same
methodology for rating securities that do not have a financial
guaranty and is as described earlier.  RMBS securities wrapped by
Ambac Assurance Corporation are rated at their underlying rating
without consideration of Ambac's guaranty.

Complete rating actions are:

Issuer: CWABS Asset-Backed Certificates Trust 2006-IM1

  -- Cl. A-2, Downgraded to Ca; previously on Jan. 14, 2010 Caa1
     Placed Under Review for Possible Downgrade

Issuer: Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2006-1

  -- Cl. 1-A-1-1, Confirmed at Caa3; previously on Jan. 14, 2010
     Caa3 Placed Under Review for Possible Downgrade

  -- Cl. 1-A-1-2, Downgraded to C; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. 1-A-2B, Upgraded to Caa3; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. 1-A-2C, Upgraded to Caa3; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

Issuer: Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2006-2

  -- Cl. 1-A1-1, Confirmed at Caa3; previously on Jan. 14, 2010
     Caa3 Placed Under Review for Possible Downgrade

  -- Cl. 1-A1-2, Downgraded to C; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. 1-A2-A, Upgraded to Caa3; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. 1-A2-B, Upgraded to Caa3; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. 1-A2-C, Upgraded to Caa3; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

Issuer: Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2006-3

  -- Cl. A-1, Upgraded to Caa3; previously on April 16, 2010
     Downgraded to Ca and Placed Under Review for Possible
     Downgrade

  -- Underlying Rating: Upgraded to Caa3; previously on Jan 21,
     2010 Ca Placed Under Review for Possible Downgrade

  -- Financial Guarantor: Ambac Assurance Corporation (Segregated
     Account - Unrated)

  -- Cl. A-2, Upgraded to Caa3; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. A-3, Upgraded to Caa3; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. A-4, Upgraded to B3; previously on Jan. 14, 2010 Caa2
     Placed Under Review for Possible Downgrade

  -- Cl. A-4M, Downgraded to C; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. A-5, Upgraded to Caa2; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. A-6, Confirmed at Ca; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. A-7, Confirmed at Ca; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

Issuer: Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2006-4

  -- Cl. A-1, Confirmed at Caa3; previously on Jan. 14, 2010 Caa3
     Placed Under Review for Possible Downgrade

  -- Cl. A-2A, Upgraded to Aaa; previously on Jan. 14, 2010 B3
     Placed Under Review for Possible Downgrade

  -- Cl. A-2B, Confirmed at Caa3; previously on Jan. 14, 2010 Caa3
     Placed Under Review for Possible Downgrade

  -- Cl. A-2C, Downgraded to Ca; previously on Jan. 14, 2010 Caa3
     Placed Under Review for Possible Downgrade

  -- Cl. A-M, Downgraded to C; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

Issuer: Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2006-5

  -- Cl. 1-A1-A, Downgraded to Caa3; previously on Jan. 14, 2010
     B3 Placed Under Review for Possible Downgrade

  -- Cl. 1-A1-B, Confirmed at Caa3; previously on Jan. 14, 2010
     Caa3 Placed Under Review for Possible Downgrade

  -- Cl. 1-A1-C, Confirmed at Caa3; previously on Jan. 14, 2010
     Caa3 Placed Under Review for Possible Downgrade

  -- Cl. 1-AM, Downgraded to C; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

Issuer: Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2007-1

  -- Cl. A-1, Upgraded to B1; previously on Jan. 14, 2010 Caa1
     Placed Under Review for Possible Downgrade

  -- Cl. A-2, Confirmed at Caa3; previously on Jan. 14, 2010 Caa3
     Placed Under Review for Possible Downgrade

  -- Cl. A-3, Downgraded to Ca; previously on Jan. 14, 2010 Caa3
     Placed Under Review for Possible Downgrade

  -- Cl. A-M, Downgraded to C; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

Issuer: Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2007-2

  -- Cl. 1-A1-A, Downgraded to Caa2; previously on Jan. 14, 2010
     Caa1 Placed Under Review for Possible Downgrade

  -- Cl. 1-A1-B, Confirmed at Caa2; previously on Jan. 14, 2010
     Caa2 Placed Under Review for Possible Downgrade

  -- Cl. 1-A1-C, Confirmed at Caa2; previously on Jan. 14, 2010
     Caa2 Placed Under Review for Possible Downgrade

  -- Cl. 1-AM, Downgraded to C; previously on April 16, 2010
     Downgraded to Ca and Placed Under Review for Possible
     Downgrade

  -- Underlying Rating: Downgraded to C; previously on Jan 21,
     2010 Ca Placed Under Review for Possible Downgrade

  -- Financial Guarantor: Ambac Assurance Corporation (Segregated
     Account - Unrated)

  -- Cl. 1-M-1, Downgraded to C; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

Issuer: Impac Secured Assets Corp. Mortgage Pass-Through
Certificates, Series 2007-3

  -- Cl. A1-A, Downgraded to Caa3; previously on Jan. 14, 2010
     Caa1 Placed Under Review for Possible Downgrade

  -- Cl. A1-B, Upgraded to Caa3; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. A1-C, Upgraded to Caa3; previously on Jan. 14, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. AM, Downgraded to C; previously on April 16, 2010
     Downgraded to Ca and Placed Under Review for Possible
     Downgrade

  -- Underlying Rating: Downgraded to C; previously on Jan. 21,
     2010 Ca Placed Under Review for Possible Downgrade

  -- Financial Guarantor: Ambac Assurance Corporation (Segregated
     Account - Unrated)


DEUTSCHE ALT-A: S&P Corrects Rating on class II-A-1 to 'CC'
-----------------------------------------------------------
Standard & Poor's Ratings Services corrected its rating on the
class II-A-1 certificates from Deutsche Alt-A Securities Mortgage
Loan Trust Series 2007-1 by lowering it to 'CC' from 'AAA'.  In
addition, S&P lowered its ratings on five other classes and
affirmed its ratings on two other classes from the same
transaction.

The underlying pool of loans backing this transaction consists of
conventional, adjustable-rate and fixed-rate, first-lien
residential mortgage loans.

Subordination provides credit support for this transaction.  In
addition, the certificates benefit from overcollateralization
(prior to its depletion) and excess spread.  The class I-A-4A
certificates also benefit from a certificate insurance policy
provided by MBIA Insurance Corp. ('BB+/Negative').

On March 2, 2010, S&P incorrectly affirmed its 'AAA' rating on
class II-A-1 and removed it from CreditWatch negative due to a
system error.  S&P should have lowered its rating on this class to
'CCC' at the time of its March rating action.  S&P has corrected
the error and contemporaneously conducted a review of all of the
classes in this transaction using data included in the June 2010
remittance report.  S&P's current ratings on all of the classes
reflect this review.

To assess the creditworthiness of each class, S&P reviewed their
ability to withstand additional credit deterioration.  In order to
maintain a 'B' rating on a class, S&P assessed whether, in S&P's
view, a class could absorb the base-case loss assumptions S&P used
in its analysis.  In order to maintain a rating higher than 'B',
S&P assessed whether the class could withstand losses exceeding
the base-case assumption at a percentage specific to each rating
category, up to 150% for a 'AAA' rating.  For example, in general,
S&P would assess whether one class could withstand approximately
110% of S&P's base-case loss assumptions to maintain a 'BB'
rating, while S&P would assess whether a different class could
withstand approximately 120% of its base-case loss assumptions to
maintain a 'BBB' rating.

S&P downgraded the class I-A-2, I-A-3A, I-A-3B, I-A-3C, I-A-4B
certificates to reflect its opinion that projected credit support
for these classes is insufficient to maintain the previous
ratings, given S&P's current projected losses.

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.

                         Rating Corrected

    Deutsche Alt-A Securities Mortgage Loan Trust Series 2007-1

                                      Rating
                                      ------
Class     CUSIP       Current    March 2 2010*  Pre-March 2, 2010
-----     -----       -------    -------------  -----------------
II-A-1     25151YAJ8   CC         AAA               AAA/Neg

* As noted above, the rating of II-A-1 should have been lowered to
  'CCC' on this date.

                         Ratings Lowered

    Deutsche Alt-A Securities Mortgage Loan Trust Series 2007-1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        I-A-2      25151YAB5     CC                   CCC
        I-A-3A     25151YAC3     CC                   CCC
        I-A-3B     25151YAD1     CC                   CCC
        I-A-3C     25151YAE9     CC                   CCC
        I-A-4B     25151YAG4     CC                   CCC

                         Ratings Affirmed

    Deutsche Alt-A Securities Mortgage Loan Trust Series 2007-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 I-A-1      25151YAA9     BB+
                 I-A-4A     25151YAF6     BB+


DLJ 1999-CG2: Fitch Upgrades Ratings on Class B-3 Notes
-------------------------------------------------------
Fitch Ratings has upgraded and assigned Loss Severity ratings to
this class of DLJ 1999-CG2, series 1999-C1 commercial mortgage
pass-through certificates:

  -- $20.2 million class B-3 to 'AAA/LS4' from 'AA'; Outlook
     Stable.

Fitch affirms and assigns LS ratings to this class as indicated:

  -- $31 million class B-4 at 'A-/LS4'; Outlook Stable;
  -- $15.5 million class B-5 at 'BBB/LS5'; Outlook Negative.

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

  -- $19.3 million class B-6 to 'CCC/RR1' from 'BB+';
  -- $11.9 million class B-7 to 'D/RR3' from 'B'.

Class B-8 remains at 'D/RR6' and has been reduced to zero due to
realized losses.  Classes A-1A, A-1B, A-2, A-3, A-4, B-1, and B-2
have paid in full.  Fitch withdraws the rating of the interest-
only class S.

The rating affirmations reflect the stable performance of the pool
and sufficient credit enhancement to offset Fitch expected losses
following Fitch's analysis which is similar to its recent vintage
fixed-rate commercial mortgage backed security analysis.  Fitch
expects potential losses of 7.55% of the remaining pool balance
from loans in special servicing and loans that are not expected to
refinance at maturity based on Fitch's refinance test.  The Rating
Outlooks reflect the likely direction of any rating changes over
the next one or two years.  As of the June 2010 distribution date
the pool has paid down 93.67% to $98.1 million from $1.5 billion
at issuance.  Of the original 343 loans, 39 remain in the
transaction.  Fitch has identified 16 Loans of Concern (33.46%),
including eight loans in special servicing (22.6%), as well as
other loans with deteriorating performance.

The largest specially serviced loan (4.56%) is collateralized by a
retail property in Houston, TX.  The loan transferred to special
servicing in June 2009 due to a maturity default.  The special
servicer is currently working with the borrower and has postponed
foreclosure.  The second largest specially serviced loan (4.24%)
is secured by a multifamily located in Melbourne, FL.  The asset
transferred to special servicing in June 2009 due to a maturity
default.  Property performance has declined due to decrease in
occupancy and the poor rental market.  The special servicer is
pursuing a deed in lieu.

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
10.5% 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.  Under this scenario, five loans are not expected to
pay off at maturity with three loans incurring a loss when
compared to Fitch's stressed value.


DLJ COMMERCIAL: Fitch Downgrades Ratings on 2000-CKP1 Certs.
------------------------------------------------------------
Fitch Ratings downgrades and assigns or revises Recovery Ratings
for these classes of DLJ Commercial Mortgage Corp.'s commercial
mortgage pass-through certificates, series 2000-CKP1, as
indicated:

  -- $33.9 million class B-4 to 'CCC/RR5' from 'BB+';
  -- $17.7 million class B-5 to 'C/RR5' from 'CCC/RR1'.

Additionally, Fitch affirms and revises Rating Outlooks for these
classes as indicated:

  -- $31.8 million class A-1B at 'AAA/LS2'; Outlook Stable;

  -- $51.6 million class A-2 at 'AAA/LS2'; Outlook Stable;

  -- $58 million class A-3 at 'AAA/LS2'; Outlook Stable;

  -- $16.1 million class A-4 at 'AAA/LS2'; Outlook Stable;

  -- $16.1 million class B-1 at 'AAA/LS5'; Outlook Stable;

  -- $25.8 million class B-2 at 'AA-/LS5'; Outlook to Negative
     from Stable;

  -- $12.9 million class B-3 at 'A-'; Outlook to Negative from
     Stable;

  -- $8.5 million class B-6 at 'D'; Recovery Rating to 'RR6' from
     'RR4';

  -- $0 class B-7 at 'D/RR6'.

Class A-1A has paid in full while the class B-6 and B-7
certificates have been reduced due to realized losses.  In
addition, Fitch does not rate the zero balance B-8, B-9, and C
classes.  Fitch withdraws the rating of the interest only class S.

The downgrades are due to an increase in Fitch expected losses
following Fitch's prospective review of potential stresses and
expected losses associated with specially serviced assets.  Fitch
expects losses of 8.5% of the remaining pool balance,
approximately $23.2 million, from the loans in special servicing
and the loans that are not expected to refinance at maturity based
on Fitch's refinance test.  As of the March 2010 distribution
date, the pool's collateral balance has paid down 18.8% to
$779.1 million from $960 million at issuance.  Fourteen of the
remaining loans have defeased (20.4%).

The downgrades on classes B-3, B-4, and B-5 are due to Fitch
expected losses on loans currently with the special servicer.  The
Negative Outlooks reflect Fitch's expected losses on the 23 loans
(23.7%) in special servicing as well as concerns on an additional
17 loans (25%) identified by Fitch as Loans of Concern, in
addition to the high concentration of maturity over the next 60
days.  As of the July 2010 distribution date, the pool has been
reduced by 78.9% to $272.5 million from $1.29 billion at issuance.
In addition, seven loans (12.3%) have defeased.

The largest specially serviced loan (2.8%) is secured by a retail
property located in Streetsboro, OH.  The loan transferred to the
special servicer in June 2010 due to pending maturity and the
borrower has been unable to secure takeout financing.  The
borrower is currently negotiating with the special servicer for a
loan extension.  As of the July 2010 distribution date, the loan
was payment current with the subject property displaying occupancy
of 89% with a debt service coverage ratio of 1.13 times.  Fitch
expects losses on this loan.

The second largest specially serviced loan (1.97%) is secured by
an industrial/flex facility located in St. Joseph, MO.  The
borrower is currently negotiating with the special servicer for an
extension while marketing the property for sale.  According to the
special servicer, an interested party has offered to by the
property and the offer is being considered.  As of December 2009,
servicer-reported occupancy was 100% with a DSCR of 1.68x.

The largest Fitch Loan of Concern (4.6%) is secured by a 382 unit
multifamily property located in Roseville, MI.  The loan is
payment current and as of the April 2010 rent roll the property is
82% occupied with a DSCR of 0.80x.

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
10.5% 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 1.25x or higher were considered to payoff at
maturity.  Under this scenario, 10 loans are not expected to
payoff at maturity with seven loans incurring a loss when compared
to Fitch's stressed value.


EATON VANCE: Moody's Downgrades Ratings on Class A to 'Ca'
----------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of these notes issued by Eaton Vance CDO II, Ltd.:

  -- US$286,600,000 Class A Floating Rate Notes Due 2012 (current
     balance of $3,338,965), Downgraded to Ca; previously on
     October 23, 2009 Downgraded to Caa3.

According to Moody's, the rating action taken on the notes
reflects the credit quality of the underlying portfolio, which
consists of one performing security rated Ca with a $2,709,759
notional.  Any material change to the remaining security will have
a significant impact on the rated notes.  Moody's believes that
there is a significant likelihood that the issuer will default on
its obligation to repay the current outstanding balance of the
notes at their maturity, and that such a default will result in
losses to holders of the notes consistent with a Ca rating.

Eaton Vance CDO II, Ltd., issued on June 15, 2000, is a
collateralized bond obligation backed primarily by a portfolio of
senior unsecured bonds.


EQUUS CAPITAL: S&P Downgrades Rating on Class B Notes to 'D'
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D' on
the class B notes issued by Equus Capital Funding Ltd., a
corporate collateralized bond obligation transaction.

The downgrade follows notification from the trustee that the
proceeds from the sale of the collateral were not sufficient to
pay the noteholders in full.

                          Rating Lowered

                    Equus Capital Funding Ltd.

                                      Rating
                                      ------
               Class               To          From
               -----               --          ----
               B                   D           CC


FAIRFAX FINANCIAL: Fitch Assigns 'BB' Rating on Series G Shares
---------------------------------------------------------------
Fitch Ratings has assigned a 'BB' rating to Fairfax Financial
Holdings Limited's new CDN$250 million issue of cumulative five-
year rate reset preferred shares, series G.  The ratings of
Fairfax's holding companies and insurance company subsidiaries are
not affected by this action.  The Rating Outlook is Stable.

Fairfax intends to use the net proceeds to augment its cash
position, to increase short-term investments and marketable
securities held at the holding company level, to retire
outstanding debt and other corporate obligations from time to
time, and for general corporate purposes.  Fitch has assigned a
class D designation to the preferred shares that allocates 75% of
the principal to adjusted equity in evaluating financial leverage.

Fairfax's equity credit adjusted debt-to-total-capital ratio was
22.5% at March 31, 2010, down from 23.5% at Dec. 31, 2009.  Pro
forma for the preferred share issuance, the CDN$275 senior note
issuance in June 2010, and the Zenith National Insurance Corp
(Zenith) transaction completed in May 2010, equity credit adjusted
debt-to-total capital was about 24.5% at March 31, 2010, below
Fitch's expected range of 25%-30%.  Earnings-based interest
coverage (excluding realized gains) improved to 2.6 times in 2009
from 0.2x in 2008.  Fairfax also continues to maintain a sizable
amount of holding company cash, short-term investments and
marketable securities of $1.7 billion on March 31, 2010, with
approximately $1 billion following the acquisition of Zenith.

Fitch assigns this rating with a Stable Outlook:

Fairfax

  -- CDN$250 million series G preferred shares at 'BB'.

Fitch currently rates Fairfax and subsidiaries:

Fairfax

  -- Issuer Default Rating 'BBB';
  -- Senior debt 'BBB-';
  -- $181 million 7.75% due April 15, 2012 'BBB-';
  -- $91 million 8.25% due Oct. 1, 2015 'BBB-';
  -- $283 million 7.75% due June 15, 2017 'BBB-';
  -- $144 million 7.375% due April 15, 2018 'BBB-';
  -- CDN$400 million 7.5% due Aug. 19, 2019 'BBB-';
  -- CDN$275 million 7.25% due June 22, 2020 'BBB-'.
  -- $92 million 8.3% due April 15, 2026 'BBB-';
  -- $91 million 7.75% due July 15, 2037 'BBB-';
  -- CDN$250 million series C preferred shares 'BB';
  -- CDN$200 million series E preferred shares 'BB'.

Fairfax, Inc.

  -- IDR 'BBB'.

Crum & Forster Holdings Corp.

  -- IDR 'BBB'.
  -- $330 million 7.75% due May 1, 2017 'BBB-'.

Crum & Forster Insurance Group:
Crum and Forster Insurance Company
Crum & Forster Indemnity Company
The North River Insurance Company
United States Fire Insurance Company

  -- Insurer Financial Strength 'A-'.

Northbridge Financial Insurance Group:
Commonwealth Insurance Company
Commonwealth Insurance Company of America
Federated Insurance Company of Canada
Lombard General Insurance Company of Canada
Lombard Insurance Company
Markel Insurance Company of Canada
Zenith Insurance Company (Canada)

  -- IFS 'A-'.

Odyssey Re Holdings Corp.

  -- IDR 'BBB';
  -- $50 million series A unsecured due March 15, 2021 'BBB-';
  -- $50 million series B unsecured due March 15, 2016 'BBB-';
  -- $40 million series C unsecured due Dec. 15, 2021 'BBB-';
  -- $225 million 7.65% due Nov.  1, 2013 'BBB-';
  -- $125 million 6.875% due May 1, 2015 'BBB-';
  -- $50 million series A preferred shares 'BB';
  -- $30 million series B preferred shares 'BB'.

Odyssey America Reinsurance Corp.

  -- IFS 'A-'.

Zenith National Insurance Corp.

  -- IDR 'BBB'.

Zenith National Insurance Capital Trust I

  -- $58.5 million 8.55% trust preferred securities due Aug. 1,
     2028 'BB'.

Zenith Insurance Company
ZNAT Insurance Company

  -- IFS 'A-'.

The Rating Outlook is Stable.


FORD AUTO: Moody's Assigns Rating on Series 2010-L2 Fixed Notes
---------------------------------------------------------------
Moody's Investors Service has assigned a Long Term rating to the
Series 2010-L2 fixed notes issued by Ford Auto Lease Trust.  The
notes are collateralized by auto leases and the underlying leased
vehicles, originated and serviced by Ford Credit Canada Limited, a
subsidiary of Ford Motor Credit Company LLC (Ba3 stable).

The complete rating action for Series 2010-L2 is:

Issuer: Ford Auto Lease Trust

* CAN$240,000,000, Fixed rate asset-backed notes, rated Aaa

The ratings are based primarily on an analysis of the credit
quality and base residual values of the collateral pool, the
historical performance of this sponsors residual values, the
servicing ability of Ford Credit Canada, and the level of credit
enhancement available.


FORT POINT: Fitch Downgrades Ratings on Five Classes of Notes
-------------------------------------------------------------
Fitch Ratings has downgraded and withdrawn the ratings on five
classes of notes issued by Fort Point CDO II, Ltd./Corp.

This rating action is a result of the sale and liquidation of Fort
Point II's portfolio following an event of default on Nov. 19,
2009, declaration of acceleration on April 27, 2010, and notice of
a direction to sell and liquidate the collateral by the requisite
noteholders on June 1, 2010.  The sale of collateral was completed
and the final distribution date was on July 16, 2010.  Proceeds
from the sale were insufficient to repay the entire outstanding
balance of the class A-1 notes.  The class A-2 and A-3 notes
received payments of interest, but no principal distributions.

Fort Point II was a collateralized debt obligation that closed on
Oct. 16, 2003, and was managed by BlackRock Financial Management.
The portfolio referenced residential mortgage-backed securities,
commercial mortgage-backed securities, corporate CDOs, various
asset-backed securities, and senior unsecured debt issued by real
estate investment trusts.

Fitch has downgraded and withdrawn these ratings:

  -- $108,640,833 class A-1 notes to 'D' from 'C' and withdrawn;
  -- $60,000,000 class A-2 notes to 'D' from 'C' and withdrawn;
  -- $38,750,000 class A-3 notes to 'D' from 'C' and withdrawn;
  -- $13,669,285 class B notes to 'D' from 'C' and withdrawn;
  -- $14,012,156 class C notes to 'D' from 'C' and withdrawn.


FORT POINT: S&P Downgrades Rating on Five Classes to 'D'
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D' on
five classes of notes from Fort Point CDO II Ltd., a cash flow
collateralized debt obligation transaction, following the
liquidation of the collateral in the portfolio.

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

The deal had triggered an event of default maturity of the notes
and liquidate the collateral assets.

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

                          Rating Actions

                      Fort Point CDO II Ltd.

                                    Rating
                                    ------
                  Class           To        From
                  -----           --        ----
                  A-1             D         CC
                  A-2             D         CC
                  A-3             D         CC
                  B               D         CC
                  C               D         CC


GALAXY CLO: Moody's Upgrades Ratings on Various Classes of Notes
----------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Galaxy CLO 2003-1, Ltd.:

  -- US$232,500,000 Class A Floating Rate Notes, Due 2016 (current
     outstanding balance of $127,830,636), Upgraded to Aa1;
     previously on June 30, 2009 Downgraded to Aa3;

  -- US$13,500,000 Class B Floating Rate Notes, Due 2016, Upgraded
     to A3; previously on June 30, 2009 Downgraded to Ba1;

  -- US$9,500,000 Class C-1 Deferrable Floating Rate Note s, Due
     2016, Upgraded to B2; previously on June 30, 2009 Downgraded
     to Caa1;

  -- US$14,500,000 Class C-2 Deferrable Fixed Rate Notes, Due
     2016, Upgraded to B2; previously on June 30, 2009 Downgraded
     to Caa1;

  -- US$17,000,000 Class 1 Combination Securities (current rated
     balance of $14,629,626), Upgraded to B2; previously on
     June 30, 2009 Downgraded to B3.

According to Moody's, the rating actions taken on the notes result
primarily from delevering of the Class A Notes since the last
rating action, which led to increases in the overcollateralization
levels of the notes.

Since the last rating action on June 30, 2009, the Class A
Notes have been paid down by approximately $100 million, or
roughly 44% of their outstanding balance reported in June
2009.  Moody's expects delevering to continue as a result of
the end of the deal's reinvestment period in January 2009.  As
a result of the delevering, the overcollateralization ratios
have increased since the last rating action.  Based on the
latest trustee report dated July 2, 2010, the Class A, Class B
and Class C overcollateralization ratios increased to 133.1%,
122% and 106.1% respectively, compared to June 2009 levels of
117%, 110.5% and 100.5% respectively.  Moody's notes that the
reported July overcollateralization levels do not reflect the
principal payment of $19.5 million which was made to the Class A
Notes on the July 15, 2010 payment date.

Moody's also notes that the credit quality of the portfolio has
stabilized since the last rating action, evidenced through stable
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.  As of the latest trustee report,
dated July 2, 2010, the weighted average rating factor is 2981
compared to 2982 in June 2009, and securities rated Caa1 or lower
make up approximately 12% of the underlying portfolio versus
approximately 15.3% in June 2009.  Additionally, defaulted
securities have been reduced to about $1.5 million from
$20.3 million in June 2009.  Due to the impact of revised and
updated key assumptions referenced in "Moody's Approach to Rating
Collateralized Loan Obligations" and "Annual Sector Review (2009):
Global CLOs," key model inputs used by Moody's in its analysis,
such as par, weighted average rating factor, diversity score, and
weighted average recovery rate, may be different from the
trustee's reported numbers.

Galaxy CLO 2003-1, Ltd., issued in January of 2004, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.


INDYMAC INDX: Moody's Junks Rating on Class A2-B Notes From 'B1'
----------------------------------------------------------------
Moody's Investors Service has downgraded the rating of one tranche
issued by IndyMac INDX Mortgage Loan Trust 2006-AR8.  The
collateral backing the transaction consists of option arm loans
originated by IndyMAC Bank F.S.B.

The downgrade is driven by a small loss of $29,315 allocated to
the A2-B and balance of loans delinquent 60 days or more,
including loans in foreclosure and real estate owned, compared to
the credit enhancement provided by subordination and excess
spread.  The Class A2-B remains on review for possible downgrade
as Moody's completes its review of this transaction.

Moody's generally rates securities Caa1 or lower if it has a very
high likelihood of taking a loss in the expected case.

Complete rating actions are:

Issuer: IndyMac INDX Mortgage Loan Trust 2006-AR8

  -- Cl. A2-B, Downgraded to Caa1 and Remains On Review for
     Possible Downgrade; previously on Jan. 27, 2010 B1 Placed
     Under Review for Possible Downgrade


JP MORGAN: Fitch Affirms Ratings on Various 2000-C10 Certs.
-----------------------------------------------------------
Fitch Ratings affirms and assigns Loss Severity ratings to these
JP Morgan Commercial Mortgage Finance Corp., series 2000-C10
commercial mortgage pass-through certificates:

  -- $608,423 class B at 'AAA/LS4'; Outlook Stable;
  -- $29.5 million class C at 'AAA/LS4'; Outlook Stable;
  -- $9.2 million class D at 'AAA/LS4'; Outlook Stable;
  -- $23.1 million class E at 'AAA/LS4'; Outlook Stable;
  -- $10.1 million class F at 'AAA/LS5'; Outlook Negative.

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

  -- $14.7 million class G to 'CCC/RR1' from 'A';
  -- $14.7 million class H to 'CC/RR1' from 'BBB-';
  -- $7.3 million class J to 'C/RR3' from 'BB-';
  -- $5.5 million class K to 'C/RR5' from 'B+';
  -- $2.4 million class L to 'D/RR5' from 'B-'.

Class M remains at 'D/RR5' and has been reduced to zero due to
realized losses.  Classes A1 and A2, have paid in full.  Fitch
withdraws the rating of the interest only class X.

The rating affirmations reflect the stable performance of the pool
and sufficient credit enhancement to offset Fitch expected losses
following Fitch's analysis which is similar to its recent vintage
fixed-rate CMBS analysis.  Fitch expects potential losses of
22.66% of the remaining pool balance from loans in special
servicing and loans that are not expected to refinance at maturity
based on Fitch's refinance test.  The Rating Outlooks reflect the
likely direction of any rating changes over the next one or two
years.  As of the June 2010 distribution date the pool has paid
down 84.09% to $117.5 million from $738 million at issuance.  Of
the original 168 loans, 28 remain in the transaction.  Fitch has
identified 14 Loans of Concern (58.05%), including 12 loans in
special servicing (63.5%), as well as other loans with
deteriorating performance.

The largest specially serviced loan (15.72%) is collateralized by
a retail property in Martinsville, VA.  The loan transferred to
special servicing in December 2009 due to imminent default.  The
deed-in-lieu documents are being negotiated.  The servicer
initiated the springing lockbox account so all cash flow is now
being captured by the noteholder.  The second largest specially
serviced loan (13.67%) is secured by an office property located in
Des Moines, IA.  The asset transferred to special servicing in
October 2008 for imminent default after the borrower requested a
loan modification of the loan terms due to a loss of a major
tenant.

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
10.5% 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.  Under this scenario, five loans are not expected to
pay off at maturity with three loans incurring a loss when
compared to Fitch's stressed value.


JP MORGAN: Fitch Downgrades Ratings on 2001-CIBC1 Certificates
--------------------------------------------------------------
Fitch Ratings downgrades, assigns Rating Outlooks and Recovery
Ratings to two classes of J.P. Morgan Chase Commercial Mortgage
Securities Corp.'s commercial mortgage pass-through certificates,
series 2001-CIBC1:

  -- $10.1 million class H to 'CCC/RR1' from 'BB+';
  -- $7.6 million class J to 'C/RR5' from 'BB-'.

In addition, Fitch affirms and assigns Outlooks and Loss Severity
ratings:

  -- $452.5million class A-3 at 'AAA/LS-1'; Outlook Stable;
  -- $43.1 million class B at 'AAA/LS3'; Outlook Stable;
  -- $40.6 million class C at 'AAA/LS3'; Outlook Stable;
  -- $12.7 million class D at 'AAA/LS5'; Outlook Stable;
  -- $25.4 million class E at 'AAA/LS4'; Outlook Stable;
  -- $14 million class F at 'AA-/LS5'; Outlook Stable;
  -- $29.2 million class G at 'BBB/LS4'; Outlook Negative;
  -- $9 million class K at 'D/RR6'.

Fitch withdraws the rating of the interest only class X-1.

Classes L and M remain at 'D/RR6' due to realized losses.  The
downgrade is the result of Fitch's revised loss estimates for the
transaction following Fitch's prospective analysis which is
similar to its recent vintage fixed-rate CMBS analysis.  Fitch
expects potential losses of 2.2% of the remaining pool balance,
approximately $14.2 million, the majority of which are from the
loans in special servicing, in addition to the loans that are not
expected to refinance at maturity based on Fitch's refinance test.

As of the July 2010 distribution date, the transaction paid down
36.5% to $644.2 million from $1.01 billion at issuance.  In total,
52% of the pool has defeased, including the three largest loans
(15%) in the transaction.  Approximately 5.7% of the performing
loans will mature in 2010 and 2.3% in 2011.

Fitch has identified 14% of the transaction as Fitch Loans of
Concern, including loans currently in special servicing (4.2%).
The largest Fitch Loan of Concern (3.3%) is the fifth largest loan
and is collateralized by a retail center in Wallkill, NY.  The
loan reported a year end 2009 debt service coverage ratio (DSCR)
of 0.89 times (x) with an occupancy rate of 91%.

The largest specially serviced asset (2.2%) is secured by a
290,413 square foot retail property located in Richmond, KY.  The
asset transferred in March 2009 due to imminent default and is
currently undergoing renovations to reposition the property.

The second specially serviced asset (0.75%) is a 63,059 square
foot anchored retail center located in Tupelo, MS.  The anchor
space is currently vacant and the largest tenant is Old Navy
representing 39% of the NRA.  The asset was transferred in January
2010 due to imminent monetary default and the special servicer is
pursuing foreclosure.

Fitch stressed the cash flow of the remaining non-defeased loans
by applying a 10% reduction to 2008 fiscal year end net operating
income or adjusted 2009 cash flow based on performance issues,
such as a significant decline in occupancy, and applying an
adjusted market cap rate between 7.25% and 10.5% 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 ratios of 1.25 times or higher were considered to pay off
at maturity.  Under this scenario, one loan is not expected to pay
off at maturity and incur a loss when compared to Fitch's stressed
value.


KEYCORP STUDENT: Moody's Reviews Ratings on 18 Classes of Notes
---------------------------------------------------------------
Moody's Investors Service has placed under review for possible
downgrade eighteen classes of notes in eight KeyCorp Student Loan
trusts.  The actions were prompted by higher than expected losses
and, in the case of KeyCorp Student Loan trusts 2004A, 2005A, and
2006A Group II transactions, a significant decline in total
parity, i.e. the ratio of total assets to total liabilities.  The
underlying collateral for these transactions includes loans
originated under the Federal Family Education Loan Program and
private student loans.  For transactions that closed after 2000,
the FFELP and the private student loan collateral is separated
into Group I and Group II, respectively, with each group having
independent reserve accounts and payment waterfalls, and a limited
overcollateralization between the two groups, wherein the residual
cash flow in each group can be used to cover any payment
shortfalls in the other group.

Taking into account the current seasoning of the pools, Moody's
concluded that the current cumulative defaults, defined as
accounts at or exceeding 180 days past due, are likely to exceed
Moody's previous expectations.  In addition, the higher than
expected defaults in the Keycorp Student Loan Trust 2004-A, 2005-
A, and 2006-A Group II have resulted in declines in total parity
to the levels of substantially less than 100%.  As of the most
recent reporting date, total parity was 93.2%, 99.2%, and 98.8%
for the KeyCorp Student Loan Trust 2004-A, 2005-A, and 2006A Group
II transactions, respectively.

During the review period, Moody's will update the expected net
losses and assess whether the available credit enhancement, which
includes the reserve accounts, subordination, and excess spread,
is sufficient to support the current ratings of the affected
classes of notes.

Primary sources of uncertainty with respect the expected losses
and recoveries on the loans backing these transactions relate to
the uncertainty within the economic environment.  Specifically,
the significantly high unemployment rate can adversely affect the
income-generating abilities of the borrowers, and thus hinder
their ability to repay their outstanding debt.

The complete rating actions are:

Issuer: KeyCorp Student Loan Trust 1999-A

  -- Certificates, A1 Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 1999 Assigned A1

Issuer: KeyCorp Student Loan Trust 2000-A

  -- Class A-2, Aa2 Placed Under Review for Possible Downgrade;
     previously on Nov. 16, 2008 Upgraded to Aa2

Issuer: KeyCorp Student Loan Trust 2000-B

  -- Class A-2, Aa2 Placed Under Review for Possible Downgrade;
     previously on Nov. 16, 2008 Upgraded to Aa2

Issuer: KeyCorp Student Loan Trust 2001-A

  -- Class II-A-2, Aa2 Placed Under Review for Possible Downgrade;
     previously on Nov. 16, 2008 Upgraded to Aa2

Issuer: KeyCorp Student Loan Trust 2003-A

  -- Cl. II-A-3, Aaa Placed Under Review for Possible Downgrade;
     previously on Aug 21, 2003 Assigned Aaa

  -- Cl. II-A-IO, Aaa Placed Under Review for Possible Downgrade;
     previously on Aug 21, 2003 Assigned Aaa

  -- Cl. II-B, A3 Placed Under Review for Possible Downgrade;
     previously on Nov. 16, 2008 Downgraded to A3

Issuer: KeyCorp Student Loan Trust 2004-A

  -- Class II-A-2, Aaa Placed Under Review for Possible Downgrade;
     previously on April 20, 2009 Confirmed at Aaa

  -- Class II-B, Aa3 Placed Under Review for Possible Downgrade;
     previously on April 20, 2009 Downgraded to Aa3

  -- Class II-C, Baa3 Placed Under Review for Possible Downgrade;
     previously on April 20, 2009 Downgraded to Baa3

  -- Class II-D, B2 Placed Under Review for Possible Downgrade;
     previously on April 20, 2009 Downgraded to B2

Issuer: KeyCorp Student Loan Trust 2005-A

  -- Cl. II-A-4, Aaa Placed Under Review for Possible Downgrade;
     previously on April 20, 2009 Confirmed at Aaa

  -- Cl. II-B, A2 Placed Under Review for Possible Downgrade;
     previously on April 20, 2009 Confirmed at A2

  -- Cl. II-C, Ba3 Placed Under Review for Possible Downgrade;
     previously on April 20, 2009 Downgraded to Ba3

Issuer: KeyCorp Student Loan Trust 2006-A

  -- Cl. II-A-3, Aaa Placed Under Review for Possible Downgrade;
     previously on Dec 8, 2006 Definitive Rating Assigned Aaa

  -- Cl. II-A-4, Aa1 Placed Under Review for Possible Downgrade;
     previously on April 20, 2009 Downgraded to Aa1

  -- Cl. II-B, Baa2 Placed Under Review for Possible Downgrade;
     previously on April 20, 2009 Downgraded to Baa2

  -- Cl. II-C, B1 Placed Under Review for Possible Downgrade;
     previously on April 20, 2009 Downgraded to B1


L2L EDUCATION: S&P Puts Note Ratings on CreditWatch Negative
------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on the class
A-2, A-3, B, and C notes from L2L Education Loan Trust 2006-1 on
CreditWatch with negative implications.

The CreditWatch placements reflect S&P's view of the level of
cumulative gross defaults in the underlying pool of private
student loans, which is approaching its revised base-case
cumulative lifetime gross defaults of 16%-17%.  As of the
collection period ended June 2010, with approximately 63.0% of the
pool's initial asset balance (principal balance plus the initial
deposit into the prefunding account) still outstanding, the
transaction had experienced cumulative gross defaults amounting to
15.39% of the initial asset balance.  Defaults have increased
61.0% over the past two years and have more than doubled from
6.92% in December 2007 (the latest data point available at the
time of S&P's last downgrade in early 2008).  In addition, despite
a 43-basis-point improvement since May 2009, total parity (the
total asset balance excluding the reserve account over the total
balance of notes outstanding) remains almost five percentage
points below the starting parity of 99.0% at issuance (at 94.08%
as of June 2010).

Given the effects of the economic landscape and the state of the
job market, S&P believes that student loan default rates will
likely continue to rise in the remainder of 2010.  As a result,
S&P expects the collateral performance of private student loans,
including those underlying the L2L Education Loan Trust 2006-1
transaction, to remain under pressure.

Standard & Poor's will continue its review of the credit
performance of the underlying private student loans over the
course of the next 90 days, as well as the available credit
enhancement associated with the ratings S&P placed on CreditWatch,
and will take any rating actions that are consistent with S&P's
criteria.

              Ratings Placed On Creditwatch Negative

                  L2L Education Loan Trust 2006-1

                                Rating
                                ------
                Class     To                  From
                -----     --                  ----
                A-2       AA-/Watch Neg       AA-
                A-3       AA-/Watch Neg       AA-
                B         BBB/Watch Neg       BBB
                C         B+/Watch Neg        B+


LB COMMERCIAL: Fitch Affirms 'D/RR2' Rating on Certificates
-----------------------------------------------------------
Fitch Ratings affirms and assigns a Recovery Rating to LB
Commercial Conduit Trust Multiclass Pass-Through Certificates,
series 1995-C2, as indicated:

  -- $3.5 million class F at 'D/RR2'.

Classes A, IO, B, C, D, and E have paid in full.  Fitch does not
rate class G.

The certificate is collateralized by two fixed rate mortgage
loans, which Fitch considers Loans of Concern.  As of the July
2010 distribution date, the pool's collateral balance has been
reduced by 98.7% to $3.5 million from $259.9 million at issuance.

The larger of the two loans, representing 64.2% of the pool, is
secured by a limited service hotel in Kissimmee, FL.  The hotel is
located on a heavily traveled highway in a high tourist area with
a lot of foot traffic and mass transit.  It is within minutes from
Walt Disney World.  The property has experienced a decline in
income which the borrower is supplementing to cover the debt
service and plans to continue doing so.

The second loan represents 35.8% of the pool and is also secured
by a limited service hotel.  It is located in Landover, MD and
suffers from several deferred maintenance issues.  Occupancy as of
March 2010 is approximately 5% below the market vacancy rate.

Fitch stressed the cash flow of the a 10% reduction to 2008 fiscal
year end net operating income and applying an adjusted market cap
rate of 10% to determine value.  Fitch does not expect any losses
on the loans.

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.  Under this scenario, both loans are expected to
payoff at maturity, and neither loan is expected to incur a loss
when compared to Fitch's stressed value.


LB COMMERCIAL: Fitch Downgrades Ratings on 1998-C1 Certs.
---------------------------------------------------------
Fitch Ratings downgrades and assigns Recovery Ratings to LB
Commercial Mortgage Trust's commercial mortgage pass-through
certificates, series 1998-C1:

  -- $43.2 million class J to 'CCC/RR1' from 'B'.

Additionally, Fitch affirms and assigns Rating Outlooks, Loss
Severity and Recovery Ratings as indicated below:

  -- $25 million class D at 'AAA'; Outlook Stable;

  -- $34.6 million class E at 'AAA'; Outlook Stable;

  -- $51.8 million class F at 'AAA'; Outlook Stable;

  -- $34.6 million class G at 'AA+'; Outlook Stable;

  -- $17.3 million class H at 'A/LS4'; Outlook to Negative from
     Stable;

  -- $17.3 million class K at 'C/RR4';

  -- $14 million class L at 'D/RR6'.

Fitch does not rate the $3.8 million class M certificates.
Classes A-1, A-2, A-3, B, and C have paid in full.

Fitch withdraws the rating of the interest only class IO.

The downgrades are due to an increase in Fitch expected losses
following Fitch's prospective review of potential stresses and
expected losses associated with specially serviced assets.  Fitch
expects losses of 8.62% of the remaining pool balance,
approximately $20.5 million, from the loans in special servicing
and the loans that are not expected to 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 July 2010 distribution date, the collateral balance has
been reduced 86.2% to $237.8 million, from $1.73 billion at
issuance.  In total, eight loans have defeased, seven of which
remain in the pool (10.5%).  Seven loans mature in 2012 (12.1%)
and 11 loans mature in 2013 (38.2%).  Loans collateralized by
retail properties represent 62% of the pool.

Four assets (11%) are currently in special servicing, two of which
(2.7%) transferred subsequent to the last Fitch rating action.
The largest specially serviced asset (5.8%) is a retail center in
Kansas City, MO that is real estate owned by the lender.  As of
May 31, 2010, occupancy for the property stood at 31%.  The
property is being marketed for sale.

The second largest specially serviced asset (2.4%) is secured by
two hotel properties.  The first is a 130-room hotel in Dayton, OH
and the second is a 129-room hotel in Englewood, OH.  As of
March 31, 2010, the borrower reported average occupancy was
29.53%.  The hotel in Dayton lost its flag as of June 2010 and is
presently operating as an unaffiliated entity.  The lender
accepted a modification agreement which allows the borrower
additional time to sell the property.

Fitch loans of concern total 20.8% of the collateral balance and
include the four specially serviced assets (11%).  The largest
Fitch loan of concern which is not specially serviced (4.1%) is
secured by nine mixed-use complexes located in Rockland County,
NY.  According to the servicer, the borrower has not provided
recent financial information or occupancy.  Per the servicer's
inspection report, one property, representing 17% of the gross
leasable area securing the loan, is vacant.  In light of
uncertainty associated with this loan, Fitch applied an additional
stress to the property's cash flow.  As of Dec. 31, 2007, the
borrower reported 100% occupancy and a debt service coverage ratio
of 0.86 times.  The loan is presently current and is scheduled to
mature in 2017.

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
11.25% 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.  Fitch considered loans that could refinance
to a debt service coverage ratio of 1.25x or higher to payoff at
maturity.  Under this scenario, five loans are not expected to
payoff at maturity with three loans incurring a loss when compared
to Fitch's stressed value.


LIBERTY SQUARE: Moody's Upgrades Ratings on Various Notes
---------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Liberty Square CDO I, Ltd.:

  -- US$311,750,000 Class A Floating Rate Notes due 2013(current
     balance of $25,800,992), Upgraded to Aaa; previously on May
     15, 2009 Downgraded to Aa2;

  -- US$41,250,000 Class B Floating Rate Notes due 2013, Upgraded
     to Aa3; previously on May 15, 2009 Downgraded to Ba1;

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 notes due to delevering since the last rating action in May
2009.

Moody's notes that the notes benefited from the substantial
delevering of the Class A Notes, which have been paid down by
approximately $90MM since the last rating action, accounting for
roughly 78% of the total Class A Notes' outstanding balance
reported in April 2009.  As a result of the delevering, the
overcollateralization ratios have increased significantly since
the rating action in May 2009.  In particular, based on the
trustee report, dated June 7, 2010, the Class AB
overcollateralization ratio was reported at 150.9% versus the
April 2009 level of 123.7%.  A substantial proportion of the
delevering is attributable to collateral sales and principal
prepayments on the underlying bonds.  In addition, the Class AB
overcollateralization ratio has also increased due to the
diversion of excess interest to delever the Class A Notes as a
result of the Class C and Class D overcollateralization test
failures.  Based on the June 2010 report, the Class C
overcollateralization ratio was reported at 89.68% versus a test
level of 105.5% and the Class D overcollateralization ratio was
reported at 80.48% versus a test level of 102.5%.  Moody's expects
delevering to continue as a result of the end of the deal's
reinvestment period in April 2006 and continued diversion of
excess interest to cure the Class C and Class D
overcollateralization test failures.

Improvement in the credit quality is observed through an
improvement in the average credit rating (as measured by the
weighted average rating factor).  As of the latest trustee report,
dated June 7, 2010, the weighted average rating factor is 2337
compared to 3490 in April 2009.  The improvement in WARF is
primarily a result of rating upgrades on several obligors with
large positions in the underlying portfolio.  Additionally, the
dollar amount of defaulted securities has decreased from $19.2MM
to $13.9MM since the last rating action.  Due to the impact of
revised and updated key assumptions referenced in "Moody's
Approach to Rating Collateralized Loan Obligations" and "Annual
Sector Review (2009): Global CLOs," key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers.

Liberty Square CDO II, Ltd., issued in March 14, 2001, is a
collateralized bond obligation backed primarily by a portfolio of
senior unsecured bonds.


LONE STAR: Moody's Upgrades Class B Notes to 'Ba1' from 'Ba3'
-------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
rating of these notes issued by Lone Star CBO Funding Ltd.:

  -- US$30,400,000 Class B Floating Rate Senior Subordinated Notes
     Due 2012, Upgraded to Ba1; previously on May 11, 2009
     Downgraded to Ba3.

According to Moody's, the rating action taken on the Class B notes
results primarily from significant delevering of the transaction
and increase in the overcollateralization levels of the notes
since the last rating action in May 2009.  Moody's also observes
improvement in the credit quality of the underlying portfolio.

Moody's notes that the Class B notes benefited from the
substantial delevering of the Class A Notes, which have been paid
down by approximately $87MM since the last rating action,
accounting for roughly 60% of the total Class A notes' outstanding
balance reported in April 2009.  As a result of the delevering,
the overcollateralization ratios have increased since the rating
action in May 2009.  In particular, based on the trustee report,
dated July 15, 2010, the Senior Principal Coverage Test and Senior
Subordinate Principal Coverage Test are reported at 155.1% and
102.9%, respectively, versus the April 2009 levels of 123.3% and
102.1%, respectively, and all related overcollateralization tests
are currently in compliance .  Moody's expects delevering to
continue as a result of the end of the deal's reinvestment period
in October 2004.

Improvement in the credit quality is observed through an
improvement in the average credit rating (as measured by the
weighted average rating factor).  As of the latest trustee report,
dated July 15, 2010, the weighted average rating factor is 931
compared to 1380 in April 2009 and securities rated Caa1 or lower
make up approximately 5.8% of the underlying portfolio versus
11.8% in April 2009.  Additionally, the dollar amount of defaulted
securities has remained stable since the last rating action.  Due
to the impact of revised and updated key assumptions referenced in
"Moody's Approach to Rating Collateralized Loan Obligations" and
"Annual Sector Review (2009): Global CLOs," key model inputs used
by Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers.

Lone Star CBO Funding Ltd. issued on December 14, 2000, is a
collateralized bond obligation backed primarily by a portfolio of
senior unsecured bonds.


MANUFACTURED HOUSING: S&P Corrects Ratings on Three Certs. to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services corrected its ratings to 'D' on
three classes of certificates issued from Manufactured Housing
Contract Senior-Sub Pass-Thru Trust's series 1999-1, 1999-3, and
2002-2.

Higher-than-expected defaults caused interest shortfalls on the
certificates.  Due to an error, S&P's rating actions on these
classes did not occur contemporaneously with the interest payment
shortfalls.

                        Ratings Corrected

    Manufactured Housing Contract Sr/Sub Pass-Thru Trust 1999-1

                  Rating
                  ------
     Class     To        From    Date Int. Shortfall Occurred
     -----     --        ----    ----------------------------
     M-2       D         CCC-    9/1/2009

    Manufactured Housing Contract Sr/Sub Pass-Thru Trust 1999-3

                  Rating
                  ------
     Class     To        From    Date Int. Shortfall Occurred
     -----     --        ----    ----------------------------
     M-1       D         CCC-    12/1/2009

    Manufactured Housing Contract Sr/Sub Pass-Through Certificates
                          Series 2002-2

                  Rating
                  ------
     Class     To        From    Date Int. Shortfall Occurred
     -----     --        ----    ----------------------------
     B-1       D         CCC-    1/2/2008


MERRILL LYNCH: Fitch Downgrades Ratings on 1998-C1-CTL Certs.
-------------------------------------------------------------
Fitch Ratings downgrades Merrill Lynch Mortgage Trust commercial
mortgage pass-through certificates, series 1998-C1-CTL:

  -- $58.1 million class F to 'C/RR4; from 'CC/RR4';
  -- $1.9 million class G to 'D/RR6' from 'C/RR6'.

Class H, which has been reduced to zero due to losses, remains
'D/RR6'.

Fitch does not rate the class A-1, A-2, A-3, A-IO, A-PO, B, C, D,
or E certificates.  Classes J and K have also been reduced to zero
due to realized losses.  The rating of class J was withdrawn in
December 2004 due to losses.


The downgrades are due to Fitch expected losses on six loans
(7.1%) that had Circuit City as the underlying credit tenant.  On
Jan. 16, 2009, Circuit City announced the liquidation of its
assets.  Fitch's loss assumptions are based on updated valuations
obtained by the special servicer.  Assumed losses were based on
Fitch's projections of values.  The weighted average expected loss
severity on the loans is approximately 74%.

As of the January 2009 distribution date, the pool has paid down
45% to $358.2 million, from $646.1 million at issuance.


MINT 2005-1: DBRS Confirms Series B & C Notes at 'C'
----------------------------------------------------
DBRS has today confirmed the Series A, B and C Notes
(collectively, the Notes) issued by MINT 2005-1 LTD (the
Transaction).  The Series A Note has been confirmed at CC and the
Series B Notes and Series C Notes have been confirmed at C.  Also,
DBRS has discontinued the ratings on the Series C4, Series D and
Series E Notes issued by the Transaction.  The Transaction
consists of customized synthetic investment-grade collateralized
debt obligation (CDO) tranches, with separate credit default swaps
for each series of notes.  Credit enhancement for each series of
notes is provided by subordination from all lower tranches.  For
each series of notes, the scheduled termination of the credit
default swap is June 20, 2012.

On March 26, 2010, a credit event was triggered for Ambac
Assurance Corporation (Ambac).  On July 1, 2010, a final recovery
of 2% was determined.  The credit event resulted in 0.49% of loss
to the Reference Portfolio.  Given the financial stress
experienced by Ambac prior to the credit event, DBRS had been
using a conservative probability of default assumption when
modelling the transaction.  As a result, the credit event does not
have a material impact on the ratings of the Notes, which are
being confirmed today at their current levels.

Prior to the Ambac credit event, the Series D Notes had
experienced a loss of approximately 20% of their original
principal.  The credit event has resulted in 0.49% in loss to the
Transaction's portfolio.  Consequently, the loss to the Series D
Notes principal increased from 20% to 69% of the original amount.

The scheduled maturity of the Notes is June 20, 2012.  DBRS is
actively monitoring the credit quality of the Notes and will
provide further updates as necessary.


MORGAN STANLEY: Fitch Affirms Ratings on 1998-HF2 Certificates
--------------------------------------------------------------
Fitch Ratings affirms, assigns Rating Outlooks and Loss Severity
ratings to Morgan Stanley Capital I Trust 1998-HF2, as indicated
below:

  -- $6.8 million class E at 'AAA/LS1'; Outlook Stable;

  -- $23.8 million class F at 'AAA/LS3'; Outlook Stable;

  -- $18.5 million class G at 'AA/LS4'; Outlook Stable';

  -- $10.6 million class H at 'A/LS4'; Outlook Stable;

  -- $21.2 million class J at 'BBB-/LS4'; Outlook Stable;

  -- $10.6 million class K at 'BB/LS4'; Outlook revised to
     Negative from Stable;

  -- $15.9 million class L at 'CCC/RR1';

  -- $4.2 million class M at 'D/RR6'.

Classes A-1, A-2, B, C, and D have been paid in full.  Fitch
withdraws the rating of the interest only class X.

The affirmations are the result of sufficient credit enhancement
to offset Fitch's revised loss estimates for the transaction
following Fitch's prospective analysis which is similar to its
recent vintage fixed rate commercial mortgage backed security
analysis.  Fitch expects potential losses of 3.6% of the remaining
pool balance, approximately four million, from the loans in
special servicing and the loans that are not expected to refinance
at maturity based on Fitch's refinance test.  The majority of the
expected losses come from the loans in special servicing.
Expected loss as a percentage of the original deal balance is
1.99%.  Rating Outlooks reflect the likely direction of any rating
changes over the next one to two years.

As of the June 2010 distribution date, the pool's collateral
balance has paid down 89.5% to $111.5 million from $1.05 billion
at issuance.

Fitch has identified four Loans of Concern (28.2%), including
three assets in special servicing (26.1%).  Two of the specially
serviced loans transferred April 2010 due to payment default.  The
two loans (10.1%) are related to seven parcels of land, with six
office buildings and one vacant lot within a corporate campus
setting located in Glen Ellyn, IL.  The collateral for the loans
is adjacent to each other and were operated as one property.  As
of Sept.  30, 2009, the servicer reported debt service coverage
ratio and occupancy were approximately 1.17 times and 70%,
respectively.  A receivership motion was granted in June 2010.

The third specially serviced asset (15.9%), is secured by eight
industrial-flex buildings located in Arlington, TX.  The loan
entered special servicing for maturity default in late 2009 and
was modified.  The modification included three options to extend
the term by three month increments.  The loan is currently in its
second extension period, while the loan remains current and at the
special servicer.  As of April 2010, the portfolio was appraised
at approximately $21.8 million.

Fitch stressed the cash flow of the remaining non-defeased loans
by applying a 10% reduction to 2008 fiscal year end net operating
income or adjusted 2009 cash flow and applying an adjusted market
cap rate between 7.25% and 10.5% 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 1.25x or higher were considered to pay off at
maturity.  Under this scenario, all of the loans are expected to
pay off at maturity.


MORGAN STANLEY: Fitch Downgrades Ratings on 18 2005-RR6 Notes
-------------------------------------------------------------
Fitch Ratings has downgraded 18 classes of notes issued by Morgan
Stanley Capital I 2005-RR6 as a result of negative credit
migration to the underlying commercial mortgage backed security
collateral.

Since the last rating action in January 2009, the credit quality
of the portfolio has declined with approximately 15.0% of the
portfolio downgraded.  Approximately 28.4% of the portfolio has a
Fitch derived rating below investment grade with 6.7% having a
rating in the 'CCC' rating category or below, compared to 20.6%
and 1.0%, respectively, at last review.  Currently, six securities
(3.6% of the portfolio) are experiencing interest shortfalls or
deferring interest payments, and are considered distressed.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  In its analysis, Fitch also
considered the structure's sensitivity to the assets that are
experiencing interest shortfalls (3.63%).  The Rating Loss Rates
were then compared to the credit enhancement of the classes.
Based on this analysis, the credit enhancement for the classes A-
2FL, A-2FX, A-3FL, A-3FX, A-J, and class B are generally
consistent with the ratings assigned below.

The Negative Rating Outlook on the notes reflects Fitch's
expectation that underlying CMBS loans will continue to face
refinance risk at maturity.  Fitch also assigned Loss Severity
ratings to the classes A-2FL, A-2FX, A-3FL, A-3FX, and A-J notes.
The LS ratings indicate each tranche's potential loss severity
given default, as evidenced by the ratio of tranche size to the
expected loss for the collateral under the 'B' stress.  The LS
rating should always be considered in conjunction with probability
of default indicated by a class' long-term credit rating.  Fitch
does not assign Rating Outlooks or LS ratings to classes rated
'CCC' or lower.

Classes C through N notes do not pass the 'CCC' stress in the PCM
model.  Therefore, Fitch compared the credit enhancement levels to
the portion of the portfolio considered distressed to determine
the probability of default at or prior to maturity.  Classes C
through G have been downgraded to 'CC', indicating that default is
probable.  Although their credit enhancement levels currently
exceed the total percentage of assets experiencing interest
shortfalls or deferring interest, further deterioration could
quickly erode that cushion.  Classes H through N have been
downgraded to 'C', indicating that default is inevitable given
that the total percentage of assets experiencing interest
shortfalls exceeds the credit enhancement available to each class.

Additionally, Fitch has withdrawn the rating of the interest-only
class X.

MSCI is a static collateralized debt obligation (CDO) that closed
on Oct. 15, 2005.  The current portfolio consists of 76 bonds from
51 CMBS transactions, 7.8% of which were issued between 2003 and
2005 and 92.2% were issued in 2002 and earlier.

Fitch has taken these actions, including assigning LS ratings and
revising Outlooks for these classes as indicated:

  -- $76,360,576 Class A-2FL downgraded to 'A/LS3' from 'AA-';
     Outlook to Negative from Stable;

  -- $81,610,000 Class A-2FX downgraded to 'A/LS3' from 'AA-';
     Outlook to Negative from Stable;

  -- $60,000,000 Class A-3-FL downgraded to 'A/LS3' from 'AA-';
     Outlook to Negative from Stable;

  -- $110,551,000 Class A-3-FX downgraded to 'A/LS3' from 'AA-';
     Outlook to Negative from Stable;

  -- $50,061,000 Class A-J downgraded to 'BB/LS4' from 'BBB+';
     Outlook to Negative from Stable;

  -- Interest-only, class X withdrawn;

  -- $27,498,000 Class B downgraded to 'CCC' from 'BB+';

  -- $14,102,000 Class C downgraded to 'CC' from 'B+';

  -- $2,115,000 Class D downgraded to 'CC' from 'B+';

  -- $8,461,000 Class E downgraded to 'CC' from 'B';

  -- $4,231,000 Class F downgraded to 'CC' from 'B'';

  -- $6,346,000 Class G downgraded to 'CC' from 'B-';

  -- $7,050,000 Class H downgraded to 'C' from 'CCC';

  -- $2,821,000 Class J downgraded to 'C' from 'CCC';

  -- $2,820,000 Class K downgraded to 'C' from 'CCC';

  -- $1,410,000 Class L downgraded to 'C' from 'CCC';

  -- $2,116,000 Class M downgraded to 'C' from 'CCC';

  -- $1,410,000 Class N downgraded to 'C' from 'CCC'.


MORGAN STANLEY: Fitch Upgrades Ratings on 1999-CAM1 Certs.
----------------------------------------------------------
Fitch Ratings upgrades and assigns Outlooks and Loss Severity
ratings to Morgan Stanley Capital I Trust 1999-CAM1 commercial
mortgage pass-through certificates, as indicated:

  -- $14.1 million class G to 'AAA/LS3' from 'AA+', Outlook
     Stable;

  -- $14.1 million class H to 'AA/LS3'from 'A+', Outlook Stable;

In addition, Fitch affirms and assigns Outlooks, LS ratings, and
Recovery Ratings, as indicated:

  -- $4.7 million class E at 'AAA/LS4'; Outlook Stable;
  -- $8 million class F at 'AAA/LS3'; Outlook Stable;
  -- $6 million class J at 'BBB+/LS4'; Outlook Stable;
  -- $8 million class K at 'BBB-/LS3'; Outlook Stable;
  -- $6 million class L at 'BB-/LS4'; Outlook Stable;
  -- $6 million class M at 'CC/RR1';
  -- $791,447 class N at 'D/RR6'.

Classes A-1, A-2, A-3, A-4, B, C, and D have paid in full.  Fitch
does not rate class O.  Fitch withdraws the rating on the interest
only class X.

The certificates are collateralized by 29 mortgage loans, two of
which Fitch considers loans of concern.  As of the July 2010
distribution date, the pool's collateral balance has been reduced
by 91.6% to $68 million from $806.4 million at issuance.

The largest loan of concern, representing 10.4% of the pool, is
secured by a retail property in a submarket of St.  Louis, MO.  As
of year-end 2009, occupancy was 82.3% with increasing operating
expenses.  The property also suffers from deferred maintenance.

The second loan of concern represents 2.9% of the pool and is
secured by a retail property in Columbia, SC.  It suffers from
several deferred maintenance issues.  Occupancy as of December
2009 was 73.2% debt service coverage ratio has decreased 8% from
the previous year due to a decrease in gross income.

Fitch stressed the cash flow of the a 10% reduction to 2008 fiscal
year end net operating income and applying an adjusted market cap
rate of 10% to determine value.  Fitch does not expect any losses
on the loans.

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.  Under this scenario, all the remaining loans are
expected to payoff at maturity and none of the loans are expected
to incur a loss when compared to Fitch's stressed value.


MORGAN STANLEY: S&P Downgrades Ratings on Various Notes to 'CC'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class IIA, III SrB, IIIA, IIIF, IIIH, IIII, and IIIJ notes from
Morgan Stanley Managed ACES SPC's series 2007-5 and class IIIA
from Morgan Stanley Managed ACES SPC's series 2007-15.  S&P
lowered its ratings on all eight classes to 'CC' from 'CCC-'.

The downgrades follow a number of credit events within the
underlying portfolios, which have caused the notes to incur
principal losses.

                         Ratings Lowered

                 Morgan Stanley Managed ACES SPC
                           Series 2007-5

                                    Rating
                                    ------
                     Class        To      From
                     -----        --      ----
                     IIA          CC      CCC-
                     III SrB      CC      CCC-
                     IIIA         CC      CCC-
                     IIIF         CC      CCC-
                     IIIH         CC      CCC-
                     IIII         CC      CCC-
                     IIIJ         CC      CCC-

                 Morgan Stanley Managed ACES SPC
                          Series 2007-15

                                    Rating
                                    ------
                     Class        To      From
                     -----        --      ----
                     IIIA         CC      CCC-


NATIONAL COLLEGIATE: Fitch Maintains Negative Watch on Ratings
--------------------------------------------------------------
Fitch Ratings maintains the bonds issued by four National
Collegiate Student Loan Trust transactions on Rating Watch
Negative.  The class D notes are not currently on Rating Watch.

The Rating Watch Negative was previously assigned to the non-
distressed ratings pertaining to the trusts that have a
significant level of pledge account balances.  The ratings account
for the funds in the pledge accounts, but currently, claims
against the funds for defaulted loans are not being filed.  This
puts pressure on the trusts from a liquidity standpoint, and the
Rating Watch Negative may be maintained until the funds are
utilized by the trusts.  It is anticipated that the funds will be
utilized when the TERI bankruptcy is resolved.

Fitch maintains its ratings for these trusts on Rating Watch
Negative:

National Collegiate Student Loan Trust 2006-3:

  -- Class A-1 'BBB+'; Rating Watch Negative;
  -- Class A-2 'BBB+'; Rating Watch Negative;
  -- Class A-3 'BBB+'; Rating Watch Negative;
  -- Class A-4 'BBB+'; Rating Watch Negative;
  -- Class A-5 'BBB+; Rating Watch Negative;
  -- Class A-IO 'BBB+'; Rating Watch Negative;
  -- Class B 'BB+'; Rating Watch Negative;
  -- Class C 'B+'; Rating Watch Negative.

National Collegiate Student Loan Trust 2006-4:

  -- Class A-1 'BBB'; Rating Watch Negative;
  -- Class A-2 'BBB'; Rating Watch Negative ;
  -- Class A-3 'BBB'; Rating Watch Negative;
  -- Class A-4 'BBB'; Rating Watch Negative;
  -- Class A-IO 'BBB'; Rating Watch Negative;
  -- Class B 'BB'; Rating Watch Negative;
  -- Class C 'B'; Rating Watch Negative.

National Collegiate Student Loan Trust 2007-1:

  -- Class A-1 'BBB-'; Rating Watch Negative;
  -- Class A-2 'BBB-'; Rating Watch Negative;
  -- Class A-3 'BBB-'; Rating Watch Negative;
  -- Class A-4 'BBB-'; Rating Watch Negative;
  -- Class A-IO 'BBB-'; Rating Watch Negative;
  -- Class B 'BB'; Rating Watch Negative;
  -- Class C 'B'; Rating Watch Negative.

National Collegiate Student Loan Trust 2007-2:

  -- Class A-1 'BBB'; Rating Watch Negative;
  -- Class A-2 'BBB'; Rating Watch Negative;
  -- Class A-3 'BBB'; Rating Watch Negative;
  -- Class A-4 'BBB'; Rating Watch Negative;
  -- Class A-IO 'BBB'; Rating Watch Negative;
  -- Class B 'BBB-'; Rating Watch Negative;
  -- Class C 'BB-'; Rating Watch Negative.


PENNSYLVANIA: Moody's Assigns 'Caa3' Rating on Bonds
----------------------------------------------------
Moody's Investors Service assigned a Caa3 rating to the planned
combined $30 million issuance of Pennsylvania Economic Development
Financing Authority Series 2010A and 2010B Special Facilities
Revenue Bonds.  The proceeds of the Bonds will be loaned to US
Airways Group, Inc., and will be used to finance renovations of
certain terminal facilities, the development and construction of a
ground handling equipment maintenance facility and equipment to be
used by US Airways, Inc., in its operations at Philadelphia
International Airport.  Group's obligations under the Loan
Agreements will be general obligations of it.  US Airways, Inc.,
will provide a non-recourse guarantee of Group's obligations under
the Loan Agreements.  This guarantee will be secured by a
leasehold mortgage, security agreement and fixture filing on its
leasehold interest in the Mainline Hanger Facility at the airport,
which US Airways, Inc. leases from the City of Philadelphia.

The Caa3 rating of the Bonds reflects the application of Moody's
Loss Given Default Rating Methodology.  The large amount of
secured debt obligations in the waterfall result in the unsecured
claims being notched below the Caa1 corporate family rating by two
notches.  The 89-LGD5 Loss Given Default assessment indicates that
the bondholders could receive substantially less than a full
recovery in the event of a default by Group.

The last rating action was on July 21, 2010, when Moody's changed
the ratings outlook to stable from negative.

Assignments:

Issuer: Pennsylvania Economic Dev. Fin. Auth.

  -- Senior Unsecured Revenue Bonds, Assigned Caa3, LGD5 89%
  -- Senior Unsecured Revenue Bonds, Assigned Caa3, LGD5 89%

US Airways Group, Inc., based in Tempe, Arizona, through its
subsidiaries operates one of the largest airlines in the U.S. with
service throughout the U.S. as well as Canada, Mexico, Europe, the
Middle East, the Caribbean, Central and South America.


PRIMUS CLO: Moody's Upgrades Ratings on Class D Notes to 'Caa3'
---------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
rating of these notes issued by Primus CLO I, Ltd.:

  -- US$28,000,000 Class D Floating Rate Deferrable Notes Due
     2019, Upgraded to Caa3; previously on August 11, 2009,
     Downgraded to Ca.

According to Moody's, the rating action taken on the notes results
primarily from improvement in the credit quality of the underlying
portfolio since the last rating action in August 2009 as well as
improvement in the Senior Overcollateralization Ratio.

Improvement in the credit quality is observed through an
improvement in the average credit rating (as measured by the
weighted average rating factor) and a decrease in the exposure to
securities rated Caa1/CCC+ and below.  In particular, as of the
latest trustee report dated June 3, 2010, the weighted average
rating factor was 2342 as compared to 2997 in July 2009 and in
compliance with the trigger level of 2590.  Based on the same
report, securities rated Caa1/CCC+ or lower make up approximately
12.48% of the underlying portfolio versus 20.95% in July 2009.

Additionally, the Senior Overcollateralization Ratio has increased
to 116.11% in June 2010 versus 112.88% in July 2009.  Moody's also
notes that the Class D notes are no longer deferring interest.
Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" and "Annual Sector Review (2009): Global CLOs," key
model inputs used by Moody's in its analysis, such as par,
weighted average rating factor, diversity score, and weighted
average recovery rate, may be different from the trustee's
reported numbers.

Primus CLO I, Ltd., issued on December 19, 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.


PRIMUS CLO: Moody's Upgrades Ratings on Various Classes of Notes
----------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Primus CLO II Ltd.:

  -- US$302,500,000 Class A Senior Secured Floating Rate notes Due
     2021 (current rated balance of US$289,231,014.28), Upgraded
     to Aa3; previously on July 30, 2009 Downgraded to A1;

  -- US$8,500,000 Class B Second Priority Floating Rate notes Due
     2021, Upgraded to A3; previously on July 30, 2009 Downgraded
     to Baa1;

  -- US$31,500,000 Class C Third Priority Deferrable Floating Rate
     notes Due 2021, Upgraded to Ba2; previously on July 30, 2009
     Downgraded to Ba3;

  -- US$10,500,000 Class D Fourth Priority Deferrable Floating
     Rate notes Due 2021, Upgraded to Caa1; previously on July 30,
     2009 Downgraded to Caa2.

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 July 2009 and to
improvements in the overcollateralization ratios.

Improvement in the credit quality is observed through an
improvement in the average credit rating (as measured by the
weighted average rating factor) and a decrease in the exposure to
securities rated Caa1 and below.  In particular, as of the latest
trustee report dated June 16, 2010, the weighted average rating
factor was 2329 as compared to 2828 in July 2009 and in compliance
with the trigger level of 2538.  Based on the same report,
securities rated Caa1 or lower make up approximately 6.34% of the
underlying portfolio versus 16.93% in July 2009.

Additionally, the overcollateralization ratios of the rated notes
have increased since the last rating action in July 2009 and are
currently all in compliance.  The Class A/B, Class C, Class D and
Class E Overcollateralization Tests are reported at 120.56%,
109.025%, 105.656%, and 101.472%, respectively versus July 2009
levels of 115.703%, 104.967%, 101.792%, and 97.415%.  The notes
also benefited from the delevering of the Class A Notes, which
have been paid down by approximately 2.59% or $7.7MM since the
last rating action.  Due to the impact of revised and updated key
assumptions referenced in "Moody's Approach to Rating
Collateralized Loan Obligations" and "Annual Sector Review (2009):
Global CLOs," key model inputs used by Moody's in its analysis,
such as par, weighted average rating factor, diversity score, and
weighted average recovery rate, may be different from the
trustee's reported numbers.

Primus CLO II Ltd., issued on July 10, 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.


RACE POINT: Moody's Raises Ratings on Various Classes of Notes
--------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Race Point CLO, Limited:

  -- US$71,000,000 Class A-2 Senior Secured Floating Rate Notes,
     Upgraded to Aaa; previously on August 4, 2008 Upgraded to
     Aa1;

  -- US$10,000,000 Class B-1 Senior Secured Floating Rate Notes,
     Upgraded to Aa1; previously on February 17, 2009 Downgraded
     to A2;

  -- US$12,000,000 Class B-2 Senior Secured Fixed Rate Notes,
     Upgraded to Aa1; previously on February 17, 2009 Downgraded
     to A2;

  -- US$20,000,000 Class C Senior Secured Floating Rate Notes,
     Upgraded to A3; previously on February 17, 2009 Downgraded to
     Baa3;

  -- US$15,500,000 Class D-1 Senior Secured Floating Rate Notes,
     Upgraded to B3; previously on February 17, 2009 Downgraded to
     Caa1;

  -- US$2,000,000 Class D-2 Senior Secured Floating Rate Notes,
     Upgraded to B3; previously on February 17, 2009 Downgraded to
     Caa1;

  -- US$3,500,000 Class D-3 Senior Secured Fixed Rate Notes,
     Upgraded to B3; previously on February 17, 2009 Downgraded to
     Caa1.

According to Moody's, the rating actions taken on the notes result
primarily from substantial deleveraging of the transaction since
the last rating action, which resulted in increases in the
overcollateralization ratios of the rated notes.  In addition, the
transaction has benefited from improvement in the credit quality
of the underlying portfolio.

Since the last rating action, the principal balance of the Class
A-1 Notes has been reduced by $92 million (from $121 million to
$29 million), accounting for roughly 76% of the total Class A-1
Notes' outstanding balance reported in February 2009.  A
substantial proportion of this reduction is attributable to
unscheduled principal payments and/or sales of the underlying
securities in the portfolio.  As a result, when compared to the
figures reported by the trustee in February 2009, the Class A
overcollateralization ratio has increased to 185.4% from 147.7%,
the Class B overcollateralization ratio has increased to 152.0%
from 132.5%, the Class C overcollateralization ratio has increased
to 130.6% from 121.2%, and the Class D overcollateralization ratio
has increased to 113.8% from 111.2%.  Moody's expects deleveraging
to continue as a result of the end of the deal's reinvestment
period in May 2007.

Improvement in the credit quality of the underlying portfolio is
observed through 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 June 30,
2010, the weighted average rating factor is 2651 compared to 3268
in February 2009.  Additionally, the concentration of assets with
a Moody's rating of Caa1 or lower has decreased to 11.3% from
19.3% in February 2009.

Race Point CLO, Limited, issued in November 2001, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans and senior unsecured bonds.


RFSC SERIES: Moody's Downgrades Ratings on Series 2002-RM1 Tranche
------------------------------------------------------------------
Moody's Investors Service has downgraded the rating of one tranche
issued by RFSC Series 2002-RM1 Trust.  The collateral backing the
transaction consists of prime loans originated by RFC.

The downgrade is driven by a small loss $20,551loss allocated to
the Class B-I-2 compared to the credit enhancement provided by
subordination.  The Class B-I-2 remains on review for possible
downgrade as Moody's completes its review of this transaction.

Moody's generally rates securities Caa1 or lower if it has a very
high likelihood of taking a loss in the expected case.

Complete rating actions are:

Issuer: RFSC Series 2002-RM1 Trust

  -- Cl. B-I-2, Downgraded to Caa3 and Remains On Review for
     Possible Downgrade; previously on April 15, 2010 B1 Placed
     Under Review for Possible Downgrade


SALOMON BROS: S&P Downgrades Ratings on Seven 2000-C1 Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on seven
classes of commercial mortgage-backed securities from Salomon
Bros. Mortgage Securities VII Inc.'s series 2000-C1 and removed
them from CreditWatch with negative implications.  In addition,
S&P affirmed its ratings on two other classes from the same
transaction.

The downgrades reflect its analysis of interest shortfalls that
have affected the trust.  As of the July 2010 remittance report,
the trust had experienced current interest shortfalls of $86,426
and had amassed cumulative interest shortfalls in the aggregate
amount of $666,488.  The downgrades reflect a reduction of
available interest to the trust, as well as S&P's opinion that the
downgraded classes have the potential to experience interest
shortfalls in the future.  The downgrades also reflect S&P's
concerns about the potential for future credit support erosion, as
13 of the remaining 24 nondefeased loans are with the special
servicer.

The current interest shortfalls primarily relate to 12 of the 13
assets with the special servicer, Berkadia Commercial Mortgage
LLC.  Appraisal subordinate entitlement reductions relating to 11
assets prompted shortfalls of $62,367 on the July 2010 remittance
report.  In addition, the master servicer, also Berkadia, has made
a nonrecoverable advance declaration on one asset (which has a
total exposure of $460,693 million, 0.4%).  The nonrecoverable
advance declaration is prompting monthly interest shortfalls of
approximately $17,000 to the trust.

The affirmation of the rating on the class E certificate reflects
a subordination level that S&P believes is consistent with the
outstanding rating.  S&P affirmed its rating on the class X
interest-only certificate based on its current criteria.

                      Credit Considerations

As of the July 2010 remittance report, 13 assets ($30.3 million,
36.9%) in the pool were with the special servicer.  The payment
status of these assets is: three ($8.9 million, 10.8%) are
classified as real estate owned, one ($2.9 million, 3.6%) is in
foreclosure, eight ($17.7 million, 21.5%) are 90-plus-days
delinquent, and one ($821,683 million, 1.0%) is less than 30 days
delinquent.  S&P discuss the three largest specially serviced
assets below.

The Los Altos Woods Office Building asset ($6.9 million, 8.4%) is
the third-largest real estate exposure in the pool and the largest
asset with the special servicer.  The asset is a 38,909-sq.-ft.
office property in Los Altos, Calif.  The loan was transferred to
the special servicer in November 2009 and is classified as REO.
The asset has been transferred to the trust, and a receiver has
been appointed.  Reported occupancy as of May 31, 2010, was 58%.
S&P expects a moderate loss upon the eventual resolution of this
asset.

The Two World's Fair Drive loan ($3.6 million, 4.4%) is the fifth-
largest real estate exposure in the pool and the second-largest
asset with the special servicer.  The loan is secured by a 59,310-
sq.-ft. office property in Franklin, N.J.  The loan was
transferred to the special servicer in August 2009 due to imminent
maturity default.  The property is currently 14% occupied after a
major tenant (84% of net rentable area) vacated in July 2009.
There is a $1.3 million appraisal reduction amount (ARA) in effect
against the asset.  There is a $1.3 million ARA in effect against
the asset.  S&P expects a significant loss upon the eventual
resolution of this asset.

The Groesbeck Industrial Park loan ($3.1 million, 3.7%) is the
sixth-largest real estate exposure in the pool and the third-
largest asset with the special servicer.  The loan is secured by a
146,646-sq.-ft. industrial property in Mount Clemens, Mich., which
was transferred to the special servicer in July 2009 due to
imminent default.  The reported DSC as of year-end 2008 was 0.53x.
According to the special servicer, the borrower was unable to
refinance the loan prior to maturity, and it initiated
foreclosure.  S&P expects a significant loss upon the eventual
resolution of this asset.

The remaining 10 specially serviced assets each have total
exposure amounts of less than $3.1 million.  S&P estimated losses
for nine of these 10 assets, resulting in an average loss severity
of 39.8%.  The remaining asset ($1.6 million, 1.9%) was
transferred to the special servicer in July 2009 due to maturity
default, and the special servicer is in discussion with the
borrower regarding an extension.

                       Transaction Summary

As of the July 2010 remittance report, the collateral pool had an
aggregate trust balance of $82.2 million, down from $713.3 million
at issuance.  The pool includes 30 assets, down from 266 at
issuance.  The master servicer provided full-year 2008 or full-
year 2009 financial information for 79.7% of the nondefeased
assets in the pool.  S&P calculated a weighted average DSC of
1.31x for the pool based on the reported figures.  This
calculation includes eight ($15.4 million, 18.6%) of the
transaction's 13 specially serviced assets.

The master servicer reported a watchlist of three ($2.9 million,
3.6%) loans.  Eight ($11.1 million, 13.6%) assets in the pool have
a reported DSC of less than 1.10x, and five ($7.8 million, 9.5%)
assets have a reported DSC of less than 1.00x.  To date, the pool
has experienced principal losses totaling $18.0 million on 13
assets.

                 Summary of Top 10 Loan Exposures

The top 10 exposures secured by real estate have an aggregate
outstanding trust balance of $60.2 million (73.3%).  Using
servicer-reported numbers, S&P calculated a weighted average DSC
of 1.36x for the top 10 real estate assets.  Seven ($23.6 million,
28.7%) of the top 10 exposures are currently with the special
servicer, three of which S&P discusses in the Credit
Considerations section above.  None of the top 10 assets appear on
the master servicer's watchlist.

Standard & Poor's analyzed the transaction according to its
current criteria, and the lowered and affirmed ratings are
consistent with its analysis.

      Ratings Lowered And Removed From Creditwatch Negative

             Salomon Bros. Mortgage Securities VII Inc.
   Commercial mortgage pass-through certificates series 2000-C1

                  Rating
                  ------
     Class      To      From           Credit enhancement (%)
     -----      --      ----           ----------------------
     F          A       A+/Watch Neg                    77.86
     G          BBB     A-/Watch Neg                    64.84
     H          BB+     BBB+/Watch Neg                  47.49
     J          B+      BB+/Watch Neg                   25.79
     K          B-      BB-/Watch Neg                   19.28
     L          CCC     B+/Watch Neg                    14.94
     M          CCC-    B/Watch Neg                      6.27

                         Ratings Affirmed

             Salomon Bros. Mortgage Securities VII Inc.
   Commercial mortgage pass-through certificates series 2000-C1

      Class     Rating                  Credit enhancement (%)
      -----     ------                  ----------------------
      E          AA                                      95.22
      X          AAA                                       N/A

                      N/A - Not applicable.


SANTANDER CONSUMER: Moody's Upgrades Ratings on Four Tranches
-------------------------------------------------------------
Moody's has upgraded four tranches from three auto loan
securitizations sponsored by Santander Consumer USA Inc. in 2007.
The actions are a result of updated lower lifetime loss
expectations since the previous actions in February 2009 as well
as build-up of credit enhancement supporting each of the affected
securities since the deal closed.  While the transactions are now
performing weaker than Moody's original expectations with higher
cumulative lifetime net loss expectations, the build-up of credit
enhancement has more than offset the increased loss projections.
The build-up in credit enhancement since closing is due to the
reserve accounts having reached their target levels.  These
transactions feature target levels which increase if cumulative
net loss and delinquency triggers are breached.  The 2007-1 and
2007-3 transactions have breached their cumulative net loss
triggers and are at the higher target levels.

Moody's expects the Santander Drive Auto Receivables Trust 2007-1
to incur lifetime cumulative net losses of 28%, which is within
the range of 27% to 30% that was published when the securities
were placed on review on July 8, 2010.  The initial expectation
for this transaction at closing was 19%.  Total hard credit
enhancement excluding available excess spread for Cl. A-4 upgraded
tranche is now approximately 31% of the outstanding collateral
balance, an increase from 21% of the balance at closing.  Updated
remaining expected losses are approximately 17% of the outstanding
collateral balance.  This transaction also benefits from excess
spread, which is approximately 11% on an annual basis.  Moody's
volatility proxy Aaa level for this transaction is approximately
66% of the remaining collateral balance.

Moody's current CNL for 2007-2 transaction is approximately 27% of
the original pool balance, which is at the low end of the 27% to
30% range that was published when the securities were placed on
review on July 8, 2010.  This is up from an original expectation
of 19% of the original pool balance.  Total hard credit
enhancement excluding available excess spread for Cl. A-3 upgraded
tranche is now approximately 26% of the outstanding collateral
balance, an increase from 21% of the balance at closing.  Updated
remaining expected losses isare approximately 17% of the
outstanding collateral balance.  This transaction also benefits
from excess spread, which is approximately 10% on an annual basis.
Moody's volatility proxy Aaa level for this transaction is
approximately 66% of the remaining collateral balance.

Moody's expects the Santander Drive Auto Receivables Trust 2007-3
to incur CNL of 28%, which is within the range of 27% to 30% that
was published when the securities were placed on review on July 8,
2010.  The initial expectation for this transaction at closing was
21%.  Total hard credit enhancement excluding available excess
spread for Cl.A-4-A and Cl. A-4-B upgraded tranches is
approximately 32% of the outstanding collateral balance, an
increase from 21% of the balance at closing.  Updated remaining
expected losses are approximately 18% of the outstanding
collateral balance.  This transaction also benefits from excess
spread, which is approximately 11% on an annual basis.  Moody's
volatility proxy Aaa level for this transaction is approximately
72% of the remaining collateral balance.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely ranges of performance over the
medium term.  From time to time, Moody's may, if warranted, change
these expectations.  Performance that falls outside the given
ranges may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated when the related
securities ratings were issued.  Even so, a deviation from the
expected ranges will not necessarily result in a rating action nor
does performance within expectations preclude such actions.  The
decision to take (or not take) a rating action is dependent on an
assessment of a ranges of factors including, but not exclusively,
the performance metrics.  Primary sources of assumption
uncertainty are the current macroeconomic environment, in which
unemployment continues to rise, and weakness in the used vehicle
market.  Moody's currently views the used vehicle market as
stronger now than it was a year ago, when the uncertainty relating
to the economy as well as the future of the U.S auto manufacturers
was significantly greater.  Overall, Moody's central global
scenario remains "Hook-shaped" for 2010 and 2011; Moody's expect
overall a sluggish recovery in most of the world largest
economies, returning to trend growth rate with elevated fiscal
deficits and persistent unemployment levels.

The underlying ratings reflect the intrinsic credit quality of the
notes in the absence of the transaction's guarantee from monoline
bond insurer.  The current ratings on the below notes are
consistent with Moody's practice of rating insured securities at
the higher of the guarantor's insurance financial strength rating
and any underlying rating.

Complete rating actions are:

Issuer: Santander Drive Auto Receivables Trust 2007-1

  -- Cl. A-4, Upgraded to A3; previously on July 8, 2010 Ba3
     Placed Under Review for Possible Upgrade

  -- Financial Guarantor: Financial Guaranty Insurance Company
     (WR; previously on 3/24/2009 Downgraded to Caa3 from Caa1)

  -- Underlying Rating: Upgraded to A3; previously on July 8, 2010
     Ba3 Placed Under Review for Possible Upgrade

Issuer: Santander Drive Auto Receivables Trust 2007-2

  -- Cl. A-3, Upgraded to Baa1; previously on July 8, 2010 Ba1
     Placed Under Review for Possible Upgrade

  -- Financial Guarantor: Financial Guaranty Insurance Company
     (WR; previously on 3/24/2009 Downgraded to Caa3 from Caa1)

  -- Underlying Rating: Upgraded to Baa1; previously on July 8,
     2010 Ba1 Placed Under Review for Possible Upgrade

Issuer: Santander Drive Auto Receivables Trust 2007-3

  -- Cl. A-4-A, Upgraded to A3; previously on July 8, 2010 Ba3
     Placed Under Review for Possible Upgrade

  -- Financial Guarantor: Financial Guaranty Insurance Company
     (WR; previously on 3/24/2009 Downgraded to Caa3 from Caa1)

  -- Underlying Rating: Upgraded to A3; previously on July 8, 2010
     Ba3 Placed Under Review for Possible Upgrade

  -- Cl. A-4-B, Upgraded to A3; previously on July 8, 2010 Ba3
     Placed Under Review for Possible Upgrade

  -- Financial Guarantor: Financial Guaranty Insurance Company
     (WR; previously on 3/24/2009 Downgraded to Caa3 from Caa1)

  -- Underlying Rating: Upgraded to A3; previously on July 8, 2010
     Ba3 Placed Under Review for Possible Upgrade


SLATE CDO: Fitch Downgrades Ratings on Five Classes of Certs.
-------------------------------------------------------------
Fitch Ratings has downgraded five and affirmed four classes issued
by Slate CDO 2007-1, Ltd., as a result of negative credit
migration and increased interest shortfalls to the underlying
collateral.

Slate CDO 2007-1 declared an Event of Default on April 3, 2009 due
to the Senior Adjusted Credit Ratio breaching its covenant.  As a
remedy to the EOD, the required majority of the controlling class
voted to accelerate the transaction on July 2, 2009.  According to
the July 6, 2010 trustee report, the class A-1SA and A-1SB notes
did not receive their full commitment fee and interest payment as
a result of insufficient interest proceeds due to interest
shortfalls on the underlying collateral and the significant hedge
payment.  Class A-1J and below continue to defer interest.  Fitch
rates the class A-1 (A-1SA, A-1SB, and A-1J) and A-2 notes to the
timely receipt of interest and has therefore downgraded these
classes to 'D'.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  Further, in its review, Fitch
analyzed the structure's sensitivity to the default of the
distressed collateral ('CCC' category and lower) and assets that
are experiencing interest shortfalls (51.3%).  All the collateral
in the portfolio has a Fitch derived rating below investment
grade; 71.9% has a rating in the 'CCC' category and below.

The classes' respective credit enhancement levels were compared to
the percent of underlying collateral experiencing interest
shortfalls.  Classes A-3 through C have been affirmed at 'C',
because Fitch believes that default appears inevitable given that
the total percentage of assets experiencing interest shortfalls
exceeds these classes' credit enhancement levels by a large
margin.

Slate CDO 2007-1 is a hybrid collateral debt obligation that
combines the use of synthetic and cash assets, as well as unfunded
and funded liabilities.  At issuance, Slate CDO 2007-1 had a
$270 million initially unfunded super-senior liquidity facility,
and issued approximately $330 million of funded notes and funded
preference shares.  The CDO initially invested in a $600 million
portfolio of combined synthetic and cash securities.  The
portfolio consists of 55% CDS, primarily referencing CMBS and CMBS
B-Piece Resecuritizations, as well as 45% cash CMBS, commercial
real estate CDO cash securities, and cash CMBS B-Piece
Resecuritizations.

Fitch has taken these rating actions:

  -- $266,334,297 class A-1SA notes downgraded to 'D' from 'CCC';
  -- $130,072,256 class A-1SB notes downgraded to 'D' from 'CCC';
  -- $67,500,000 class A-1J notes downgraded to 'D' from 'CC';
  -- $38,200,000 class A-2 notes downgraded to 'D' from 'C';
  -- $27,800,000 class A-3 notes affirmed at 'C';
  -- $18,000,000 class B1 notes affirmed at 'C';
  -- $13,500,000 class B-2 notes affirmed at 'C';
  -- $11,200,000 class B-3 notes affirmed at 'C';
  -- $5,300,000 class C notes affirmed at 'C'.

The ratings on the class A1SA, class A1SB, class A1J and class A2
notes address the likelihood that investors will receive full and
timely payments of interest, as per the governing documents, as
well as the aggregate outstanding amount of principal by the
stated maturity date.  The ratings on the class A3, class B1,
class B2, class B3, and class C notes address the likelihood that
investors will receive ultimate and compensating interest
payments, as per the governing documents, as well as the aggregate
outstanding amount of principal by the stated maturity date.


STRUCTURED INVESTMENTS: S&P Downgrades Ratings on Notes to 'CC'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the notes
issued by Structured Investments Corp. III's series 2007-3, a U.S.
synthetic collateralized debt obligation transaction, to 'CC' from
'CCC-'.

SIC III 2007-3 is a repackaging of the class C floating-rate notes
from South Coast Funding III Ltd., a cash flow mezzanine
structured finance CDO of asset-backed securities.  Class C is
currently rated 'CC' and is deferring its quarterly interest
payments.  The downgrade reflects the reduction in credit
enhancement available to support the class C notes.

                          Rating Lowered

                 Structured Investments Corp. III
                           Series 2007-3

                                    Rating
                                    ------
               Class           To             From
               -----           --             ----
               Notes           CC             CCC-


TRIAXX FUNDING: Moody's Withdraws Ratings on Various Classes
------------------------------------------------------------
Moody's Investors Service has withdrawn these ratings of notes
issued by Triaxx Funding High Grade I, Ltd.  The credit ratings
have been withdrawn because Moody's believes it has inadequate
information to maintain the credit ratings.

  -- US$80,000,000 Class B-1 Mezzanine Floating Rate Notes Due
     2047, Withdrawn; previously on December 16, 2009 Downgraded
     to C;

  -- US$41,000,000 Class B-2 Mezzanine Floating Rate Notes Due
     2047, Withdrawn; previously on March 2, 2009 Downgraded to C;

  -- US$149,375,000 Class C Mezzanine Floating Rate Deferrable
     Interest Notes Due 2047, Withdrawn; previously on March 2,
     2009 Downgraded to C;

  -- US$8,000,000 Class D Mezzanine Floating Rate Deferrable
     Interest Notes Due 2047, Withdrawn: previously on March 2,
     2009 Downgraded to C.


WEST NEW YORK: S&P Keeps BB Ratings on General Obligation Bonds
---------------------------------------------------------------
Standard & Poor's Ratings Services said it affirmed its 'BB' long-
term ratings on West New York, New Jersey's general obligation
bonds and removed them from CreditWatch, where they had been
placed with negative implications in March 2009.  The outlook on
the town's GO debt is developing.

"The rating action reflects positive operations in fiscal 2009,
which brought the current fund balance to $2.9 million, or a good
4% of expenditures," said Standard & Poor's credit analyst Jesse
Brady.  "The fiscal 2010 budget was also balanced without the use
of one-time or nonrecurring revenues, and preliminary estimates
indicate a second consecutive year of positive operations."  Town
officials estimate the current fund balance at $4.04 million, a
38% increase over the previous year, which represents 5.5% of
budgeted 2010 expenditures.

The town is operating under a six-month interim budget as it
changes to a Dec. 31 fiscal year-end from June 30.  The interim
budget was balanced without the use of reserves and without a tax
increase.

Standard & Poor's noted the town's significant fiscal stress when
it reviewed the rating last year and placed it on CreditWatch with
negative implications in March 2009.  At that time, projections
indicated a negative cash position in early April.  As many of the
town's outstanding debt issuances have debt service payment dates
in the first two weeks of April, a thin cash position was of
immediate concern.  Latest projections provided by the town now
indicate a negative cash position at the end of August.  Property
tax bills are to be mailed in August and the town expects
collections in the first two weeks of September to be more than
sufficient to cover debt service payments due during that two-week
period.  The town has indicated that in the event of late
payments, it is authorized to issue a tax anticipation note up to
70% of the quarterly tax bill to cover debt service payments.

In S&P's view, West New York's ongoing liquidity concerns and
history of chronic budgetary imbalance and stress are inconsistent
with an investment-grade rating.


* Fitch Takes Various Rating Actions From 12 SF CDO Transactions
----------------------------------------------------------------
Fitch Ratings has taken various rating actions as detailed at the
end of this press release for classes of notes issued by 12
structured finance collateralized debt obligations that closed in
2004 with exposure to structured finance assets.  The downgrades
are due to credit deterioration in the underlying portfolios.

This review was conducted under the framework described in the
reports 'Global Structured Finance Rating Criteria' and 'Global
Rating Criteria for Structured Finance CDOs'.  The analytical
scope of each CDO review varied depending on the quality of the
portfolio and credit enhancement for the CDO's classes available
from subordination and excess spread.

For transactions where expected losses from assets with a Fitch
derived rating of 'CC' and lower already significantly exceed the
credit enhancement level of the most senior class of notes, Fitch
believes that the probability of default for all classes of notes
can be evaluated without factoring potential further losses from
the remaining portion of the portfolios and without considering
the outcomes of various interest rate and default timing scenarios
as described in the relevant criteria.  Therefore these
transactions were not modeled using the Structured Finance
Portfolio Credit Model or cash flow model.

For transactions where expected losses from distressed assets did
not significantly exceed the credit enhancement level of the
senior class of notes, Fitch used SF PCM to project losses from
the transaction's entire portfolio.  If credit enhancement levels
to the most senior class indicate a rating higher than 'CCC',
Fitch performed cash flow model analysis to evaluate the notes'
performance under a range of interest rate and default timing
scenarios.

For all transactions, this review considered realized losses and
credit migration in the underlying portfolios since last review,
the ongoing and future impact of interest rate hedges,
availability of excess spread to pay down the notes, or
conversely, erosion of par due to the use of principal proceeds to
pay interest, and the likelihood of these trends to continue.

Fitch considered non-deferrable classes which have missed their
interest on at least one payment date and have not cured within an
appropriate cure period as specified in the transaction's
documents, to be in default as reflected in the respective
ratings.

Fitch does not assign Rating Outlooks or LS ratings to notes rated
category 'CCC' and lower.  Fitch currently does not assign
Recovery Ratings to notes of structured finance CDOs.

Fitch has taken these rating actions:

ACA ABS 2004-1, Limited/LLC.

  -- $35,075,417 class A-1 notes downgraded to 'A/LS5' from
     'AA/LS4'; Outlook Negative;

  -- $49,500,000 class A-2 notes downgraded to 'B/LS4' from
     'BB/LS4'; Outlook Negative;

  -- $47,250,000 class B notes affirmed at 'C';

  -- $15,002,866 class C-1 notes affirmed at 'C';

  -- $2,449,447 class C-2 notes affirmed at 'C'.

Fitch performed SF PCM and cash flow model analysis on ACA 2004-1.
Since Fitch's last review in October 2009, 56.3% of the portfolio
has been downgraded a weighted average of 3.1 notches.
Approximately 65.5% of the portfolio has a below investment grade
rating, with 44.1% considered in the 'CCC' rating category or
below, compared to 57.3% and 29.4%, respectively, at the last
review.  Additionally, principal proceeds are currently being used
to pay interest due to class A-2 and class B notes before
redeeming the class A-1 notes

ACA ABS 2004-1 is a structured finance collateralized debt
obligation that closed on May 27, 2004.  The portfolio is
monitored by Solidus Capital, LLC.  As of the June 2010 report,
the portfolio is composed of residential mortgage-backed
securities, commercial mortgage-backed securities, corporate CDOs,
senior unsecured debt issued by real estate investment trusts, and
SF CDOs bonds primarily of the 2003 and 2004 vintages.

Acacia CDO 6, Ltd./ Inc.

  -- $113,342,253 class A-1 notes downgraded to 'CC' from 'B/LS3';
  -- $15,000,000 class A-2 notes affirmed at 'D';
  -- $27,000,000 class B notes affirmed at 'D';
  -- $6,663,643 class C notes affirmed at 'C';
  -- $3,100,696 class D notes affirmed at 'C';
  -- $1,586,318 class E-1 notes affirmed at 'C';
  -- $7,762,193 class E-2 notes affirmed at 'C'.

Fitch performed SF PCM analysis on Acacia 6, but did not cash flow
model the transaction.  Since Fitch's last review in October 2009,
approximately 78.1% of the portfolio has been downgraded a
weighted average of 4.2 notches.  The losses expected from the
distressed portion of the portfolio are comparable to the CE level
for the class A-1 notes; however, the resulting 'CCC' RLR from SF
PCM significantly exceeds the class A-1 CE.  Acacia 6 entered an
event of default on May 14, 2009, as a result of the class A/B
overcollateralization ratio falling below 100%.  As a remedy to
the EOD, the class A-1 notes as the controlling class voted to
accelerate the maturity of the transaction.  Consequently, all
interest that would otherwise be paid to the classes A-2 and B
notes along with all principal proceeds are paid to the class A-1
notes until paid in full.  Despite the benefit of the acceleration
to the class A-1 notes, this class has been downgraded to 'CC' to
reflect Fitch's belief that default is probable given the
deterioration in the portfolio.

Acacia 6 is a cash flow CDO that closed on Nov. 9, 2004, and is
monitored by MBIA Capital Management Corp. As of the June 30, 2010
trustee report, the portfolio is comprised of RMBS, CMBS, and CDOs
from primarily 2004 through 2006 vintage transactions.

C-BASS CBO X, Ltd./Corp

  -- $50,771,871 class A notes downgraded to 'CCC' from 'BBB/LS3';
  -- $25,000,000 class B notes downgraded to 'CC' from 'B/LS5';
  -- $20,000,000 class C notes downgraded to 'C' from 'CC';
  -- $15,201,519 class D notes affirmed at 'C'.

Fitch performed SF PCM analysis on C-BASS X but did not cash flow
model the transaction.  Since Fitch's last review in October 2009,
approximately 51.3% of the portfolio has been downgraded a
weighted average of 5.9 notches.  The CE levels for the class A
and class B notes exceed the losses expected from the distressed
portion of the portfolio; however, the resulting 'CCC' RLR from SF
PCM is comparable to the class A CE.  Although a small portion of
interest is being used to pay down the notes, it is not sufficient
to offset the expected losses.

C-BASS X is a cash flow CDO that closed on May 27, 2004, and is
monitored by C-BASS Investment Management.  As of the June 30,
2010 trustee report, the portfolio is comprised of RMBS, CMBS, and
consumer ABS from 1995 through 2005 vintage transactions.

C-BASS CBO XI, Ltd./Corp

  -- $152,006,764 class A notes downgraded to 'C' from 'CCC';
  -- $17,500,000 class B notes downgraded to 'C' from 'CCC';
  -- $20,000,000 class C notes downgraded to 'C' from 'CC';
  -- $14,250,000 class D notes affirmed at 'C'.

Fitch did not perform SF PCM or cash flow model analysis on C-BASS
XI.  Since Fitch's last review in September 2009, approximately
71% of the portfolio has been downgraded a weighted average of 5.9
notches.  The losses expected from the distressed portion of the
portfolio already significantly exceed the CE level of the class A
notes.  Additionally, interest collections are not sufficient to
fulfill the entire interest rate swap obligation.  Principal
proceeds are currently being used to fulfill the remaining hedge
counterparty payment and the entire accrued interest amounts due
to class A and class B before redeeming the class A notes.

C-BASS XI is a cash flow CDO that closed on Sept. 15, 2004, and is
monitored by C-BASS Investment Management.  As of the June 30,
2010 report, the portfolio is composed of RMBS, commercial and
consumer ABS, SF CDOs and CMBS primarily of the 2001 through 2004
vintage transactions.

C-BASS CBO XII Ltd./Corp

  -- $148,643,704 class A notes downgraded to 'C' from 'CCC';
  -- $14,000,000 class B notes downgraded to 'C' from 'CC';
  -- $24,000,000 class C notes affirmed at 'C';
  -- $7,690,430 class D notes affirmed at 'C'.

Fitch performed SF PCM analysis on C-BASS XII but did not cash
flow model the transaction.  Since Fitch's last review in
September 2009, approximately 62.4% of the portfolio has been
downgraded a weighted average of 5.2 notches.  The losses expected
from the distressed portion of the portfolio already exceed the CE
level of the class A notes.  Additionally, interest collections
are insufficient to fulfill the hedge counterparty payment.
Principal proceeds are currently being used to fulfill the
remaining payment to the hedge counterparty and the entire accrued
interest distribution amounts to the class A-1, class A-2 and
class B notes before redeeming the class A-1 notes.

C-BASS XII is a cash flow CDO that closed on Dec. 16, 2004, and is
monitored by C-BASS Investment Management.  As of the June 30,
2010 trustee report, the portfolio is comprised of RMBS, SF CDOs,
consumer ABS and CMBS primarily from 1998, 2003 and 2004 vintage
transactions.

Dunhill ABS CDO, Ltd./Corp.

  -- $130,539,007 class A-1NV notes downgraded to 'C' from 'CC';
  -- $86,416 class A-1VA notes downgraded to 'C' from 'CC';
  -- $6,913,283 class A-1VB notes downgraded to 'C' from 'CC';
  -- $57,500,000 class A-2 notes affirmed at 'C';
  -- $55,000,000 class B notes affirmed at 'C';
  -- $19,793,885 class C notes affirmed at 'C'.

Fitch performed SF PCM analysis on Dunhill but did not cash flow
model the transaction.  Since Fitch's last review in September
2009, approximately 50.9% of the portfolio has been downgraded a
weighted average of four notches.  The losses expected from the
distressed portion of the portfolio already exceed the CE level
for the class A-1NV, A-1VA and A-1VB (together class A-1) notes.
Additionally, interest collections are not sufficient to fulfill
the accrued interest obligation to the timely rated class B notes.
Principal proceeds are currently being used to fulfill the
remaining interest to the class B notes.

Dunhill is a cash flow CDO that closed on Dec. 14, 2004, and is
monitored by Vanderbilt Capital Advisors LLC.  As of the June 29,
2010 trustee report, the portfolio is comprised of RMBS from
primarily 2004 and 20045 vintage transactions.

Glacier Funding CDO II, Ltd./Corp.

  -- $98,551,672 class A-1 notes downgraded to 'B/LS3' from
     'BBB/LS3'; Outlook Negative;

  -- $70,000,000 class A-2 notes downgraded to 'C' from 'CC';

  -- $65,750,000 class B notes affirmed at 'C';

  -- $20,823,038 class C notes affirmed at 'C';

  -- $5,120,682 class D notes affirmed at 'C'.

Fitch performed SF PCM and cash flow model analysis on Glacier II.
Since Fitch's last review in November 2009, 50.8% of the portfolio
has been downgraded.  Approximately 59.5% of the portfolio has a
below investment grade rating, compared to 35.8% at the last
review.  The class A-1 notes are receiving some principal
repayment from excess interest due to the failing class A/B
overcollateralization test.

Glacier II is a structured finance collateralized debt obligation
that closed on Oct. 12, 2004.  The portfolio was initially
selected by Terwin Money Management LLC and is now monitored by
Aventine Hill Capital, LLC.  As of the June 30, 2010 trustee
report, the portfolio is comprised of RMBS and CMBS from 2004
vintage transactions.

Ischus CDO I Ltd./LLC

  -- $77,650,132 class A-1 notes downgraded to 'CC' from 'CCC';
  -- $47,000,000 class A-2 notes affirmed at 'C';
  -- $39,000,000 class B notes affirmed at 'C';
  -- $11,801,981 class C-1 notes affirmed at 'C';
  -- $2,083,402 class C-2 notes affirmed at 'C'.

Fitch performed SF PCM analysis on Ischus I, but did not cash flow
model the transaction.  Since Fitch's last review in September
2009, approximately 44.9% of the portfolio has been downgraded a
weighted average of 4 notches.  The CE level for the class A-1
notes exceeds the losses expected from the distressed portion of
the portfolio; however, the resulting 'CCC' RLR from SF PCM is
significantly higher than the class A notes' CE level.  Although a
small portion of interest is being used to pay down the notes, it
is not sufficient to offset the expected losses.

Ischus I is a cash flow CDO that closed on Dec. 29, 2004, and is
monitored by Ischus Capital Management, LLC.  The transaction
entered an event of default on July 31, 2009, due to the class A
notes being undercollateralized.  To date, the trustee has not
been directed to accelerate the transaction.  As of the June 29,
2010 trustee report, the portfolio is comprised of RMBS, corporate
and SF CDOs, CMBS, and consumer ABS from 2001 through 2005 vintage
transactions.

Palisades CDO, Ltd.

  -- $225,894,829 class A-1A notes affirmed at 'B/LS3'; Outlook
     Negative;

  -- $3,703,194 class A-1B notes affirmed at 'B/LS3'; Outlook
     Negative;

  -- $88,500,000 class A-2 notes downgraded to 'C' from 'CC';

  -- $78,000,000 class B-1 notes affirmed at 'C';

  -- $6,000,000 class B-2 notes affirmed at 'C';

  -- $12,844,000 class C-1 notes affirmed at 'C';

  -- $13,266,501 class C-2 notes affirmed at 'C'.

Fitch performed SF PCM and cash flow model analysis on Palisades
CDO.  Since Fitch's last review in October 2009, 38.4% of the
portfolio has been downgraded a weighted average of 4.9 notches.
Approximately 66% of the portfolio has a below investment grade
rating, with 55.9% considered in the 'CCC' rating category or
below, compared to 53.5% and 45.5%, respectively, at the last
review.  The effect of the decline in credit quality has been
offset by increased credit enhancement levels for the class A-1A
and A-1B (class A-1) notes due to the deleveraging of the
transaction.  As of the April 2010 distribution date,
approximately 61.7% of the class A-1 notes' original principal
balance has amortized down with 13.7% paid down since the last
review

Palisades CDO is a SF CDO that closed on July 15, 2004, and is
managed by Western Asset Management Company.  As of the July 2010
trustee report, the portfolio is comprised of RMBS, corporate
CDOs, consumer and commercial ABS, and CMBS from 1997 through 2005
vintage transactions.

Vermeer Funding, Ltd./Inc.

  -- $37,822,774 class A-1 notes downgraded to 'B/LS5' from
     'A/LS4'; Outlook Negative;

  -- $38,500,000 class A-2 notes downgraded to 'CC' from 'B/LS4';

  -- $37,625,000 class B notes affirmed at 'C';

  -- $15,428,392 class C notes affirmed at 'C'.

Fitch performed SF PCM and cash flow model analysis on Vermeer
Funding.  Since Fitch's last review in October 2009, 45.6% of the
portfolio has been downgraded a weight average of 3.9 notches.
Approximately 67.1% of the portfolio has a below investment grade
rating, with 49.2% considered in the 'CCC' rating category or
below, compared to 59.8% and 38.5%, respectively, at the last
review.  While the class A-1 notes are receiving some principal
repayment from excess interest due to the failing class A/B
overcollateralization test, the amount of benefit from these
payments is marginal relative to the remaining outstanding balance
of the class A-1 notes.

Vermeer Funding is a cash flow CDO that closed on April 13, 2004,
and is monitored by Rabobank International.  As of the June 30,
2010 trustee report, the portfolio is comprised of RMBS,
commercial and consumer ABS, corporate CDOs, corporate debt and
CMBS from 2002 through 2006 vintage transactions.

Vermeer Funding II, Ltd./Inc.

  -- $69,624,665 class A-1 notes affirmed at 'CC';
  -- $3,000,000 class A-2A notes affirmed at 'C';
  -- $25,250,000 class A-2B notes affirmed at 'C';
  -- $35,290,000 class B notes affirmed at 'C';
  -- $11,663,774 class C-1 notes affirmed at 'C';
  -- $2,728,274 class C-2 notes affirmed at 'C';
  -- $6,028,899 preference shares affirmed at 'C'.

Fitch performed SF PCM analysis on Vermeer II but did not cash
flow model the transaction.  Since Fitch's last review in November
2009, approximately 34.3% of the portfolio has been downgraded a
weighted average of 4.6 notches.  The CE level for the class A-1
notes exceeds the losses expected from the distressed portion of
the portfolio; however, the resulting 'CCC' RLR from SF PCM is
higher than the class A-1 notes' CE level.  Additionally, a small
portion of interest is being used to pay down the class A-1notes.

Vermeer II is a SF CDO that closed on Dec. 14, 2004, and is
monitored by Rabobank International.  As of the May 31, 2010
trustee report, the portfolio is comprised of RMBS, commercial and
consumer ABS, corporate CDOs, SF CDOs, and CMBS from 2004 and 2005
vintage transactions.

Whately CDO I, Ltd./Corp.

  -- $126,077,434 class A-1A notes affirmed at 'CC';
  -- $6,000,000 class A-1BF notes affirmed at 'C';
  -- $51,000,000 class A-1BV notes affirmed at 'C';
  -- $27,000,000 class A-2 notes affirmed at 'C';
  -- $13,389,037 class A-3 notes affirmed at 'C';
  -- $4,890,697 class BF notes affirmed at 'C';
  -- $11,627,991 class BV notes affirmed at 'C'.

Fitch performed SF PCM analysis on Whately but did not cash flow
model the transaction.  Since Fitch's last review in October 2009,
approximately 49.3% of the portfolio has been downgraded a
weighted average of 4.5 notches.  The CE level for the class A-1A
notes exceeds the losses expected from the distressed portion of
the portfolio; however, the resulting 'CCC' RLR from SF PCM is
significantly higher than the class A-1A notes' CE level.
Additionally, principal proceeds are currently being used to
fulfill interest amounts due to the class A-1BF, A1BV, and A2
notes before redeeming the class A-1A notes.

Whately is a SF CDO that closed on June 9, 2004, and is monitored
by Babson Capital Management LLC.  As of the July 2010 trustee
report, the portfolio is comprised of RMBS, commercial and
consumer ABS, corporate CDOs, and CMBS from 2003 through 2006
vintage transactions.


* Moody's Affirms 'Ba2' Rating on Housing & Redevelopment Bonds
---------------------------------------------------------------
Moody's affirms the Ba2 rating on the $2,010,000 outstanding
Aurora (Minnesota) Housing & Redevelopment Authority's Multifamily
Housing Revenue Bonds (Irongate Apts. Section 8 Assisted Project),
Series 1996.  The rating affirmation is based on the property's
financial performance and the continued support of the section 8
HAP contract, which is coterminous with bond maturity.  The
outlook on the bonds is revised to stable from negative.

Based on the 2009 audited financial statements, property
performance remains sufficient.  The financials had a Debt Service
Coverage Ratio of 1.09x up from 0.98x in 2008.  The property shows
consistent revenue streams year on year, despite fluctuating
property expenses since 2006.  The volatility in property expenses
is driven by the decrease in utility usage.  The 78 unit property
located in Aurora, Minnesota, has rental rates at 111% of HUD Fair
Market Rates "FMR" for St Louis County.  The high rental rates
mean it is highly unlikely that there will be a rental increase in
the near future.  The average occupancy over the last year is 89%,
ranging from a low of 83% in August 2009 to a high of 96% in March
2010.  Improvements have also been seen in the most recent HUD
property inspection conducted in 2007, which resulted in a REAC
score of 94b up from 60c in 2006.

                              Outlook

The outlook for the bonds is revised to stable from negative.  The
stable outlook reflects the sufficient performance of the project
including an increase in DSCR levels and high occupancy over the
last year.

                 What could change the rating -- UP

* Improved Debt Service Coverage levels

* Increase in financial performance and in occupancy levels for a
  prolonged period

               What could change the rating -- DOWN

* Decline in occupancy
* Increase in property expenses

Key Statistics (AS OF 12/31/09):

* Recent Reported Occupancy: 90% (July, 2010)

* Bond Maturity: 10/01/2019

* HAP Contract Expiration : 10/01/2019

* Fair Market Rates: Rental prices average 111% of FMR in St Louis
  County, MN

* HUD REAC Score: 94b (2007)

* Reserve and Replacement: Per unit $513

The last rating action with respect to the Aurora (Minnesota)
Housing & Redevelopment Authority's Multifamily Housing Revenue
Bonds (Irongate Apts. Section 8 Assisted Project), Series 1996,
was on October 9, 2007, when a municipal finance scale rating of
Ba2 negative was assigned.  That rating was subsequently
recalibrated to Ba2 negative on May 7, 2010.


* Moody's Downgrades Ratings on 10 Tranches From Six US SF CDOs
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of 10 tranches contained within 6 US Structured Finance
CDOs.  The tranches affected by the actions are from CDOs that
have experienced an Event of Default and in each case the Trustee
has been directed to liquidate the collateral as a post-event-of-
default remedy.  Moody's has been notified by the respective
Trustee in each of these cases that a final distribution of
liquidation proceeds has taken place (except for retention of a
small amount of residual funds in certain cases).

The rating actions taken reflect the final liquidation
distribution and changes in severity of loss associated with the
downgraded tranches.

Delphinus CDO 2007-1, Ltd.

  -- US$27,000,000 Class S Senior Floating Rate Notes Due October
     2012, Downgraded to C; previously on 8/26/2008 Downgraded to
     Ca;

  -- US$640,000,000 Super Senior Swap dated as of July 19,2007,
     Downgraded to C; previously on 8/26/2008 Downgraded to Ca;

  -- US$73,500,000 Class A-1A Senior Floating Rate Notes Due
     October 2047, Downgraded to C; previously on 8/26/2008
     Downgraded to Ca;

  -- US$86,500,000 Class A-1B Senior Floating Rate Notes Due
     October 2047, Downgraded to C; previously on 8/26/2008
     Downgraded to Ca.

Fort Point CDO II, LTD.

  -- Class A1 Floating Rate Notes, Downgraded to Ca; previously on
     2/4/2009 Downgraded to Caa2.

KLIO Funding, Ltd.

  -- Funding Notes, Downgraded to Ca; previously on 2/26/2009
     Downgraded to Caa1;

  -- Class A-1 Notes, Downgraded to C; previously on 2/26/2009
     Downgraded to Caa1.

Pacific Pinnacle CDO Ltd.

  -- US$800,000,000 Class A-1LA Floating Rate Notes Due January
     2052, Downgraded to C; previously on 4/24/2009 Downgraded to
     Ca.

Tourmaline CDO III Ltd.

  -- US$1,050,000,000 Class A-1 Senior Floating Rate Notes Due
     2052, Downgraded to C; previously on 9/23/2008 Downgraded to
     Ca.

IMAC CDO 2006-1, Ltd.

  -- US$75,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Delayed Draw Notes due 2051, Downgraded to C;
     previously on 4/24/2009 Downgraded to Ca.

The rating actions taken reflect the changes in severity of loss
associated with certain tranches and reflect the final liquidation
distribution.


* S&P Affirms Ratings on 54 Certs. From Seven Re-Remic Deals
------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on 54
classes of certificates from seven resecuritized real estate
mortgage investment conduit residential mortgage-backed securities
transactions.  The affirmations reflect S&P's assessment of the
credit enhancement available to the underlying certificates, which
in S&P's opinion is sufficient to maintain the ratings on the re-
REMIC classes.  In addition, certain re-REMIC classes may also
benefit from support classes within the re-REMIC transaction.

When performing S&P's analysis on the re-REMIC classes, S&P
applied S&P's loss projections to the underlying trusts in order
to identify the magnitude of losses that S&P believes could be
passed through to the applicable re-REMIC classes.  Generally,
S&P's projected losses depend on the related collateral supporting
the underlying trusts.  S&P then stressed these loss projections
at various rating categories to assess whether the re-REMIC
classes could withstand such stressed losses associated with their
current ratings.

Generally, the underlying collateral consists of 2005-2007 vintage
prime, subprime, and alternative-A loans that back the applicable
classes that contribute to the re-REMICs.  In S&P's view, these
vintages' performance has declined substantially in recent years.
As a result, over the past several years S&P has revised its RMBS
default and loss assumptions, and consequently its projected
losses, to reflect S&P's view of the continuing decline in
mortgage loan performance.  The performance deterioration of most
U.S. RMBS has continued to outpace the market's expectation.

                         Ratings Affirmed

                  Asset Repackaging Vehicle Ltd.
                          Series 2009-10

                  Class                    Rating
                  -----                    ------
                  A5                       BB+
                  A1                       AAA
                  A6                       BB
                  A7                       BB-
                  A4                       BBB
                  A3                       A
                  A2                       AA

                  Asset Repackaging Vehicle Ltd.
                          Series 2009-13

                  Class                    Rating
                  -----                    ------
                  A7                       BB-
                  A3                       A
                  A5                       BB+
                  A4                       BBB
                  A6                       BB
                  B                        B
                  A2                       AA

                   Asset Repackaging Vehicle Ltd.
                          Series 2009-15

                  Class                    Rating
                  -----                    ------
                  A3                       A
                  A1                       AAA
                  A7                       BB-
                  A6                       BB
                  A2                       AA
                  A5                       BB+
                  A4                       BBB

                   Asset Repackaging Vehicle Ltd.
                          Series 2009-18

                  Class                    Rating
                  -----                    ------
                  A5                       BB+
                  A7                       BB-
                  B                        B
                  A6                       BB
                  A2                       AA
                  A4                       BBB
                  A3                       A
                  A1                       AAA

                     BCAP LLC 2009-RR8 Trust
                          Series 2009-RR8

                  Class      CUSIP         Rating
                  -----      -----         ------
                  I-A1       05532CAA7     AAA

             Jefferies Resecuritization Trust 2009-R11
                          Series 2009-R11

                  Class      CUSIP         Rating
                  -----      -----         ------
                  2-A1-2     47233DAL5     AAA
                  2-A2B      47233DAH4     B
                  2-A2       47233DAF8     B
                  2-A2A      47233DAG6     B
                  2-A1-1     47233DAK7     AAA

                LVII Resecuritization Trust 2009-3
                          Series 2009-3

                  Class      CUSIP         Rating
                  -----      -----         ------
                  M-9        550786AM9     BBB-
                  A-IO-1     550786AW7     AAA
                  A-3        550786AC1     AAA
                  M-1        550786AD9     AA+
                  A-1        550786AA5     AAA
                  M-4        550786AG2     A+
                  M-7        550786AK3     BBB+
                  B-2        550786AP2     BB-
                  M-6        550786AJ6     A-
                  M-8        550786AL1     BBB
                  M-3        550786AF4     AA-
                  A-2        550786AB3     AAA
                  A-4        550786AY3     AAA
                  M-5        550786AH0     A
                  M-2        550786AE7     AA
                  B-3        550786AQ0     B
                  B-1        550786AN7     BB
                  A-IO-2     550786AZ0     AA
                  A-IO-3     550786BA4     A


* S&P Assigns 'CCC+' Rating on Pennsylvania's Revenue Bonds
-----------------------------------------------------------
Standard & Poor's Ratings Services assigned its 'CCC+' rating to
the Pennsylvania Economic Development Financing Authority (US
Airways Group Inc. project) Series 2010A and 2010B special
facility revenue bonds.  The bonds are to be serviced by payments
that US Airways Group Inc. will make to the Authority under a loan
agreement.  Proceeds will finance various facilities and
improvements that US Airways will use at Philadelphia
International Airport.  US Airways Inc., the largest airline
subsidiary of US Airways Group, guarantees the bonds.  That
guarantee is secured by a leasehold mortgage on a hangar leased by
US Airways Inc. from the City of Philadelphia.  The hangar was
built in 2000 at a cost of about $35 million.

These bonds are somewhat unusual relative to other airline special
facilities revenue bonds, in that the obligor is a holding
company, rather than an airline operating company.  In addition,
the bonds' guarantee is secured by a leasehold mortgage related to
property separate from that which the bonds are financing.
Because the hangar is leased from the City, the rights of
bondholders from the leasehold mortgage are subject to and limited
by the existing hangar lease between the City and the airline.  If
US Airways Group defaulted on the loan agreement with the
Authority and bondholders sought compensation through the
guarantee, they would not be entitled to receive the rentals
currently paid by US Airways Inc. to the City under the hangar
lease (although they could receive any excess rents if the City
replaced US Airways Inc. with another airline and received higher
rents).

The principal value of the leasehold mortgage to bondholders, S&P
believe, is that the bond Trustee (acting on behalf of the
bondholders) could take possession of the hangar and seek to
prevent US Airways from using it.  If successful, the bond Trustee
could use this as bargaining leverage in seeking compensation for
the default on the bonds.  Because the bondholders have no right
to existing payments under the lease that secures the guarantee,
S&P judged that recovery prospects were not as strong as in
special revenue bonds that S&P considers the equivalent of secured
debt (in which case S&P would typically assign an issue rating
equal to the airline's corporate credit rating).  At the same
time, S&P judged that the recovery prospects of the special
revenue bonds S&P is rating are better in a default scenario than
senior unsecured debt (which is rated two notches below the
corporate credit rating in the case of US Airways Group Inc.).
S&P accordingly assigned a rating of 'CCC+', one notch below the
'B-' corporate credit rating of US Airways Group and US Airways
Inc.

                           Rating List

                       US Airways Group Inc.
                          US Airways Inc.

           Corp. credit rating          B-/Negative/--

                          Ratings Assigned

    Pennsylvania Economic Development Financing Authority
     (US Airways Group Inc. project)
    Series 2010A, 2010B special facility revenue bonds      CCC+


* S&P Downgrades Ratings on 27 Notes From Four Hybrid CDOs to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 27
classes of notes from three cash flow and four hybrid
collateralized debt obligation transactions to 'D' and removed two
of these ratings from CreditWatch with negative implications.  At
the same time, S&P withdrew S&P's 'BB' rating from class B issued
by Nova CDO 2001 Ltd.  Additionally, S&P affirmed its 'CC' ratings
on three classes issued by Orion 2006-1 Ltd..

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

S&P withdrew its rating on class B from Nova CDO 2001 Ltd.
following the complete paydown of the notes on the payment date.

The downgrade of class B from Orion 2006-1 Ltd. resulted from an
EOD on June 15, 2010, following a default in the payment of
interest due on the non-payment-in-kind class B notes.

S&P lowered its ratings on the three hybrid CDOs--Big Horn
Structured Funding CDO 2007-1 Ltd., GSC ABS CDO 2005-1 Ltd., and
Tourmaline CDO III Ltd.--because the transactions did not have
proceeds to pay back par payments to the noteholders after making
the termination payments on the credit default swap contracts.

For the remaining three cash flow transactions (Klio Funding Ltd.,
Nova CDO 2001 Ltd., and Pacific Pinnacle CDO Ltd.), S&P has
received notices from the trustees stating that after the
liquidation of the portfolio assets, the available proceeds were
insufficient to pay the noteholders in full.

                          Ratings Lowered

                                                    Rating
                                                    ------
  Transaction                        Class        To     From
  -----------                        -----        --     ----
Big Horn Str. Fdg CDO 2007-1 Ltd.     C            D      CC
Big Horn Str. Fdg CDO 2007-1 Ltd.     D            D      CC
GSC ABS CDO 2005-1 Ltd.               A1S          D      CC
GSC ABS CDO 2005-1 Ltd.               A1J          D      CC
GSC ABS CDO 2005-1 Ltd.               A2           D      CC
GSC ABS CDO 2005-1 Ltd.               A3           D      CC
GSC ABS CDO 2005-1 Ltd.               B            D      CC
Klio Funding Ltd.                     A-2          D      CC
Klio Funding Ltd.                     B            D      CC
Klio Funding Ltd.                     A-1          D      CC
Klio Funding Ltd.                     Fund Notes   D      CC
Nova CDO 2001 Ltd.                    D-1          D      CC
Nova CDO 2001 Ltd.                    D-2          D      CC
Nova CDO 2001 Ltd.                    C-1          D      CCC-/Watch Neg
Nova CDO 2001 Ltd.                    C-2          D      CCC-/Watch Neg
Orion 2006-1 Ltd.                     B            D      CC
Pacific Pinnacle CDO Ltd.             A-3L         D      CC
Pacific Pinnacle CDO Ltd.             B-1L         D      CC
Tourmaline CDO III Ltd.               B-2          D      CC
Tourmaline CDO III Ltd.               C            D      CC
Tourmaline CDO III Ltd.               D-1          D      CC
Tourmaline CDO III Ltd.               D-2 FLT      D      CC
Tourmaline CDO III Ltd.               D-2 HYB      D      CC
Tourmaline CDO III Ltd.               D-3          D      CC
Tourmaline CDO III Ltd.               E            D      CC
Tourmaline CDO III Ltd.               Combo Nts    D      CC
Tourmaline CDO III Ltd.               A-1a         D      CCC-

                             Rating Withdrawn

                                                       Rating
                                                       ------
  Transaction                               Class    To     From
  -----------                               -----    --     ----
  Nova CDO 2001 Ltd.                        B        NR     BB/Watch neg

                         Ratings Affirmed

  Transaction                               Class          Rating
  -----------                               -----          ------
  Orion 2006-1 Ltd.                         C              CC
  Orion 2006-1 Ltd.                         D              CC
  Orion 2006-1 Ltd.                         A              CC

                     Other Outstanding Ratings

  Transaction                               Class          Rating
  -----------                               -----          ------
  Big Horn Str.  Fdg CDO 2007-1 Ltd.        SprSr Swap        D
  Big Horn Str.  Fdg CDO 2007-1 Ltd.        S                 D
  Big Horn Str.  Fdg CDO 2007-1 Ltd.        A                 D
  Big Horn Str.  Fdg CDO 2007-1 Ltd.        Jr Swap           D
  Big Horn Str.  Fdg CDO 2007-1 Ltd.        B                 D
  Pacific Pinnacle CDO Ltd.                 A-1LA             D
  Pacific Pinnacle CDO Ltd.                 A-1LB             D
  Pacific Pinnacle CDO Ltd.                 A-1LC             D
  Pacific Pinnacle CDO Ltd.                 X                 D
  Pacific Pinnacle CDO Ltd.                 A-2L              D
  Tourmaline CDO III Ltd.                   A-1b              D
  Tourmaline CDO III Ltd.                   A-2 FLT           D
  Tourmaline CDO III Ltd.                   A-2 FXD           D
  Tourmaline CDO III Ltd.                   B-1               D


* S&P Downgrades Ratings on 35 Classes of Certificates
------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 35
classes of certificates from five re-securitized real estate
mortgage investment conduit residential mortgage-backed securities
transactions and removed six of them from CreditWatch negative.
Additionally, S&P affirmed its ratings on 13 other classes of
certificates from the same transactions.

The downgrades reflect S&P's assessment of the significant
deterioration in performance of the mortgage loans supporting the
underlying certificates.  As a result of this performance
deterioration, the downgraded classes were unable to maintain
their previous ratings at the applicable rating stresses.  The
affirmations reflect S&P's assessment of the credit enhancement
available to the underlying certificates, which in S&P's opinion,
is sufficient to maintain the ratings on the re-REMIC classes.  In
addition, certain re-REMIC classes may also benefit from
supporting classes within the re-REMIC transaction.

When S&P performed its analysis on the re-REMIC classes, S&P
applied its loss projections to the underlying trusts in order to
identify the magnitude of losses that S&P believes could be passed
through to the applicable re-REMIC classes.  Generally, S&P's
projected losses depend on the type of collateral supporting the
underlying trusts.  S&P then stressed these loss projections at
various rating categories in order to assess whether the re-REMIC
classes could withstand such stressed losses at their current
rating levels.

Generally, the underlying collateral for these transactions
consists of prime, subprime, and Alternative-A mortgage loans from
2005-2007 vintages.  In S&P's view, the performance of these
collateral types from these vintages has declined in recent years.
As a result, over the past several years S&P has revised its RMBS
default and loss assumptions, and consequently its projected
losses, to reflect its view of the continuing decline in mortgage
loan performance.  The performance deterioration of most U.S. RMBS
has continued to outpace the market's expectations.

                          Rating Actions

                       CSMC Series 2009-12R
                        Series    2009-12R

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        43-A-1     12642MEJ5     A+                   AAA
        42-A-1     12642MEC0     B+                   AAA

                       CSMC Series 2009-3R
                        Series    2009-3R

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    30-A-1     22943YUR8     CCC                  AAA
    26-A-2     22943YTW9     B-                   AAA/Watch Neg
    26-A-1     22943YTV1     BBB+                 AAA
    30-AA      22943YVA4     CC                   B+/Watch Neg
    30-A-9     22943YUZ0     CC                   B+/Watch Neg
    30-A-7     22943YUX5     CC                   B+/Watch Neg
    30-A-2     22943YUS6     CC                   B+/Watch Neg
    30-A-5     22943YUV9     CCC                  AAA
    4-A-2      22943YCK3     B+                   AAA/Watch Neg
    30-A-8     22943YUY3     CCC                  AAA
    30-A-4     22943YUU1     CCC                  AAA
    30-A-3     22943YUT4     CCC                  AAA
    30-A-6     22943YUW7     CCC                  B+

            J.P. Morgan Mortgage Trust Series 2008-R4
                        Series    2008-R4

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        2-A-1      46633AAC9     A-                   AAA

             Jefferies Resecuritization Trust 2008-R2
                        Series    2008-R2

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        I-A1       472321AA6     AA                   AAA
        I-A2       472321AB4     BB                   BBB
        II-A1      472321AC2     BB                   BBB
        II-A2      472321AD0     B                    BB
        II-A3      472321AH1     CCC                  B
        II-A4      472321AN8     CC                   CCC
        III-A1     472321AJ7     B                    BBB
        III-A2     472321AK4     CCC                  B
        III-A3     472321AL2     CC                   CCC

          Mortgage Loan Resecuritization Trust 2009-RS1
                        Series    2009-RS1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A85        61914WAA4     CCC                  A
        A89        61914WAL0     CCC                  BBB-
        A77        61914WAW6     BBB                  A
        A91        61914WAJ5     CCC                  BB
        A95        61914WAE6     CCC                  B
        A87        61914WAN6     CCC                  BBB+
        A81        61914WAS5     B                    A
        A93        61914WAG1     CCC                  B+
        A79        61914WAU0     BB                   A
        A83        61914WAQ9     CCC                  A

                         Ratings Affirmed

                       CSMC Series 2009-12R
                        Series    2009-12R

                 Class      CUSIP         Rating
                 -----      -----         ------
                 41-A-1     12642MDS6     AAA

                       CSMC Series 2009-3R
                        Series    2009-3R

                 Class      CUSIP         Rating
                 -----      -----         ------
                 4-R        22943YVE6     AAA
                 4-A-1      22943YCJ6     AAA

            J.P. Morgan Mortgage Trust Series 2008-R4
                        Series    2008-R4

                 Class      CUSIP         Rating
                 -----      -----         ------
                 3-A-2      46633AAH8     CCC
                 2-A-2      46633AAD7     CCC
                 3-A-1      46633AAG0     AAA

             Jefferies Resecuritization Trust 2008-R2
                        Series    2008-R2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 I-A3       472321AG3     CCC

           Mortgage Loan Resecuritization Trust 2009-RS1
                        Series    2009-RS1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A65        61914WBJ4     A
                 A67        61914WBG0     A
                 A75        61914WAY2     A
                 A69        61914WBE5     A
                 A73        61914WBA3     A
                 A71        61914WBC9     A


* S&P Downgrades Ratings on 60 Tranches From 18 Preferred CDOs
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 60
tranches from 18 U.S. trust preferred securities collateralized
debt obligation transactions and removed 58 of them from
CreditWatch negative.  The tranches with lowered ratings have a
total issuance amount of $5.822 billion.  At the same time, S&P
affirmed its ratings on 15 tranches from five transactions and
removed one of them from CreditWatch negative.  S&P also withdrew
its rating on one tranche from Principal Protected I-PreTSL I
following the complete paydown of the notes.

The downgrades reflect three primary factors:

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

* The application of S&P's revised recovery assumptions for TruPS
  issued by U.S. Banks; and

* In most cases, significant deterioration in the credit quality
  of the underlying asset portfolios due to increased exposure to
  obligors that have either defaulted or deferred payments on
  TruPS, along with an increase in the number of TruPS that
  experienced downgrades into the 'CCC' range.

In July 2010, S&P stated that S&P has observed severe negative
credit migration and significant increases in defaults and
deferrals in the pools underlying assets.

In January 2009, S&P indicated its view that the economic and
regulatory conditions pointed to a potential increase in the
number of U.S. banks that defer on their TruPS payment
obligations.  Since January 2009, S&P has observed significant
increases in the number of deferrals of U.S. Bank TruPS held by
the CDOs S&P rates.  While the rate of increase in the number of
deferrals may have recently slowed, in S&P's view, the economic
and regulatory conditions at the root of these deferrals continue
to unfold.

The affirmations reflect S&P's view that the affirmed tranches
have sufficient credit support to maintain their current ratings
according to its updated criteria.  Some of the affirmed tranches
were structured as principal-protected notes that are supported by
additional collateral, usually in the form of a zero-coupon bond
issued by the U.S. government or an entity backed by the U.S.
government.  S&P's ratings on these principal-protected notes
address only the payment of principal at maturity and are linked
to the rating on the bond pledged as additional collateral.
Accordingly, the credit quality of the CDO portfolios did not
drive S&P's ratings on the principal-protected notes.

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

                          Rating Actions

                                           Rating
                                           ------
    Transaction                    Class  To    From
    -----------                    -----  --    ----
    ALESCO Preferred Funding VII   A-1B   CCC-  BBB-/Watch Neg
    ALESCO Preferred Funding VII   A-2    CCC-  BB/Watch Neg
    ALESCO Preferred Funding VII   B      CCC-  BB-/Watch Neg
    ALESCO Preferred Funding XV    A-1    CCC-  BBB+/Watch Neg
    Attentus CDO II                B      CC    CCC-/Watch Neg
    Dekania CDO II                 A-1    BBB+  AAA/Watch Neg
    Dekania CDO II                 A-2    BBB   AA+/Watch Neg
    Dekania CDO II                 B      BB+   A+/Watch Neg
    Dekania CDO II                 C-1    CCC   BB+/Watch Neg
    Dekania CDO II                 C-2    CCC   BB+/Watch Neg
    Dekania CDO II                 Combo  BB+   BBB/Watch Neg
    Dekania CDO II                 D-1    CCC-  B+/Watch Neg
    Dekania CDO II                 D-2    CCC-  B+/Watch Neg
    I-Preferred Term Securities I  A-1    A+    AAA
    I-Preferred Term Securities I  A-2    A+    AAA/Watch Neg
    I-Preferred Term Securities I  A-3    A+    AAA/Watch Neg
    I-Preferred Term Securities I  B-1    CCC-  B+/Watch Neg
    I-Preferred Term Securities I  B-2    CCC-  B+/Watch Neg
    I-Preferred Term Securities I  B-3    CCC-  B+/Watch Neg
    I-Preferred Term Securities I  C      CCC-  CCC+/Watch Neg
    Kodiak CDO II                  A-1    BB+   AA+/Watch Neg
    Kodiak CDO II                  A-2    BB+   AA/Watch Neg
    Kodiak CDO II                  A-3    B     BBB/Watch Neg
    Kodiak CDO II                  B-1    CCC   BB-/Watch Neg
    Kodiak CDO II                  B-2    CCC   BB-/Watch Neg
    Kodiak CDO II                  C-1    CCC-  B-/Watch Neg
    Kodiak CDO II                  C-2    CCC-  B-/Watch Neg
    Kodiak CDO II                  D      CCC-  CCC+/Watch Neg
    Kodiak CDO II                  E      CCC-  CCC/Watch Neg
    Kodiak CDO II                  F      CC    CCC-/Watch Neg
    Preferred Term Securities XIX  A-1    CCC-  BB+/Watch Neg
    Preferred Term Securities XIX  A-2    CCC-  BB/Watch Neg
    Principal Protected I-PreTSL I PrnPrt NR    AAA
    Soloso CDO 2007-1              A-1LA  CCC-  BB-/Watch Neg
    Soloso CDO 2007-1              A-1LB  CCC-  B+/Watch Neg
    Taberna Preferred Funding VII  A-1LA  CCC-  BBB-/Watch Neg
    Taberna Preferred Funding VII  A-1LB  CC    B-/Watch Neg
    Taberna Preferred Funding VII  A-2LA  CC    CCC/Watch Neg
    Taberna Preferred Funding VII  A-2LB  CC    CCC-/Watch Neg
    TPref Funding II               A-1    AA+   AAA
    TPref Funding II               A-2    BB+   A/Watch Neg
    TPref Funding III              A-1    BB+   A/Watch Neg
    TPref Funding III              A-2    BB-   BB/Watch Neg
    Trapeza CDO III LLC            A1A    B+    BBB-/Watch Neg
    Trapeza CDO III LLC            A1B    CCC-  B+/Watch Neg
    Trapeza CDO VI                 A-1A   CCC+  BB+/Watch Neg
    Trapeza CDO VI                 A-1B   CCC+  BB/Watch Neg
    Trapeza CDO VII                A-1    CCC+  BB+/Watch Neg
    Trapeza CDO VII                A-2    CCC-  B+/Watch Neg
    Trapeza CDO XI                 A-1    CCC-  BB+/Watch Neg
    Trapeza CDO XI                 A-2    CCC-  BB-/Watch Neg
    Trapeza CDO XI                 A-3    CCC-  B+/Watch Neg
    Trapeza CDO XI                 B      CCC-  CCC/Watch Neg
    Trapeza CDO XI                 C      CCC-  CCC-/Watch Neg
    Trapeza CDO XIII               A-1    CCC+  BB+/Watch Neg
    Trapeza CDO XIII               A-2a   CCC-  BB-/Watch Neg
    Trapeza CDO XIII               A-2b   CCC-  BB-/Watch Neg
    Tropic CDO III                 A-1L   CCC+  BBB/Watch Neg
    Tropic CDO III                 A-2L   CCC-  BB+/Watch Neg
    Tropic CDO IV                  A-1L   CCC-  BBB-/Watch Neg
    Tropic CDO IV                  A-2L   CCC-  BB+/Watch Neg
    Tropic CDO IV                  A-3L   CCC-  B+/Watch Neg

                         Ratings Affirmed

        Transaction                    Class        Rating
        -----------                    -----        ------
        ALESCO Preferred Funding VII   A-1A         AAA
        Attentus CDO II                A-1          AAA
        Attentus CDO II                C            CC
        Attentus CDO II                D            CC
        Attentus CDO II                E-1          CC
        Attentus CDO II                E-2          CC
        Attentus CDO II                F-1          CC
        Attentus CDO II                F-2          CC
        Soloso CDO 2007-1              P-1          AAA
        Soloso CDO 2007-1              P-2          AAA
        Taberna Preferred Funding VII  A-3L         CC
        Taberna Preferred Funding VII  B-1L         CC
        Taberna Preferred Funding VII  B-2L         CC
        Taberna Preferred Funding VII  C-1          CC

                     Other Ratings Outstanding

        Transaction                    Class        Rating
        -----------                    -----        ------
        Attentus CDO II                A-2          D
        Attentus CDO II                A-3A         D
        Attentus CDO II                A-3B         D


* S&P Downgrades Ratings on Six Certificates From Six RMBS Deals
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes of mortgage pass-through certificates from six U.S.
residential mortgage-backed securities transactions issued from
2004 to 2008.  In addition, S&P placed its ratings on five classes
from two additional deals on CreditWatch with negative
implications.

All of the downgrades reflect S&P's assessment of interest
shortfalls on the affected classes during recent remittance
periods.  S&P's ratings reflect its view of the magnitude of the
interest payment deficiencies that have affected each class to
date compared with the remaining principal balance owed and the
likelihood that certificateholders will be reimbursed for these
deficiencies.  S&P also considered the balance of current
delinquencies of the affected transactions.

The CreditWatch placements reflect S&P's view of the greater
potential for the affected certificates to be reimbursed for their
interest shortfalls compared with the certificates S&P downgraded.
Standard & Poor's will continue to monitor its ratings on
securities that experience interest shortfalls, and S&P will
adjust the ratings as S&P determine appropriate.

Three of the classes with lowered ratings are from transactions
backed by prime jumbo mortgage loan collateral.  The lowered
ratings consist of the following:

* Three are from prime jumbo transactions (50.00% of all
  downgrades);

* One is from an Alternative-A (Alt-A) transaction;

* One is from a subprime transaction; and

* One is from a resecuritized real estate mortgage investment
  conduit (re-REMIC) transaction.

S&P lowered its ratings on five of the downgraded classes from the
'CC' rating category, and all of the lowered ratings were
speculative grade before the downgrades.

                          Rating Actions

          Alternative Loan Trust Resecuritization 2008-2R
                          Series 2008-2R

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        4-A-1      021482AG9     CCC                  B-

               Banc of America Funding 2007-E Trust
                           Series 2007-E

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        J-B-3      05954DBU9     D                    CC

               Banc of America Mortgage 2007-3 Trust
                           Series 2007-3

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        B-3        05954CBG2     D                    CC

                   Bear Stearns ARM Trust 2003-9
                           Series 2003-9

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        I-A-1      07384MA85     AA/Watch Neg         AA
        I-A-2      07384MB27     AA/Watch Neg         AA
        I-A-3      07384MB43     AA/Watch Neg         AA

              JPMorgan Alternative Loan Trust 2005-A2
                           Series 2005-A2

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        C-B-2      46627MCD7     D                    CC

    Merrill Lynch Mortgage Investors Trust Series MLMI 2004-A1
                           Series 2004-A1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        I-A        59020UAA3     AAA/Watch Neg        AAA
        M-1        59020UAG0     BBB/Watch Neg        BBB

           Morgan Stanley Mortgage Loan Trust 2004-10AR
                          Series 2004-10AR

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        B-4        61748HFP1     D                    CC

          Popular ABS Mortgage Pass-Through Trust 2005-6
                           Series 2005-6

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-2        73316PJH4     D                    CC


* S&P Takes Various Rating Actions on 116 Classes From 44 Deals
---------------------------------------------------------------
Standard & Poor's Ratings Services took various rating actions
affecting 116 classes from 44 manufactured housing asset-backed
securities transactions.  Overall, S&P raised its ratings on four
classes, lowered its ratings on 39 classes, and affirmed its
ratings on 73 classes.

The 44 affected transactions were issued out of these trusts:

* Green Tree Financial Corp. Manufactured Housing Trust;

* Manufactured Housing Contract Senior-Subordinate Pass-Through
  Trust; and

* Manufactured Housing Contract Senior-Subordinate Pass-Through
  Certificates.

All 44 transactions are experiencing higher cumulative net losses
than S&P originally anticipated at deal inception, and most
losses, in S&P's view, are significantly higher.  The increase in
losses can be attributed to increases in both default frequencies
and loss severities because current recoveries are in the 10%-20%
range.

The downgrades reflect S&P's view of both the high default
frequencies and loss severities and the resulting reduction in
available credit enhancement to cover its revised expected losses.
S&P lowered its rating on one class to 'D' due to an interest
shortfall that took place during the June collection period.

The upgrades reflect S&P's assessment of the growth in credit
enhancement because some of the classes in the capital structure
benefit from subordination that continues to grow as a percent of
the current pool balance, which mitigates S&P's higher loss
expectations for these pools.

Most of the affirmations reflect S&P's view of the growth in
credit enhancement levels, which S&P believes are sufficient to
cover its revised loss expectations at the current rating levels.
S&P affirmed a number of other ratings at 'CCC-' or 'CC' to
reflect its view of the classes' high continued vulnerability to
nonpayment of full and timely interest or ultimate principal at a
future date.

                              Table 1

                    Collateral Performance (%)

              As of the June 2010 performance month

                    Pool    Current   90+ day     Lifetime
      Series   Mo.  factor      CNL   delinq.     CNL exp.(i)
      ------   ---  ------  -------   --------    -----------
      1995-2   183    6.44    14.37     1.14      15.00-16.00
      1995-3   182    7.99    15.57     0.99      16.50-17.50
      1995-4   181    8.87    14.69     0.66      16.00-17.00
      1995-5   180    9.30    13.53     0.65      15.00-16.00
      1995-6   179   10.85    13.05     0.71      14.50-15.50
      1995-7   178   10.88    12.81     0.57      14.50-15.50
      1995-8   177   10.62    13.19     1.06      15.00-16.00
      1995-9   176   11.11    12.66     0.70      14.50-15.50
      1995-10  175   11.49    12.56     1.08      14.50-15.50
      1996-1   173   12.01    12.28     0.41      14.50-15.50
      1996-2   172   13.22    15.15     1.18      17.50-18.50
      1996-3   171   13.83    15.89     0.94      18.00-19.00
      1996-4   170   14.06    14.82     0.63      17.00-18.00
      1996-5   169   13.92    15.08     1.03      17.50-18.50
      1996-6   168   13.71    14.91     0.77      17.00-18.00
      1996-7   167   13.57    14.98     0.45      17.00-18.00
      1996-8   166   13.67    14.31     0.57      16.50-17.50
      1996-9   164   14.28    15.60     1.08      18.00-19.00
      1996-10  163   14.16    14.35     0.47      16.50-17.50
      1997-4   157   16.92    15.09     0.89      18.00-19.00
      1997-6   154   17.79    14.53     0.93      17.50-18.50
      1997-7   153   18.10    14.98     0.82      18.00-19.00
      1997-8   151   19.36    15.06     1.14      18.50-19.50
      1998-2   147   19.40    18.06     0.83      22.00-23.00
      1998-3   146   21.56    18.15     0.79      23.00-24.00
      1998-5   144   23.44    15.20     0.80      19.50-20.50
      1998-6   143   22.23    17.75     0.66      23.00-24.00
      1998-8   139   25.46    17.12     0.80      22.50-23.50
      1999-1   137   25.67    18.27     0.77      23.50-24.50
      1999-2   135   23.84    19.22     0.94      24.00-25.00
      1999-3   133   25.99    20.09     1.05      25.50-26.50
      1999-4   132   25.36    22.77     0.99      27.50-28.50
      1999-5   130   24.17    25.35     1.08      29.50-30.50
      1999-6   127   23.88    24.28     1.42      28.50-29.50
      2000-2   121   22.52    25.52     0.93      30.00-31.00
      2000-3   120   23.52    23.74     1.45      28.00-29.00
      2000-4   119   22.99    26.64     1.56      31.50-32.50
      2000-5   117   23.07    24.56     1.89      29.50-30.50
      2000-6   115   22.81    28.32     1.21      33.50-34.50
      2001-1   111   22.17    27.62     1.39      33.00-34.00
      2001-3   106   27.24    25.53     1.61      32.00-33.00
      2001-4   103   25.99    22.97     1.29      29.50-30.50
      2002-1    98   28.14    22.34     1.41      30.00-31.00
      2002-2    96   28.13    21.05     0.89      29.50-30.50

(i) Lifetime CNL expectations based on current performance data.

CNL -- cumulative net loss.

Initial credit enhancement in these transactions was provided
through overcollateralization, subordination, and excess spread
for the senior classes and overcollateralization and excess spread
for the junior classes.  However, the high loss levels have
completely depleted overcollateralization for all 44 transactions
while subordination levels have been reduced by varying degrees
through principal write-downs on the subordinate and, in some
cases, mezzanine classes.

Standard & Poor's will continue to monitor the performance of
these transactions to assess whether, based on S&P's criteria, the
credit enhancement remains adequate to support its ratings on each
class under various stress scenarios.

                          Ratings Raised

      Green Tree Financial Corp. Manufactured Housing Trust

                                      Rating
                                      ------
               Series   Class    To            From
               ------   -----    --            ----
               1995-2   B-1      AA            BBB
               1995-4   M-1      AA+           A
               1995-4   B-1      BB-           B-

         Manufactured Housing Contract Senior-Subordinate
                    Pass-Through Certificates

                                      Rating
                                      ------
               Series   Class    To            From
               ------   -----    --            ----
               2002-1   A-1      BBB+          BB+

                         Ratings Lowered

      Green Tree Financial Corp. Manufactured Housing Trust

                                      Rating
                                      ------
               Series   Class    To            From
               ------   -----    --            ----
               1995-5   B-1      B+            BB-
               1995-8   B-1      CCC           B-
               1996-2   M-1      B-            B+
               1996-3   M-1      CCC-          CCC+
               1996-4   M-1      CCC-          CCC
               1996-5   M-1      CCC-          CCC+
               1996-6   M-1      CCC           B-
               1996-7   M-1      B-            B+
               1996-8   M-1      CCC           B-
               1996-9   M-1      CCC           B-
               1997-4   M-1      CCC-          B-
               1997-6   M-1      CCC-          CCC+
               1997-7   M-1      CCC-          CCC+
               1997-8   M-1      CCC-          CCC+
               1998-3   A-5      BBB-          BBB
               1998-3   A-6      BBB-          BBB
               1998-5   A-1      BBB           BBB+
               1998-5   M-1      CCC-          CCC
               1998-6   A-8      BBB-          BBB
               1998-6   M-1      CCC-          CCC
               1998-8   A-1      B+            BB+
               1998-8   M-1      CCC-          CCC

        Manufactured Housing Contract Senior-Subordinate
                        Pass-Through Trust

                                      Rating
                                      ------
               Series   Class    To            From
               ------   -----    --            ----
               1999-1   M-1      CCC-          CCC
               1999-2   M-1      CCC-          CCC
               1999-3   A-7      CCC-          B-
               1999-3   A-8      CCC-          B-
               1999-3   A-9      CCC-          B-
               1999-4   A-7      CCC-          CCC
               1999-4   A-8      CCC-          CCC
               1999-4   A-9      CCC-          CCC
               1999-5   A-5      CCC-          CCC
               1999-5   A-6      CCC-          CCC
               1999-6   A-1      CCC-          CCC

         Manufactured Housing Contract Senior-Subordinate
                    Pass-Through Certificates

                                      Rating
                                      ------
               Series   Class    To            From
               ------   -----    --            ----
               2000-3   A        CCC-          CCC
               2000-6   A-5      CCC-          B-
               2001-1   A-5      CCC-          B-
               2001-3   M-1*     D             CCC-
               2001-4   M-1      CCC-          CCC
               2002-2   M-2      CCC-          CCC

* As of the July 1, 2010, remittance report, class M-1 had not
  paid full and timely interest when due.

                         Ratings Affirmed

       Green Tree Financial Corp. Manufactured Housing Trust

                    Series   Class    Rating
                    ------   -----    ------
                    1995-3   M-1      AAA
                    1995-3   B-1      BBB-
                    1995-5   M-1      AA+
                    1995-6   M-1      A-
                    1995-6   B-1      B
                    1995-7   M-1      A+
                    1995-7   B-1      B-
                    1995-8   M-1      AA
                    1995-9   M-1      BBB+
                    1995-9   B-1      B-
                    1995-10  M-1      AA-
                    1995-10  B-1      B
                    1996-1   M-1      BBB
                    1996-1   B-1      CCC
                    1996-2   A-4      AAA
                    1996-2   A-5      AAA
                    1996-2   B-1      CCC-
                    1996-3   A-5      AAA
                    1996-3   A-6      AAA
                    1996-3   B-1      CCC-
                    1996-4   A-6      AA
                    1996-4   A-7      AA
                    1996-5   A-6      AAA
                    1996-5   A-7      AAA
                    1996-6   A-6      AAA
                    1996-7   A-6      AAA
                    1996-8   A-6      AAA
                    1996-8   A-7      AAA
                    1996-9   A-5      AAA
                    1996-9   A-6      AAA
                    1996-10  A-5      AAA
                    1996-10  A-6      AAA
                    1996-10  M-1      B+
                    1996-10  B-1      CCC-
                    1997-4   A-5      AA
                    1997-4   A-6      AA
                    1997-4   A-7      AA
                    1997-6   A-6      A+
                    1997-6   A-7      A+
                    1997-6   A-8      A+
                    1997-6   A-9      A+
                    1997-6   A-10     A+
                    1997-7   A-6      A+
                    1997-7   A-7      A+
                    1997-7   A-8      A+
                    1997-7   A-9      A+
                    1997-7   A-10     A+
                    1997-8   A-1      A+
                    1998-2   A-5      BBB
                    1998-2   A-6      BBB
                    1998-2   M-1      CCC-
                    1998-3   M-1      CCC-
                    1998-6   A-7      BBB
                    1998-8   M-2      CCC-

         Manufactured Housing Contract Senior-Subordinate
                        Pass-Through Trust

                    Series   Class    Rating
                    ------   -----    ------
                    1999-1   A-6      B-
                    1999-1   A-7      B-
                    1999-2   A-5      B-
                    1999-2   A-6      B-
                    1999-2   A-7      B-
                    2000-2   A-5      CCC-
                    2000-2   A-6      CCC-

         Manufactured Housing Contract Senior-Subordinate
                    Pass-Through Certificates

                    Series   Class    Rating
                    ------   -----    ------
                    2000-4   A-5      CCC-
                    2000-4   A-6      CCC-
                    2000-5   A-6      CCC-
                    2000-5   A-7      CCC-
                    2001-3   A-4      B-
                    2001-4   A-4      B-
                    2002-1   M-1-A    CCC+
                    2002-1   M-1-F    CCC+
                    2002-1   M-2      CCC-
                    2002-1   B-1      CC
                    2002-2   A-2      BB+
                    2002-2   M-1      B-



                           *********

Monday's edition of the TCR delivers a list of indicative prices
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