TCR_Public/100808.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 8, 2010, Vol. 14, No. 218

                            Headlines

AB SCDO: Fitch Withdraws Ratings on All Classes of Notes
ACAS BUSINESS: Fitch Affirms Ratings on 2007-2 Classes of Notes
ACAS BUSINESS: Fitch Affirms Ratings on Four Classes of Notes
ACAS BUSINESS: Fitch Affirms Ratings on Two Classes of Notes
ACAS BUSINESS: Fitch Affirms Ratings on Three Classes of Notes

ACAS BUSINESS: Fitch Downgrades Ratings on Four Classes of Notes
ACAS CLO: Fitch Affirms Ratings All Classes of Notes
AIRCRAFT FINANCE: Moody's Does Not Take Rating Action on Notes
ALPINE SECURITIZATION: DBRS Keeps Low-B Ratings on 2 Facilities
AMERICREDIT FINANCIAL: Moody's Reviews Ratings on 21 Tranches

AMERICREDIT FINANCIAL: Moody's Reviews Ratings on Six Tranches
ARLO LTD: S&P Downgrades Rating on Class B-1 Certs. to 'CC'
ARLO VI: S&P Downgrades Ratings on Various Notes to 'D'
ASSOCIATED BANK: S&P Removes 'BB+' Ratings From Negative Watch
BANC OF AMERICA: S&P Downgrades Ratings on Six Certificates

BANC OF AMERICA: S&P Downgrades Rating on 2004-BBA4 Certs. to 'D'
BANC OF AMERICA: S&P Downgrades Ratings on Six 2001-PB1 Certs.
BEA CBO: Fitch Downgrades Ratings on Various 1998-2 Notes
BEAR STEARNS: Fitch Downgrades Ratings on 1999-WF2 Certificates
CALLIDUS DEBT: Moody's Upgrades Ratings on Three Classes of Notes

CAPITAL AUTO: Fitch Affirms Ratings on Various Classes of Notes
CARLYLE HIGH: Moody's Upgrades Ratings on Two Classes of Notes
CENTERPOINT ENERGY: Moody's Upgrades Ratings on Debt Obligations
COCONINO COUNTY: Fitch Expects to Assign Ratings on 1998 Bonds
COMMERCIAL MORTGAGE: S&P Downgrades Ratings on 1999-C2 Certs.

CREDIT SUISSE: Fitch Downgrades Rating on 1997-C2 Certificates
CREDIT SUISSE: Fitch Downgrades Ratings on Two 2004-TFL2 Certs.
CREDIT SUISSE: Moody's Affirms Ratings on 10 2001-CKN5 Certs.
CREDIT SUISSE: Moody's Downgrades Ratings on Six 2005-C2 Notes
CSMC SERIES: S&P Corrects Ratings on 2009-3R Notes to 'B'

CSMC SERIES: S&P Corrects Ratings on Two 2009-12R Certificates
DRYDEN VI-LEVERAGED: Moody's Upgrades Ratings on Various Notes
FACTS 2007-1: Moody's Downgrades Ratings on Floating Notes to 'C'
GE CAPITAL: Moody's Confirms Ratings on 2001-1 Certificates
GREENWICH CAPITAL: Moody's Downgrades Ratings on 2004-FL2 Certs.

GS MORTGAGE: DBRS Puts Low-B Provisional Ratings on Class E & F
HARLEY-DAVIDSON MOTORCYCLE: S&P Raises Ratings on Various Notes
HELLER FINANCIAL: Fitch Downgrades Ratings on 1999 PH-1 Certs.
HELLER SBA: Fitch Downgrades Ratings on 1998-1 Certificates
HOMEEQ SERVICING: Fitch Maintains Ratings on 22 Transactions

HSPI DIVERSIFIED: Moody's Junks Ratings on Class S Notes
INLAND EMPIRE: Fitch Affirms Ratings on Various 2007 Bonds
IXIS REAL: Moody's Downgrades Ratings on 10 RMBS Tranches
JP MORGAN: Moody's Affirms Ratings on Seven Pooled Classes
JP MORGAN: Moody's Reviews Ratings on 11 Series 2008-C2 Certs.

JP MORGAN: Moody's Reviews Ratings on 27 2006-LDP9 Certificates
KINGSLAND V: Moody's Upgrades Ratings on Various Classes of Notes
LB-UBS COMMERCIAL: Moody's Affirms Ratings on 2005-C1 Certs.
LB-UBS COMMERCIAL: S&P Downgrades Ratings on Four 2000-C4 Notes
LNR CDO: Moody's Downgrades Ratings on Eight Classes of Notes

MANUFACTURED HOUSING: S&P Corrects Rating on Class A to 'CCC-'
MERRILL LYNCH: Fitch Affirms Ratings on 2004-MKB1 Securities
MERRILL LYNCH: Moody's Reviews Ratings on 2004-KEY2 Certificates
MKP CBO: Fitch Takes Rating Actions on Three Classes of Notes
MORGAN STANLEY: Moody's Reviews Ratings on 16 2005-HQ7 Notes

MORGAN STANLEY: S&P Downgrades Ratings on 2006-6 Notes to 'D'
MORGAN STANLEY: S&P Withdraws 'CCC-' Rating on Class IIC Notes
N-45 FIRST: Moody's Affirms Ratings on Four Classes of Notes
NAVIGATOR CDO: Moody's Upgrades Ratings on Various Notes
OAKWOOD HOMES: S&P Downgrades Ratings on 23 Classes of Certs.

PARCS-R MASTER: S&P Downgrades Rating on Series 2007-19 to 'D'
PARTS 2007-CT1: Fitch Affirms Ratings on Various Classes of Notes
PPM AMERICA: Moody's Upgrades Ratings on Two Classes of Notes
REVE SPC: Moody's Downgrades Ratings on Class C Notes to 'C'
REVE SPC: S&P Downgrades Rating on Class B Notes to 'D'

SALOMON BROTHERS: Moody's Upgrades Ratings on Five 2000-C1 Certs.
SALT CREEK: Fitch Withdraws Ratings on Class B-6$L Notes
SENIOR HOUSING: Moody's Upgrades Senior Unsec. Rating From 'Ba1'
SLM STUDENT: Fitch Affirms Ratings on Various 2003-12 Notes
SLM STUDENT: Fitch Affirms Ratings on Various 2004-8 Bonds

STARTS 2007-21: Moody's Upgrades Ratings on Various Classes
STRUCTURED INVESTMENTS: Moody's Raises Ratings on Series 81 Notes
SYCAMORE CBO: Moody's Downgrades Ratings on Three Classes of Notes
TOWNSHIP OF WEEHAWKEN: Moody's Assigns 'Ba1' Rating on Bonds
UCFC FUNDING: S&P Corrects Rating on Class M-1 Notes to 'D'

VINACASA CLO: Moody's Upgrades Ratings on Four Classes of Notes
WACHOVIA BANK: Moody's Affirms Ratings on Nine 2004-C11 Certs.
WEIRTON MUNICIPAL: Fitch Downgrades Ratings on 2001A Bonds to 'BB'

* Moody's Takes ABCP Rating Actions Ending August 2, 2010
* S&P Affirms Ratings on Eight Classes From Seven NIMS RMBS Deals
* S&P Cuts Ratings on 17 Classes From Eight RMBS Transactions
* S&P Downgrades Ratings on 49 Classes From 16 RMBS Transactions
* S&P Downgrades Ratings on Five Tranches From Four CDO Deals

* S&P Puts Ratings on Tobacco Manufacturers' Notes on Neg. Watch
* S&P Withdraws Ratings on 57 Classes From 31 North American CMBS

                            *********

AB SCDO: Fitch Withdraws Ratings on All Classes of Notes
--------------------------------------------------------
Fitch Ratings has withdrawn its ratings on the notes issued by AB
SCDO Series 2007-1 and AB SCDO Series 2007-7.

On May 1, 2009, Fitch downgraded the ratings of both series of
notes to 'D' from 'C'.  The downgrades were due to losses incurred
following credit events in the reference portfolios.  Fitch has
been notified by Bank of America Merrill Lynch, as trustee, that
final credit event settlements have resulted in a total loss of
principal to the noteholders and the transactions have terminated.

Both AB SCDO Series 2007-1 and AB SCDO Series 2007-7 were
partially funded synthetic collateralized debt obligations
referencing the same portfolio of primarily investment grade
corporate obligations.  At close, proceeds from the issuance of
the notes were used to collateralize credit default swaps between
the issuer and Morgan Stanley Capital Services Inc., the CDS
counterparty.  The portfolio was managed by Alliance Bernstein
L.P.  The transactions had a scheduled termination date of
June 20, 2014.  The ratings of the notes addressed the likelihood
that investors would receive full and timely payments of interest
and ultimate receipt of principal by the scheduled maturity date.

Fitch has withdrawn the 'D' ratings on these classes:

  -- AB SCDO Series 2007-1 class IV A notes;
  -- AB SCDO Series 2007-7 class IV A notes.


ACAS BUSINESS: Fitch Affirms Ratings on 2007-2 Classes of Notes
---------------------------------------------------------------
Fitch Ratings has affirmed one and downgraded four classes of
notes issued by ACAS Business Loan Trust 2007-2.

This review was conducted under the framework described in the
reports also highlighted at the end of the press release.

The downgrades reflect the considerable credit deterioration that
has occurred in the underlying portfolio since Fitch's last rating
review.  Additionally, the rating actions were driven by Fitch's
lower recovery rate assumptions for second lien, junior secured,
and subordinate loans, which were recently updated in the report
'Global Rating Criteria for Corporate CDOs' dated July 5, 2010.

There has been significant credit deterioration in the underlying
portfolio since Fitch's last rating review in May 2009.  Fitch
currently considers 29.3% of the portfolio to be defaulted or
distressed, representing a stark increase from the last review,
when Fitch considered just 6.1% of the total portfolio to be in
default.  As of the May 16, 2010 servicer report the defaulted
loan balance was reported at $96.6 million, compared to
$18 million as of the Feb. 16, 2009 report.  Additionally, Fitch
considers 19% of the performing portfolio to be rated 'CCC+' or
below, up from 10.4% at the last review.

The additional principal amount has increased to $54.9 million,
compared to $3.8 million at the last rating review.  Upon the
occurrence of a default, the APA feature directs part or all of
the excess interest otherwise available to the subordinate notes
to pay down the senior-most notes in an amount equal to the
aggregate balance of defaulted assets in the portfolio.

Although the class A notes have been amortized by approximately
$70.3 million since the last review, in Fitch's opinion the
increase in defaults has offset the improvement in credit
enhancement.  The class A notes will continue to amortize and
benefit from excess spread diversions via the APA.  The class A
notes remain of relatively strong credit quality, in line with a
'AA' rating.  Fitch has assigned an Outlook Stable to these notes.

The class B, C, D, and E notes all remain particularly susceptible
to further negative credit migration in the portfolio.  Increasing
obligor concentration in the underlying portfolio also poses a
risk to these notes, as just 36 obligors remain, 11 of which Fitch
considers to be defaulted or distressed.  Fitch has assigned a
Negative Outlook to the class B, C and D notes due to the
aforementioned risk factors.  Fitch generally does not assign
Rating Outlooks to distressed tranches rated 'CCC' or below.

Fitch notes that the negative credit performance has been
partially offset by the application of excess interest as
described above.  Rating actions would have been materially worse
had this excess spread not been available to amortize the capital
structure.

In the criteria report 'Global Rating Criteria for Corporate CDOs'
released July 5, 2010, Fitch updated its recovery rate assumptions
for corporate assets to reflect the significant compression in
recovery rates in the high yield debt market in 2009.  The updated
framework benchmarks Fitch's recovery rate assumptions to the
extreme lows recently recorded.  In particular, Fitch's reduced
recovery rate assumptions on non-senior debt affected the analysis
of ACAS BLT 2007-2, since junior and subordinate debt represent
approximately 70.6% of the total portfolio.

The class A, B, C, and D notes have been assigned Loss Severity
ratings.  The LS ratings indicate each tranche's potential loss
severity given default, as evidenced by the ratio of tranche size
to the base-case loss expectation for the collateral, as explained
in Fitch's 'Criteria for Structured Finance Loss Severity
Ratings'.  The LS rating should always be considered in
conjunction with the notes' long-term credit rating.

The class E notes were assigned a Recovery Rating as part of this
review.  The class E notes were not projected to recover any
proceeds in a base-case default scenario, and have therefore been
assigned an 'RR6' on Fitch's Recovery Rating scale.  Recovery
Ratings are designed to provide a forward-looking estimate of
recoveries on currently distressed or defaulted structured finance
securities rated 'CCC' or below.  For further detail on Recovery
Ratings, please see Fitch's reports 'Global Surveillance Criteria
for Corporate CDOs' and 'Criteria for Structured Finance Recovery
Ratings'.

ACAS BLT 2007-2 is a collateralized debt obligation that closed on
Aug. 7, 2007, and is managed by American Capital Strategies, Ltd.
The transaction's reinvestment period ended in February 2008.
ACAS BLT 2007-2 is secured by a portfolio composed of middle-
market loans, 70.6% of which are either junior secured or
subordinate, and 29.4% of which are senior secured.  The majority
of these loans are not publicly rated.  Instead, Fitch provides
model-based shadow ratings for the performing loans.  Information
for the model-based shadow ratings was gathered from financial
statements provided to Fitch by ACAS.

The servicer, ACAS, began breaching various loan covenants in
fourth-quarter 2008 due to substantial weakening of the company's
capitalization.  ACAS eventually reached a restructuring agreement
with its unsecured creditors, the terms of which were considered
to be a coercive debt exchange by Fitch, resulting in a downgrade
to 'RD' on June 28, 2010.  Fitch subsequently assigned a post-
restructure Issuer Default Rating of 'B+' to ACAS.

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

  -- $179,805,059 class A notes to 'AA/LS3' from 'AAA', Outlook
     Stable;

  -- $34,874,179 class B notes to 'A/LS5' from 'AA-', Outlook
     Negative;

  -- $58,588,620 class C notes 'BB/LS5' from 'BB+', Outlook
     Negative;

  -- $29,294,310 class D notes to 'B/LS5' from 'B+', Outlook
     Negative.

Fitch affirms and assigns an RR to this class as indicated:

  -- $39,524,069 class E notes 'CCC/RR6'.

All classes were placed on Rating Watch Negative in April 2010 due
to the increasing number of defaults and delinquencies in the
portfolio, coupled with the financial troubles of the servicer
ACAS.  With these actions, all classes are removed from Rating
Watch Negative.


ACAS BUSINESS: Fitch Affirms Ratings on Four Classes of Notes
-------------------------------------------------------------
Fitch Ratings has affirmed four classes of notes issued by ACAS
Business Loan Trust 2007-1.

This review was conducted under the framework described in the
reports also highlighted at the end of the release.

The underlying portfolio of ACAS BLT 2007-1 has experienced a
large degree of credit deterioration since Fitch's last rating
review in May 2009.  However, substantial amortization of the
class A notes has helped mitigate the negative effects of the
collateral deterioration.  Fitch believes that the current ratings
remain indicative of the credit enhancement and structural
protection available to each class of notes.

The notes of ACAS BLT 2007-1 benefit from credit enhancement in
the form of collateral coverage, note subordination, and the
application of excess spread via the additional principal amount.
Upon the occurrence of a default, the APA feature directs part or
all of the excess interest otherwise available to the subordinate
notes to pay down the senior-most notes in an amount equal to the
aggregate balance of defaulted assets in the portfolio.

The credit deterioration in the underlying portfolio since Fitch's
last rating review has been significant.  Fitch currently
considers 27.8% of the portfolio to be defaulted or distressed,
representing an increase from the last review, when Fitch
considered 11.3% of the total portfolio to be in default.  As of
the May 16, 2010 servicer report the defaulted loan balance was
reported at $94.6 million, compared to $18 million as of the
Feb. 16, 2009 report.  Further, the APA now stands at
$46.1 million, compared to $2.2 million at the last rating review.
Finally, Fitch considers 17.1% of the performing portfolio to be
rated 'CCC+' or below, up from 14.5% at the last review.

The continuing amortization of the class A notes has helped offset
the credit deterioration.  The class A notes have received
approximately $101.7 million of principal payments since Fitch's
last rating review, representing almost 29% of their initial
principal balance.  In total, the class A notes have received
55.2% of their initial principal balance since close.  Fitch
calculates that approximately $48.5 million of the principal
payments have been made via diversions of excess spread due to the
APA feature.  The class A notes are well-positioned at their
current rating to withstand the deterioration that has occurred in
the portfolio and will continue to benefit from collateral
amortization and interest diversions via the APA.  Fitch assigns a
Stable Outlook to the class A notes.

The class B, C and D notes also have benefited from the principal
redemption of the class A notes above, as each class's relative
priority has increased.  However, these notes all remain
particularly susceptible to further negative credit migration in
the portfolio.  Increasing obligor concentration in the underlying
portfolio also poses a risk to these notes, as just 33 obligors
remain, 10 of which Fitch considers to be defaulted or distressed.
Fitch assigns a Negative Outlook to these notes due to the
aforementioned risk factors.

In the criteria report 'Global Rating Criteria for Corporate CDOs'
released July 5, 2010, Fitch updated its recovery rate assumptions
for corporate assets to reflect the significant compression in
recovery rates in the high yield debt market in 2009.  The updated
framework benchmarks Fitch's recovery rate assumptions to the
extreme lows recently recorded.  In particular, Fitch's reduced
recovery rate assumptions on non-senior debt affected the analysis
of ACAS BLT 2007-1, since junior and subordinate debt represent
approximately 84.9% of the total portfolio.

The class A, B, C, and D notes have been assigned Loss Severity
ratings.  The LS ratings indicate each tranche's potential loss
severity given default, as evidenced by the ratio of tranche size
to the base-case loss expectation for the collateral, as explained
in Fitch's 'Criteria for Structured Finance Loss Severity
Ratings'.  The LS rating should always be considered in
conjunction with the notes' long-term credit rating.

ACAS BLT 2007-1 is a collateralized debt obligation that closed on
April 24, 2007 and is managed by American Capital Strategies, Ltd.
The transaction's reinvestment period ended in November 2007.
ACAS BLT 2007-1 is secured by a portfolio composed of middle-
market loans, 84.9% of which are either junior secured or
subordinate, and 15.1% of which are senior secured.  The majority
of these loans are not publicly rated.  Instead, Fitch provides
model-based shadow ratings for the performing loans.  Information
for the model-based shadow ratings was gathered from financial
statements provided to Fitch by ACAS.

The servicer, ACAS, began breaching various loan covenants in
4Q'08 due to substantial weakening of the company's
capitalization.  ACAS eventually reached a restructuring agreement
with its unsecured creditors, the terms of which were considered
to be a coercive debt exchange by Fitch, resulting in a downgrade
to 'RD' on June 28, 2010.  Fitch subsequently assigned a post-
restructure Issuer Default Rating of 'B+' to ACAS.

Fitch affirms and assigns Loss Severity ratings and Rating
Outlooks to these classes as indicated:

  -- $157,246,499 class A notes at 'AA/LS4'; Outlook Stable;
  -- $36,095,289 class B notes at 'A/LS5'; Outlook Negative;
  -- $64,971,520 class C notes at 'BB/LS5'; Outlook Negative;
  -- $36,095,289 class D notes at 'B/LS5'; Outlook Negative.

All classes were placed on Rating Watch Negative in April 2010 due
to the increasing number of defaults and delinquencies in the
portfolio, coupled with the financial troubles of the servicer
ACAS.  With these actions, all classes are removed from Rating
Watch Negative.


ACAS BUSINESS: Fitch Affirms Ratings on Two Classes of Notes
------------------------------------------------------------
Fitch Ratings has affirmed two and downgraded two classes of notes
issued by ACAS Business Loan Trust 2004-1.

This review was conducted under the framework described in the
reports also highlighted at the end of the press release.

The affirmations reflect the sufficient credit enhancement
available to the class A and B notes in the form of collateral
coverage, note subordination, and the application of excess spread
via the additional principal amount.  Upon the occurrence of a
default, the APA feature directs part or all of the excess
interest otherwise available to the subordinate notes to pay down
the senior-most notes in an amount equal to the aggregate balance
of defaulted assets in the portfolio.

At the last payment date on July 25, 2010, approximately
$29.7 million was paid toward class A principal, of which
$4.9 million represented excess interest proceeds.  To date, Fitch
calculates that approximately $43.7 million of excess interest
proceeds have been used to pay class A principal.  In total, the
class A notes have been paid down 92.6% of their initial principal
balance, as only $22.5 million of these notes remain outstanding.

The class B notes are next in line to receive principal payments
once the class A notes have been paid in full.  As the class B
notes represent a relatively small tranche and benefit from
significant collateral coverage, they appear to be well positioned
against the deterioration that has occurred in the portfolio.
Fitch considers the performing portfolio (excluding defaulted and
distressed assets) to be $178.8 million, compared to a combined
class A and B note balance of $56.2 million.  The class B notes
will benefit from continued collateral amortization and interest
diversions via the APA once the class A notes are paid in full.
Fitch has assigned a Stable Outlook to the class A and B notes.

The downgrades of the class C and D notes were driven by the
considerable negative credit migration that has occurred since
Fitch's last rating review in April 2009.  Additionally, the
rating actions were driven by Fitch's lower recovery rate
assumptions for second lien, junior secured, and subordinate
loans, which were recently updated in the report 'Global Rating
Criteria for Corporate CDOs' dated July 5, 2010.  Finally, there
is significant obligor concentration risk present in the
underlying portfolio, as only 17 performing obligors and 10
defaulted or distressed obligors remain.  The Outlook for the
class C and D notes is Negative.

The credit deterioration in the underlying portfolio since Fitch's
last rating review has been significant.  Fitch currently
considers 32.2% of the portfolio to be defaulted or distressed,
representing a stark increase from Fitch's last review, when just
9.4% of the portfolio was in default.  As of the July 25, 2010
servicer report the defaulted loan balance was reported at
$75.5 million, compared to $28.4 million as of the Jan. 25, 2009
report.  Further, the APA now stands at $31.7 million, compared to
$11.3 million at the last rating review.  Additionally, Fitch
considers 15.5% of the performing portfolio to be rated 'CCC+' or
below, up from 9.4% at the last review.

Fitch notes that the negative credit performance has been
partially offset by the application of excess interest as
described above.  Rating actions would have been materially worse
had this excess spread not been available to amortize the capital
structure.

In the criteria report 'Global Rating Criteria for Corporate CDOs'
released July 5, 2010, Fitch updated its recovery rate assumptions
for corporate assets to reflect the significant compression in
recovery rates in the high yield debt market in 2009.  The updated
framework benchmarks Fitch's recovery rate assumptions to the
extreme lows recently recorded.  In particular, Fitch's reduced
recovery rate assumptions on non-senior debt affected the analysis
of ACAS BLT 2004-1, since junior and subordinate debt represent
approximately 88.8% of the total portfolio.

The class A, B, and C notes have been assigned Loss Severity
ratings.  The LS ratings indicate each tranche's potential loss
severity given default, as evidenced by the ratio of tranche size
to the base-case loss expectation for the collateral, as explained
in Fitch's 'Criteria for Structured Finance Loss Severity
Ratings'.  The LS rating should always be considered in
conjunction with the notes' long-term credit rating.

The class D notes were assigned a Recovery Rating based on the
total discounted future cash flows projected to be available to
these bonds in a base-case default scenario.  These discounted
cash flows of approximately $23.7 million yielded an ultimate
recovery projection in a range between 31% and 50%, which is
representative of an 'RR4' on Fitch's Recovery Rating scale.
Recovery Ratings are designed to provide a forward-looking
estimate of recoveries on currently distressed or defaulted
structured finance securities rated 'CCC' or below.  For further
detail on Recovery Ratings, please see Fitch's reports 'Global
Surveillance Criteria for Corporate CDOs' and 'Criteria for
Structured Finance Recovery Ratings'.

ACAS BLT 2004-1 is a collateralized debt obligation that closed on
Dec. 2, 2004 and is managed by American Capital Strategies, Ltd.
The transaction's reinvestment period ended in January 2007.  ACAS
BLT 2004-1 is secured by a portfolio composed of middle-market
loans, 88.8% of which are either junior secured or subordinate,
and 11.2% of which are senior secured.  The majority of these
loans are not publicly rated.  Instead, Fitch provides model-based
shadow ratings for the performing loans.  Information for the
model-based shadow ratings was gathered from financial statements
provided to Fitch by ACAS.

The servicer, ACAS, began breaching various loan covenants in
fourth-quarter 2008 due to substantial weakening of the company's
capitalization.  ACAS eventually reached a restructuring agreement
with its unsecured creditors, the terms of which were considered
to be a coercive debt exchange by Fitch, resulting in a downgrade
to 'RD' on June 28, 2010.  Fitch subsequently assigned a post-
restructure Issuer Default Rating of 'B+' to ACAS.

Fitch affirms, assigns LS ratings and Rating Outlooks to these
classes as indicated:

  -- $22,469,395 class A notes 'AAA/LS5', Outlook Stable;
  -- $33,750,000 class B notes 'AA/LS5', Outlook Stable.

Fitch downgrades, assigns an LS rating and a Rating Outlook to
this class as indicated:

  -- $73,750,000 class C notes to 'BB/LS4' from 'BBB', Outlook
     Negative.

Fitch downgrades and assigns an RR to this class as indicated:

  -- $50,000,000 class D notes to 'CCC/RR4' from 'B' (principal-
     only rating).

All classes were placed on Rating Watch Negative in April 2010 due
to the increasing number of defaults and delinquencies in the
portfolio, coupled with the financial troubles of the servicer
ACAS.  With these actions, all classes are removed from Rating
Watch Negative.


ACAS BUSINESS: Fitch Affirms Ratings on Three Classes of Notes
--------------------------------------------------------------
Fitch Ratings has affirmed three and downgraded three classes of
notes issued by ACAS Business Loan Trust 2005-1.

This review was conducted under the framework described in the
reports also highlighted at the end of the release.

The affirmations reflect the sufficient credit enhancement
available to the class A-1, A-2A, and A-2B (collectively, class A;
class A-2A and class A-2B collectively, class A-2) notes in the
form of collateral coverage, note subordination, and the
application of excess spread via the additional principal amount.
Upon the occurrence of a default, the APA feature directs part or
all of the excess interest otherwise available to the subordinate
notes to pay down the senior-most notes in an amount equal to the
aggregate balance of defaulted assets in the portfolio.

ACAS BLT 2005-1 generates significant excess spread due to a
combination of high-interest-yielding assets and relatively low-
cost liabilities, including 17% of the initial capital structure
that does not accrue periodic interest payments.  At the last
payment date on July 25, 2010, approximately $87.8 million was
paid toward class A principal, of which $19.3 million represented
excess interest proceeds.  To date, Fitch calculates that
approximately $133.7 million of excess interest proceeds have been
used to pay class A principal.  In total, the class A notes have
been paid down 45.5% of their initial aggregate principal balance.
The class A notes are well-positioned against the deterioration
that has occurred in the portfolio and will continue to benefit
from collateral amortization and interest diversions via the APA.

Class A principal is paid pro rata to the class A-1 notes and the
class A-2 notes based on their respective outstanding principal
balances.  Within the class A-2 notes, principal proceeds are
applied first to class A-2A and second to class A-2B.  The class
A-2A notes effectively have a shorter duration than the class A-1
and class A-2B notes, and have been assigned a Stable Outlook.
The class A-1 and class A-2B notes have been assigned Negative
Outlooks due to their longer anticipated exposure to the
deteriorating portfolio.

The downgrades of the class B, C, and D notes were driven by the
considerable negative credit migration that has occurred since
Fitch's last rating review in April 2009.  Additionally, the
rating actions were driven by Fitch's lower recovery rate
assumptions for second lien, junior secured, and subordinate
loans, which were recently updated in the report 'Global Rating
Criteria for Corporate CDOs' dated July 5, 2010.  The Outlook for
these notes is Negative.

The credit deterioration in the underlying portfolio since Fitch's
last rating review has been significant.  Fitch currently
considers 35.1% of the portfolio to be defaulted or distressed,
representing a stark increase from Fitch's last review, when just
3.2% of the portfolio was in default.  As of the July 25, 2010
servicer report the defaulted loan balance was reported at
$244.3 million, compared to $31.6 million as of the Jan.  25, 2009
report.  Further, the APA now stands at $110.6 million, compared
to $0 at the last rating review.  Additionally, Fitch considers
9.4% of the performing portfolio to be rated 'CCC+' or below.

Fitch notes that the negative credit performance has been
partially offset by the application of excess interest as
described above.  Rating actions would have been materially worse
had this excess spread not been available to amortize the capital
structure.

In the criteria report 'Global Rating Criteria for Corporate CDOs'
released July 5, 2010, Fitch updated its recovery rate assumptions
for corporate assets to reflect the significant compression in
recovery rates in the high yield debt market in 2009.  The updated
framework benchmarks Fitch's recovery rate assumptions to the
extreme lows recently recorded.  In particular, Fitch's reduced
recovery rate assumptions on non-senior debt affected the analysis
of ACAS BLT 2005-1, since junior and subordinate debt represent
approximately 75.9% of the total portfolio.

The class A, B, and C notes have been assigned Loss Severity
ratings.  The LS ratings indicate each tranche's potential loss
severity given default, as evidenced by the ratio of tranche size
to the base-case loss expectation for the collateral, as explained
in Fitch's 'Criteria for Structured Finance Loss Severity
Ratings'.  The LS rating should always be considered in
conjunction with the notes' long-term credit rating.

The class D notes were assigned a Recovery Rating based on the
total discounted future cash flows projected to be available to
these bonds in a base-case default scenario.  These discounted
cash flows of approximately $30 million yielded an ultimate
recovery projection in a range between 31% and 50%, which is
representative of an 'RR4' on Fitch's Recovery Rating scale.
Recovery Ratings are designed to provide a forward-looking
estimate of recoveries on currently distressed or defaulted
structured finance securities rated 'CCC' or below.  For further
detail on Recovery Ratings, please see Fitch's reports 'Global
Surveillance Criteria for Corporate CDOs' and 'Criteria for
Structured Finance Recovery Ratings'.

ACAS BLT 2005-1 is a collateralized debt obligation that closed on
Oct.  4, 2005 and is managed by American Capital Strategies, Ltd
(ACAS).  The transaction's reinvestment period ended in January
2009.  ACAS BLT 2005-1 is secured by a portfolio composed of
middle-market loans, 75.9% of which are either junior secured or
subordinate, and 24.1% of which are senior secured.  The majority
of these loans are not publicly rated.  Instead, Fitch provides
model-based shadow ratings for the performing loans.  Information
for the model-based shadow ratings was gathered from financial
statements provided to Fitch by ACAS.

The servicer, ACAS, began breaching various loan covenants in
4Q'08 due to substantial weakening of the company's
capitalization.  ACAS eventually reached a restructuring agreement
with its unsecured creditors, the terms of which were considered
to be a coercive debt exchange by Fitch, resulting in a downgrade
to 'RD' on June 28, 2010.  Fitch subsequently assigned a post-
restructure Issuer Default Rating of 'B+' to ACAS.

Fitch affirms and assigns Loss Severity ratings and Rating
Outlooks to these classes as indicated:

  -- $236,936,735 class A-1 notes at 'AAA/LS3'; Outlook Negative;
  -- $58,936,430 class A-2A notes at 'AAA/LS3'; Outlook Stable;
  -- $50,000,000 class A-2B notes at 'AAA/LS3'; Outlook Negative.

Fitch downgrades and assigns LS ratings and Rating Outlooks to
these classes as indicated:

  -- $50,000,000 class B notes to 'A/LS5' from 'AA'; Outlook
     Negative;

  -- $145,000,000 class C notes to 'BB/LS5' from 'BBB'; Outlook
     Negative.

Fitch downgrades and assigns a Recovery Rating to this class as
indicated:

  -- $90,000,000 class D notes to 'CCC/RR4' from 'B+' (principal
     only rating).

All classes were placed on Rating Watch Negative in April 2010 due
to the increasing number of defaults and delinquencies in the
portfolio, coupled with the financial troubles of the servicer
ACAS.  With these actions, all classes are removed from Rating
Watch Negative.


ACAS BUSINESS: Fitch Downgrades Ratings on Four Classes of Notes
----------------------------------------------------------------
Fitch Ratings has downgraded four classes of notes issued by ACAS
Business Loan Trust 2006-1.

This review was conducted under the framework described in the
reports also highlighted at the end of the press release.

The downgrades reflect the considerable credit deterioration that
has occurred in the underlying portfolio since Fitch's last rating
review.  Additionally, the rating actions were driven by Fitch's
lower recovery rate assumptions for second lien, junior secured,
and subordinate loans, which were recently updated in the Fitch
report 'Global Rating Criteria for Corporate CDOs' dated July 5,
2010.

There has been significant credit deterioration in the underlying
portfolio since Fitch's last rating review in April 2009.  Fitch
currently considers 25.7% of the portfolio to be defaulted or
distressed, representing a stark increase from Fitch's last
review, when just 3% of the portfolio was in default.  As of the
May 26, 2010 servicer report the defaulted loan balance was
reported at $106.6 million, compared to $15 million as of the Feb.
26, 2009 report.  Additionally, Fitch considers 26.5% of the
performing portfolio to be rated 'CCC+' or below, up from 10.8% at
the last review.

The additional principal amount has increased to $57.5 million,
compared to $0 at the last rating review.  Upon the occurrence of
a default, the APA feature directs part or all of the excess
interest otherwise available to the subordinate notes to pay down
the senior-most notes in an amount equal to the aggregate balance
of defaulted assets in the portfolio.

Although the class A notes have been amortized by approximately
$69 million since the last review, in Fitch's opinion the increase
in defaults over this time has prevented any meaningful increase
in credit enhancement to the notes.  Combined with the significant
exposure to assets rated 'CCC+' or below, Fitch views the risk to
all notes as having increased.  Fitch also recognizes the obligor
concentration risk posed by the portfolio of just 40 obligors, 12
of which Fitch considers to be defaulted or distressed.  Fitch has
assigned Negative Outlooks to all of the notes to reflect these
risk factors.

Fitch notes that the negative credit performance has been
partially offset by the application of excess interest as
described above.  Rating actions would have been materially worse
had this excess spread not been available to amortize the capital
structure.

In the criteria report 'Global Rating Criteria for Corporate CDOs'
released July 5, 2010, Fitch updated its recovery rate assumptions
for corporate assets to reflect the significant compression in
recovery rates in the high yield debt market in 2009.  The updated
framework benchmarks Fitch's recovery rate assumptions to the
extreme lows recently recorded.  In particular, Fitch's reduced
recovery rate assumptions on non-senior debt affected the analysis
of ACAS BLT 2006-1, since junior and subordinate debt represent
approximately 81.3% of the total portfolio.

The class A, B, and C notes have been assigned Loss Severity
ratings.  The LS ratings indicate each tranche's potential loss
severity given default, as evidenced by the ratio of tranche size
to the base-case loss expectation for the collateral, as explained
in Fitch's 'Criteria for Structured Finance Loss Severity
Ratings'.  The LS rating should always be considered in
conjunction with the notes' long-term credit rating.

The class D notes were assigned a Recovery Rating based on the
total discounted future cash flows projected to be available to
these bonds in a base-case default scenario.  These discounted
cash flows of approximately $8.1 million yielded an ultimate
recovery projection in a range between 11% and 30%, which is
representative of an 'RR5' on Fitch's Recovery Rating scale.
Recovery Ratings are designed to provide a forward-looking
estimate of recoveries on currently distressed or defaulted
structured finance securities rated 'CCC' or below.  For further
detail on Recovery Ratings, please see Fitch's reports 'Global
Surveillance Criteria for Corporate CDOs' and 'Criteria for
Structured Finance Recovery Ratings'.

ACAS BLT 2006-1 is a collateralized debt obligation that closed on
July 28, 2006 and is managed by American Capital Strategies, Ltd
(ACAS).  The transaction's reinvestment period ended in August
2009.  ACAS BLT 2006-1 is secured by a portfolio composed of
middle-market loans, 81.3% of which are either junior secured or
subordinate, and 18.7% of which are senior secured.  The majority
of these loans are not publicly rated.  Instead, Fitch provides
model-based shadow ratings for the performing loans.  Information
for the model-based shadow ratings was gathered from financial
statements provided to Fitch by ACAS.

The servicer, ACAS, began breaching various loan covenants in
fourth-quarter 2008 due to substantial weakening of the company's
capitalization.  ACAS eventually reached a restructuring agreement
with its unsecured creditors, the terms of which were considered
to be a coercive debt exchange by Fitch, resulting in a downgrade
to 'RD' on June 28, 2010.  Fitch subsequently assigned a post-
restructure issuer default rating of 'B+' to ACAS.

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

  -- $206,945,984 class A notes to 'A/LS4' from 'AAA', Outlook
     Negative;

  -- $37,000,000 class B notes 'BBB/LS5' from 'AA', Outlook
     Negative;

  -- $72,500,000 class C notes to 'B/LS5' from 'BB+', Outlook
     Negative.

Fitch downgrades and assigns an RR to this class as indicated:

  -- $35,500,000 class D notes to 'CCC/RR5' from 'B+'.

All classes were placed on Rating Watch Negative in April 2010 due
to the increasing number of defaults and delinquencies in the
portfolio, coupled with the financial troubles of the servicer
ACAS.  With these actions, all classes are removed from Rating
Watch Negative.


ACAS CLO: Fitch Affirms Ratings All Classes of Notes
----------------------------------------------------
Fitch Ratings affirms all classes of notes issued by ACAS CLO
2007-1 Ltd./Corp.

This review was conducted under the framework described in the
reports 'Global Rating Criteria for Corporate CDOs', 'Global
Structured Finance Rating Criteria', 'Global Criteria for Cash
Flow Analysis in Corporate CDOs', 'Global Surveillance Criteria
for Corporate CDOs', and 'Criteria for Structured Finance Loss
Severity Ratings'.

The affirmation of the ratings is attributable to improved credit
enhancement available to the notes, which was partially offset by
some deterioration in the credit quality of the portfolio.  All
coverage tests improved and continue to pass as of the last
trustee report dated July 8, 2010.  Since the last rating review,
the manager has purchased additional collateral at a discount to
par.  Currently there are no reported defaults in the portfolio,
which is down from 3.7% at the last rating review.  There has been
some deterioration in the credit quality of the portfolio since
the last rating review in April 2009.  Approximately 12.4% of the
portfolio is considered 'CCC+' or lower by Fitch, up from 10.3% at
the last rating review.  Fitch considers the weighted average
rating of the underlying portfolio to have worsened slightly to
'B/B-' from 'B' at the last rating review.  Fitch calculates a
different weighted average rating than the 'B+/B' rating measured
by the trustee due to a difference in calculation methods outlined
in Fitch's current rating criteria and the transaction's
Indenture.

The Rating Outlook on the class C and class D notes remains
Negative to reflect the notes' exposure to future deterioration in
portfolio credit quality and losses.  These notes also show some
sensitivity to rising interest rates in the cash flow analysis.

The notes were also assigned Loss Severity ratings.  The LS
ratings indicate each tranche's potential loss severity given
default, as evidenced by the ratio of tranche size to the base-
case loss expectation for the collateral, as explained in Fitch's
'Criteria for Structured Finance Loss Severity Ratings'.  The LS
rating should always be considered in conjunction with the notes'
long-term credit rating.  Fitch does not assign LS ratings to
tranches rated 'CCC' and below.

ACAS CLO 2007-1, Ltd., is a cash flow CLO that closed April 26,
2007, and is managed by American Capital Asset Management, LLC.
The portfolio is currently composed of 92.1% senior secured loans,
3.1% senior secured debt, 3.3% junior secured/mezzanine debt, and
1.6% structured finance assets.  Approximately 21.8% of the
collateral is shadow-rated by Fitch.  ACAS CLO 2007-1 is currently
in its reinvestment period through April 20, 2014, during which
time principal proceeds are used to reinvest in collateral.
During the reinvestment period, there is a reinvestment OC test,
which will divert up to 50% of excess interest to invest in
additional collateral to build credit enhancement for the notes
should the test fail.

Fitch affirms and assigns LS ratings to these notes as indicated:

  -- $110,750,000 class A-1 notes at 'AAA/LS3'; Outlook Stable;
  -- $135,000,000 class A-1-S notes at 'AAA/LS2'; Outlook Stable;
  -- $33,750,000 class A-1-J notes at 'AAA/LS3'; Outlook Stable;
  -- $25,000,000 class A-2 notes at 'AA/LS4'; Outlook Stable;
  -- $22,000,000 class B notes at 'A/LS4'; Outlook Stable;
  -- $21,000,000 class C notes at 'BBB/LS4'; Outlook Negative;
  -- $15,500,000 class D notes at 'B/LS5'; Outlook Negative.


AIRCRAFT FINANCE: Moody's Does Not Take Rating Action on Notes
--------------------------------------------------------------
Moody's Investors Service stated that its ratings on the notes
issued by Aircraft Finance Trust, are not being downgraded or
withdrawn as a result of certain concentration limits being
exceeded.  The referenced ratings are AFT, Series 1999-1, Class A-
1 rated Caa1, Class A-2 rated Ba3, and Class B through D each
rated C.

The Servicer, GE Capital Aviation Services, Limited is placing one
Boeing 737-300 with Air Nigeria.  As a result two concentration
limits would be exceeded: undesignated countries will exceed the
20% limit, and undesignated countries rated below Baa2 will exceed
the 10% limit.  According to the transaction documents, the
portfolio should comply at all times with the concentration
limits.  If a prospective lease would result in one or more
concentration limits being exceeded, such lease may be executed if
a rating agency confirmation is obtained.

In assessing the potential impact on the ratings of the notes,
Moody's focused on: the change to the credit profile and
concentrations of the lessees in the pool in light of the current
ratings on the notes, which are lower than the original ratings;
the experience and expertise of GECAS in placing, monitoring and
repossessing of aircraft; and, the change in demand for the type
of aircraft involved.  With respect to the last factor, Moody's
note that in the past few years the demand for such aircraft have
declined dramatically and so potential lessees are likely to come
from countries and airlines with credit profiles similar to
Nigeria and Air Nigeria.

Moody's concluded that the execution of the proposed lease would
not have an adverse effect on the credit quality of the rated
securities.  However, Moody's is not expressing an opinion as to
whether the lease could have other, non credit-related effects
that investors may or may not view positively.


ALPINE SECURITIZATION: DBRS Keeps Low-B Ratings on 2 Facilities
---------------------------------------------------------------
DBRS has confirmed the rating of R-1 (high) for the Commercial
Paper (CP) issued by Alpine Securitization Corp. (Alpine), an
asset-backed commercial paper (ABCP) vehicle administered by
Credit Suisse, New York branch.  In addition, DBRS has confirmed
the ratings and revised the tranche sizes of the aggregate
liquidity facilities (the Liquidity) provided to Alpine by Credit
Suisse.

The $6,107,687,207 aggregate liquidity facilities are tranched as
follows:

  -- $5,761,816,209 rated AAA
  -- $70,487,597 rated AA
  -- $41,264,756 rated A
  -- $62,247,105 rated BBB
  -- $61,911,182 rated BB
  -- $23,602,547 rated B
  -- $86,357,811 unrated

The ratings are based on April 30, 2010 data.

The CP rating reflects the AAA credit quality of Alpine's asset
portfolio.  The updated credit quality aspect of the CP rating is
based on both the portfolio of assets and the available program-
wide credit enhancement (PWCE).  The rationale for the CP rating
is based on the updated AAA credit quality assessment as well as
DBRS' prior and ongoing review of legal, operational and liquidity
risks associated with Alpine's overall risk profile.

The ratings assigned to the Liquidity reflect the credit quality
of Alpine's asset portfolio based on an analysis that assesses
each transaction to a term standard.  The tranching of the
Liquidity reflects the credit risk of the portfolio at each rating
level.  The tranche sizes are expected to vary each month based on
changes in portfolio composition.

For Alpine, both the CP and the Liquidity ratings use DBRS'
simulation methodology, which was developed to analyze diverse
ABCP conduit portfolios.  This analysis uses the DBRS CDO Toolbox
simulation model, with adjustments to reflect the unique structure
of an ABCP conduit and its underlying assets.  DBRS determines
attachment points for risk based on an analysis of the portfolio
and models the portfolio based on key inputs such as asset
ratings, asset tenors and recovery rates.  The attachment points
determine the portion of the exposure rated AAA, AA, A through B
as well as unrated.

DBRS models the portfolio on an ongoing basis to reflect changes
in Alpine's portfolio composition and credit quality.  The rating
results are updated and posted on the DBRS website.


AMERICREDIT FINANCIAL: Moody's Reviews Ratings on 21 Tranches
-------------------------------------------------------------
Moody's has placed on review for possible upgrade twenty one
tranches from eleven auto loan securitizations sponsored by
AmeriCredit Financial Services, Inc between 2006 and 2008.  Even
though overall pool losses are now projected to exceed original
pool loss expectations, the credit enhancement calculated as a
percentage of the current pool balance supporting the affected
securities in these transactions has increased substantially due
to the non-declining nature of the cash reserve accounts.

Moody's expects AmeriCredit Automobile Receivables Trust 2006-1 to
incur a lifetime cumulative net loss between 15.00% and 15.50%,
compared to Moody's original expectation at issuance of 12.75%.
This transaction has paid down significantly, with a pool factor
of approximately 10%.  Total hard credit enhancement for Cl. D
(excluding excess spread of approximately 9% per annum) as a
percentage of the remaining collateral balance is approximately
39%.

For the three wrapped transactions that were issued in 2006,
Moody's currently expects lifetime CNLs to range between 15.00%
and 18.00% (expressed as a percentage of the original pool
balances).  This is up from the CNL expectations of between 10.00%
and 12.25% at issuance for these transactions.  The pool factors
on these transactions range between approximately 15% and 21%.
Total hard credit enhancements for the Cl. A certificates (that
exclude excess spread that ranges between 8% and 9% per annum) as
a percentage of the remaining collateral balance, ranges between
22% and 27%.

For the four wrapped transactions that were issued in 2007,
Moody's currently expects lifetime CNLs to range between 17.50%
and 20.50% (expressed as a percentage of the original pool
balance).  This is up from the CNL expectations of between 10.75%
and 11.25% at issuance for these transactions.  The pool factors
on these transactions range between approximately 23% and 35%.
Total hard credit enhancements for the Cl. A certificates
(excluding excess spread that ranges between 8% and 10% per annum)
as a percentage of the remaining collateral balance, ranges
between 20% and 28%.

Moody's expects the AmeriCredit Automobile Receivables Trust 2008-
A-F (wrapped transaction) to incur a lifetime CNL of between
19.50% and 21.00%.  Moody's CNL expectation was 15.25% at
issuance.  The pool factor for this transaction is approximately
46%.  Total hard credit enhancement for Cl. A (excluding excess
spread of approximately 8% per annum) as a percentage of the
remaining collateral balance is approximately 40%.

Moody's expects AmeriCredit Automobile Receivables Trust 2008-1 to
incur a lifetime CNL of between 18.50% and 20.00%.  Moody's loss
expectation was 15.50% at issuance.  The pool factor for this
transaction is approximately 55%.  Total hard credit enhancement
for Cl. B (excluding excess spread of approximately 5% per annum)
as a percentage of the remaining collateral balance is
approximately 55%.  Total hard credit enhancement for Cl.  C
(excluding excess spread of approximately 5% per annum) as a
percentage of the remaining collateral balance is approximately
45%.

Moody's expects AmeriCredit Automobile Receivables Trust 2008-2 to
incur a lifetime CNL of between 17.50% and 19.00%.  Moody's loss
expectation was 15.50% at issuance.  The pool factor for this
transaction is approximately 58%.  Total hard credit enhancement
for Cl. B (excluding excess spread of approximately 5% per annum)
as a percentage of the remaining collateral balance is
approximately 54%.  Total hard credit enhancement for Cl. C
(excluding excess spread of approximately 5% per annum) as a
percentage of the remaining collateral balance is approximately
45%.

The performance expectations for a given variable 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 the given
range 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 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.  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 transactions' guarantees from monoline
bond insurers.  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: AmeriCredit Automobile Receivables Trust 2006-A-F

  -- Class Description: Class A-4

  -- Current Rating: Aa3; previously on 11/23/2008 Downgraded to
     Aa3 from Aaa

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously on 11/23/2008 Downgraded to Aa3 from Aaa)

  -- Underlying rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 3/18/2008 downgraded to Baa3 from Baa2

Issuer: AmeriCredit Automobile Receivables Trust 2006-1

  -- Class Description: Class D

  -- Current Rating: Aa1, Placed Under Review for Possible
     Upgrade; previously on 2/10/2008 Upgraded to Aa1from Baa2

Issuer: AmeriCredit Automobile Receivables Trust 2006-B-G

  -- Class Description: Class A-4

  -- Current Rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 3/31/2008 downgraded to Baa3 from A3

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

  -- Underlying rating: Baa3, previously on 03/18/2008 downgraded
     to Baa3 from Baa1

Issuer: AmeriCredit Automobile Receivables Trust 2006-R-M

  -- Class Description: Class A-2

  -- Current Rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 2/18/2009 downgraded to Baa3 from Baa1

  -- Financial Guarantor: MBIA Insurance Corporation (B3;
     previously on 2/18/2009 Downgraded to B3 from Baa1)

  -- Underlying rating: Baa3, previously on 03/18/2008 downgraded
     to Baa3 from Baa2

  -- Class Description: Class A-3

  -- Current Rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 2/18/2009 downgraded to Baa3 from Baa1

  -- Financial Guarantor: MBIA Insurance Corporation (B3;
     previously on 2/18/2009 Downgraded to B3 from Baa1)

  -- Underlying rating: Baa3, previously on 03/18/2008 downgraded
     to Baa3 from Baa2

Issuer: AmeriCredit Automobile Receivables Trust 2007-A-X

  -- Class Description: Class A-4

  -- Current Rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 6/20/2008 downgraded to Baa3 from A3

  -- Financial Guarantor: Syncora Guarantee Inc., (Ca; previously
     on 3/9/2009 Downgraded to Ca from Caa1)

  -- Underlying rating: Baa3, previously on 03/18/2008 downgraded
     to Baa3 from Baa2

Issuer: AmeriCredit Automobile Receivables Trust 2007-B-F

  -- Class Description: Class A-4

  -- Current Rating: Aa3; previously on 11/23/2008 Downgraded to
     Aa3 from Aaa

  -- Financial Guarantor: Assured Guaranty Municipal Corp (Aa3;
     previously on 11/23/2008 Downgraded to Aa3 from Aaa)

  -- Underlying rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 03/24/2009 downgraded to Baa3 from
     Baa2

Issuer: AmeriCredit Automobile Receivables Trust 2007-C-M

  -- Class Description: Class A-3-A

  -- Current Rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 3/24/2009 downgraded to Baa3 from Baa2

  -- Financial Guarantor: MBIA Insurance Corporation (B3;
     previously on 2/18/2009 Downgraded to B3 from Baa1)

  -- Underlying rating: Baa3, previously on 3/24/2009 downgraded
     to Baa3 from Baa2

  -- Class Description: Class A-3-B

  -- Current Rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 3/24/2009 downgraded to Baa3 from Baa2

  -- Financial Guarantor: MBIA Insurance Corporation (B3;
     previously on 2/18/2009 Downgraded to B3 from Baa1)

  -- Underlying rating: Baa3, previously on 03/24/2009 downgraded
     to Baa3 from Baa2

  -- Class Description: Class A-4-A

  -- Current Rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 3/24/2009 downgraded to Baa3 from Baa2

  -- Financial Guarantor: MBIA Insurance Corporation (B3;
     previously on 2/18/2009 Downgraded to B3 from Baa1)

  -- Underlying rating: Baa3, previously on 03/24/2009 downgraded
     to Baa3 from Baa2

  -- Class Description: Class A-4-B

  -- Current Rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 3/24/2009 downgraded to Baa3 from Baa2

  -- Financial Guarantor: MBIA Insurance Corporation (B3;
     previously on 2/18/2009 Downgraded to B3 from Baa1)

  -- Underlying rating: Baa3, previously on 03/24/2009 downgraded
     to Baa3 from Baa2

Issuer: AmeriCredit Automobile Receivables Trust 2007-D-F

  -- Class Description: Class A-3-A

  -- Current Rating: Aa3; previously on 11/23/2008 Downgraded to
     Aa3 from Aaa

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously on 11/23/2008 Downgraded to Aa3 from Aaa)

  -- Underlying rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 03/24/2009 downgraded to Baa3 from
     Baa2

  -- Class Description: Class A-3-B

  -- Current Rating: Aa3; previously on 11/23/2008 Downgraded to
     Aa3 from Aaa

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously on 11/23/2008 Downgraded to Aa3 from Aaa)

  -- Underlying rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 03/24/2009 downgraded to Baa3 from
     Baa2

  -- Class Description: Class A-4-A

  -- Current Rating: Aa3; previously on 11/23/2008 Downgraded to
     Aa3 from Aaa

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously on 11/23/2008 Downgraded to Aa3 from Aaa)

  -- Underlying rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 03/24/2009 downgraded to Baa3 from
     Baa2

  -- Class Description: Class A-4-B

  -- Current Rating: Aa3; previously on 11/23/2008 Downgraded to
     Aa3 from Aaa

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously on 11/23/2008 Downgraded to Aa3 from Aaa)

  -- Underlying rating: Baa3, Placed Under Review for Possible
     Upgrade; previously on 03/24/2009 downgraded to Baa3 from
     Baa2

Issuer: AmeriCredit Automobile Receivables Trust 2008-A-F

  -- Class Description: Class A-3

  -- Current Rating: Aa3; previously on 11/23/2008 Downgraded to
     Aa3 from Aaa

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously on 11/23/2008 Downgraded to Aa3 from Aaa)

  -- Underlying rating: Baa1, Placed Under Review for Possible
     Upgrade; previously on 05/22/2009 downgraded to Baa1 from A3

  -- Class Description: Class A-4

  -- Current Rating: Aa3; previously on 11/23/2008 Downgraded to
     Aa3 from Aaa

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously on 11/23/2008 Downgraded to Aa3 from Aaa)

  -- Underlying rating: Baa1, Placed Under Review for Possible
     Upgrade; previously on 05/22/2009 downgraded to Baa1 from A3

Issuer: AmeriCredit Automobile Receivables Trust 2008-1

  -- Class Description: Class B

  -- Current Rating: Aa2 Placed Under Review for Possible Upgrade;
     previously on 10/13/2008 assigned Aa2

  -- Class Description: Class C

  -- Current Rating: A3 Placed Under Review for Possible Upgrade;
     previously on 10/13/2008 assigned A3

Issuer: AmeriCredit Automobile Receivables Trust 2008-2

  -- Class Description: Class B

  -- Current Rating: Aa2 Placed Under Review for Possible Upgrade;
     previously on 12/1/2008 assigned Aa2

  -- Class Description: Class C

  -- Current Rating: A3 Placed Under Review for Possible Upgrade;
     previously on 12/1/2008 assigned A3


AMERICREDIT FINANCIAL: Moody's Reviews Ratings on Six Tranches
--------------------------------------------------------------
Moody's has placed on review for possible upgrade six tranches
from two auto loan securitizations sponsored by AmeriCredit
Financial Services, Inc in 2007.  Even though overall pool losses
are now projected to exceed original pool loss expectations, the
credit enhancement supporting the affected securities in these
transactions has increased substantially.  In the case of
AmeriCredit Prime Automobile Receivables Trust 2007-2-M,
consideration was also given to prior amendments that, among other
things, resulted in revised credit performance triggers and an
increase in the amount required for the spread (reserve) account
from 3.5% to 4.0% of the initial pool balance.

Moody's expects AmeriCredit Prime Automobile Receivables Trust
2007-1 to incur a lifetime cumulative net loss of between 7.50%
and 8.50% (expressed as a percentage of the original pool
balance).  This is up from Moody's loss expectation of 3.50% at
issuance.  The pool factor for this transaction is approximately
25%.  Total hard credit enhancement for the affected Cl.  B, C and
D securities (excluding excess spread of approximately 4% per
annum) as a percentage of the remaining collateral balance, is
approximately 41%, 28% and 15%, respectively.

For AmeriCredit Prime Automobile Receivables Trust 2007-2-M which
is a wrapped transaction, Moody's currently expects lifetime CNL
to range between 11.50% and 12.50% (expressed as a percentage of
the original pool balance).  This is up from the CNL expectation
of 4.50% at issuance for this transaction.  The pool factor on
this transaction is approximately 35%.  Total hard credit
enhancement for the Cl.  A certificates (that exclude excess
spread of approximately 5% per annum) as a percentage of the
remaining collateral balance is approximately 18%.

The performance expectations for a given variable 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 the given
range 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 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.  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
securities in the absence of the transactions' guarantees from
monoline bond insurers.  The current ratings on the securities 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: AmeriCredit Prime Automobile Receivables Trust 2007-1

  -- Class Description: Class B

  -- Current Rating:Aa2, Placed Under Review for Possible Upgrade;
     previously on 6/26/2009 Confirmed atAa2

  -- Class Description: Class C

  -- Current Rating:A3, Placed Under Review for Possible Upgrade;
     previously on 6/26/2009 downgraded toA3 fromA1

  -- Class Description: Class D

  -- Current Rating:Ba2, Placed Under Review for Possible Upgrade;
     previously on 6/26/2009 downgraded toBa2 fromBaa2

Issuer: AmeriCredit Prime Automobile Receivables Trust 2007-2-M

  -- Class Description: Class A-3

  -- Current Rating:Baa2, Placed Under Review for Possible
     Upgrade; previously on 8/27/2009 confirmed atBaa2

  -- Financial Guarantor: MBIA Insurance Corporation (B3;
     previously on 2/18/2009 Downgraded to B3 from Baa1)

  -- Underlying rating: Baa2, Placed Under Review for Possible
     Upgrade; previously on 8/27/2009 confirmed atBaa2

  -- Class Description: Class A-4-A

  -- Current Rating: Baa2, Placed Under Review for Possible
     Upgrade; previously on 8/27/2009 confirmed atBaa2

  -- Financial Guarantor: MBIA Insurance Corporation (B3;
     previously on 2/18/2009 Downgraded to B3 from Baa1)

  -- Underlying rating: Baa2, Placed Under Review for Possible
     Upgrade; previously on 8/27/2009 confirmed atBaa2

  -- Class Description: Class A-4-B

  -- Current Rating: Baa2, Placed Under Review for Possible
     Upgrade; previously on 8/27/2009 confirmed atBaa2

  -- Financial Guarantor: MBIA Insurance Corporation (B3;
     previously on 2/18/2009 Downgraded to B3 from Baa1)

  -- Underlying rating: Baa2, Placed Under Review for Possible
     Upgrade; previously on 8/27/2009 confirmed atBaa2


ARLO LTD: S&P Downgrades Rating on Class B-1 Certs. to 'CC'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on class B-1
from ARLO Ltd.'s series 2006-B-1 (Prima II-CDO Long/Short) to 'CC'
from 'CCC-'.

The downgrade follows a number of recent losses the transaction
incurred due to credit events affecting underlying reference
entities, which have caused the notes to incur a partial principal
loss.


ARLO VI: S&P Downgrades Ratings on Various Notes to 'D'
-------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on ARLO VI
Ltd.'s 2006-B-1 (Prima-CDO Long/Short), 2006-C-1 (Prima-CDO
Long/Short), 2006-C-2 (Prima-CDO Long/Short), and 2007-B-1
(Wellspring CDO Long/Short) to 'D' from 'CC'.  Concurrently, S&P
withdrew its 'CCC-' rating on class A-1 from series 2006-A-1
(Prima-CDO Long/Short).

The downgrades follow a number of recent losses the transaction
incurred due to credit events affecting underlying reference
entities, which have caused each of the notes to incur a complete
principal loss.

The rating withdrawal follows the complete redemption of the
notes.

                         Ratings Lowered

                           ARLO VI Ltd.
              Series 2006-B-1 (Prima-CDO Long/Short)

                                       Rating
                                       ------
          Class                 To                 From
          -----                 --                 ----
          B-1                   D                  CCC-

                           ARLO VI Ltd.
              Series 2006-C-1 (Prima-CDO Long/Short)

                                       Rating
                                       ------
          Class                 To                 From
          -----                 --                 ----
          C-1                   D                  CC

                           ARLO VI Ltd
              Series 2006-C-2 (Prima-CDO Long/Short)

                                       Rating
                                       ------
          Class                 To                 From
          -----                 --                 ----
          C-2                   D                  CC

                           ARLO VI Ltd.
              Series 2007-B-1 (Wellspring CDO Long/Short)

                                       Rating
                                       ------
          Class                 To                 From
          -----                 --                 ----
          Unfunded              D                  CC
          Tranche 1             D                  CC
          Tranche 2             D                  CC

                         Rating Withdrawn

                           ARLO VI Ltd.
              Series 2006-A-1 (Prima-CDO Long/Short)

                                        Rating
                                        ------
           Class                 To                 From
           -----                 --                 ----
           A-1                   NR                 CCC-

                          NR - Not rated.


ASSOCIATED BANK: S&P Removes 'BB+' Ratings From Negative Watch
--------------------------------------------------------------
Standard & Poor's Ratings Services removed its 'BB+' ratings on
four bond issues that are supported by Associated Bank N.A.'s
letters of credit from CreditWatch with negative implications,
where S&P had placed them on May 11, 2010.

S&P's ratings on the four affected bond issues reflect its long-
term issuer credit rating on Associated Bank ('BB+').  These
ratings also address S&P's assessment of the likelihood of
repayment of principal and interest to maturity based on the
credit support that Associated Bank provides for each bond series
in the form of an LOC.

The rating actions reflect the July 26, 2010, removal of S&P's
'BB+' long-term issuer credit rating on Associated Bank from
CreditWatch negative, where S&P had placed it on April 28, 2010.

Rating adjustments may be precipitated by, among other things,
changes to S&P's rating on any financial institution that is
providing an irrevocable LOC or by amendments to the documentation
governing the obligations.

             Ratings Removed From Creditwatch Negative

                          Howard Village
      US$4.5 mil indl dev rev bnds ser 1999A due 07/01/2020

                               Rating
                               ------
         CUSIP          To                 From
         -----          --                 ----
         44285NAA1      BB+                BB+/Watch Neg

              Illinois Development Finance Authority
  US$4.1 mil var rt dem indl dev rev bnds ser 1997 due 01/01/2018

                               Rating
                               ------
         CUSIP          To                 From
         -----          --                 ----
         451887TR4      BB+                BB+/Watch Neg

      US$7.5 mil var rt dem rev bnds ser 2003 due 10/01/2023

                               Rating
                               ------
         CUSIP          To                 From
         -----          --                 ----
         45189FAR5      BB+                BB+/Watch Neg

                    Illinois Finance Authority
    US$2.5 mil taxable var rt dem rev bnds (Beecher Energy LLC)
                      ser 2006 due 07/01/2026

                               Rating
                               ------
         CUSIP          To                 From
         -----          --                 ----
         45200BZG6      BB+                BB+/Watch Neg


BANC OF AMERICA: S&P Downgrades Ratings on Six Certificates
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes of U.S. commercial mortgage pass-through certificates from
Banc of America Commercial Mortgage Trust 2006-3.

The downgrades reflect interest shortfalls to the transaction.
S&P lowered its ratings on classes B, C, D, E, and F to 'D' due to
recurring interest shortfalls that S&P expects will continue.  S&P
downgraded class A-J to 'CCC+' from 'B+' due to monthly interest
shortfalls, which have averaged approximately $1.1 million since
the Nov. 10, 2009, remittance report, affecting all of the classes
subordinate to the class A-J certificate.  S&P's analysis of the
interest shortfalls considered the significant amount of advances
that remains to be recovered by the master servicer, Bank of
America, for six of the Boscov's assets with the special servicer,
CWCapital Asset Management LLC, as well as the potential timing of
the resolution of the assets with CWCapital.

The five classes that S&P lowered to 'D' have experienced interest
shortfalls for nine months or more.  The recurring interest
shortfalls for the respective certificates are primarily due to
these factors:

* Appraisal subordinate entitlement reductions in effect for three
  specially serviced assets;

* Trust expenses, including property operating expenses, property
  taxes, insurance payments, and legal expenses;

* Nonrecoverable advance declarations;

* Recovery of previous advances made by the master servicer; and

* Special servicing fees.

As of the July 12, 2010, remittance report, the transaction
consisted of 94 loan exposures and two assets with an aggregate
trust balance of $1.938 billion.  There are 13 specially serviced
assets in the pool totaling $180.4 million (9.81% of the aggregate
trust balance).  Two assets ($41.2 million, 2.1%) are real estate
owned and 11 ($139.2 million, 7.3%) are in foreclosure, while 10
appraisal reduction amounts are in effect totaling $129.3 million.

Seven ($115.4 million, 6%) of the assets in foreclosure are
collateralized by properties formerly tenanted by Boscov's.  The
assets are neither cross-collateralized nor cross-defaulted and
were transferred to CWCapital on Aug. 7, 2008, after Boscov's
filed for bankruptcy on Aug. 4, 2008.  Seven of the ARAs
outstanding ($110.4 million) are for the Boscov's assets and, the
master servicer made nonrecoverability determinations on all seven
of these assets.

According to the July 2010 remittance report, the accumulated
outstanding interest shortfalls on classes B, C, D, E, and F are
$6.0 million, and the total accumulated interest shortfall for the
transaction is $15.6 million.  A significant portion of the
monthly interest shortfalls resulted from nonrecoverability
determinations ($619,114) and the recovery of previous advances
($343,949) made by the master servicer for six of the Boscov's
exposures.  Based on S&P's conversations with the master servicer,
it is its understanding that an additional $9.3 million in
advances remain outstanding and are likely to be recouped over
approximately the next 24 months.  However, S&P believes the
timing of the advance recoveries may change as the Boscov's assets
are resolved and depending on the monthly interest available to
the transaction.  According to the special servicer, all seven
properties are considered to be in "good condition" and have been
listed for lease or sale.

A full-building lease for one of the properties, the Boscov's
White Marsh has been signed with Forever 21.  Standard & Poor's
expects a significant loss upon the resolution of these assets.
S&P previously lowered S&P's ratings on eight subordinate classes
to 'D' due to the interest shortfalls affecting the transaction.

The remaining six exposures with the special servicer
($65.0 million, 3.81%) include the Fair Lake Promenade asset
($31.6 million, 1.6%), which is the largest asset with the special
servicer.  The exposure was transferred to special servicing on
April 8, 2009, due to imminent default and became REO on Nov. 24,
2009.  The property consists of a 137,107-sq.-ft. retail property
in Fairfax, Va.  As of the six months ended June 2009, the
property reported a debt service coverage of 0.41x and 53%
occupancy.  An ARA totaling $14.6 million is in effect for this
asset.  Standard & Poor's expect a significant loss upon the
resolution of this asset.  The remaining five assets, each
individually comprise less than 0.50% of the total pool balance.

                         Ratings Lowered

             Banc of America Commercial Mortgage Trust
    Commercial mortgage pass-through certificates series 2006-3

                Rating
                ------
   Class     To         From             Credit enhancement (%)
   -----     --         ----             ----------------------
   A-J       CCC+       B+                     12.48
   B         D          B                      10.32
   C         D          B-                      9.30
   D         D          CCC+                    7.64
   E         D          CCC                     6.76
   F         D          CCC-                    5.60


BANC OF AMERICA: S&P Downgrades Rating on 2004-BBA4 Certs. to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D' from
'CCC-' on the class K commercial mortgage pass-through
certificates from Banc of America Large Loan Inc.'s series 2004-
BBA4, a U.S. commercial mortgage-backed securities transaction.
Concurrently, S&P affirmed its 'BBB' rating on class J and
withdrew S&P's 'AAA' ratings on three interest-only classes from
this transaction.

The downgrade of class K follows recurring interest shortfalls and
a principal loss.  The class has experienced interest shortfalls
for eight months primarily due to special servicing fees related
to the Heritage Square I & II loan.  The loan was transferred back
to the master servicer from the special servicer in January 2010;
however, S&P expects the shortfalls to continue due to ongoing
workout fees.  Additionally, class K sustained a principal loss as
reflected on the Nov. 16, 2009, remittance report following the
sale and simultaneous note write-down on the Heritage Square I &
II asset.  The trustee, Bank of America Merrill Lynch, issued a
revised trustee remittance report on July 13, 2010, reflecting a
corrected principal loss.  Based on the revised report, class K
has incurred an aggregate loss of $624,090 (3.3% of the current
principal balance).

The affirmation of the 'BBB' rating on class J reflects S&P's
revaluation of the collateral office properties securing the two
remaining loans in the pool.  The office properties' performance
has experienced marginal change since S&P's last review.

S&P withdrew its ratings on the IO class X-2, X-3, and X-4
certificates following the repayment of all principal and interest
paying classes rated 'AA-' or higher in accordance with S&P's
criteria.  The principal repayments were noted in the June 2010
remittance report.

The larger of the two remaining loans in the pool is the Heritage
Square I & II loan, with a trust and whole-loan balance of
$16.0 million.  Two office buildings in Farmers Branch, Texas,
totaling 354,500 sq. ft. secure this loan.  The properties were
sold for $16 million in October 2009, and as part of the
transaction, the new borrower assumed the loan and executed a
modification agreement.  The modified loan is scheduled to mature
in June 2013, with one 24-month extension option remaining.  The
master servicer, Bank of America Merrill Lynch, reported a debt
service coverage of 1.53x and 65% occupancy for the first quarter
of 2010.  Based on S&P's analysis of the borrower's operating
statements for year-end 2008, year-end 2009, and the March 31,
2010, rent roll, S&P's adjusted valuation declined 32% since S&P's
last review taking into consideration the recent purchase price,
increasing market vacancies, and decreasing market rental rates.
Using a capitalization rate of 9.25%, S&P's analysis yielded a
stressed loan-to-value ratio of 123.1%.

The smallest loan in the pool, the Arapahoe Business Park loan,
has a trust balance of $11.3 million and a whole-loan balance
of $17.8 million.  At issuance, a 10-building flex
(office/industrial) complex totaling 423,400 sq. ft. in
Richardson, Texas, secured the loan.  The loan was transferred
to the special servicer, CT Investment Management Co., on Oct. 22,
2008, due to imminent default.  The special servicer subsequently
modified the loan in January 2009 to allow the borrower to market
the individual buildings for sale.  Two properties (820 N.
Glenville and 1231 American Parkway) have sold and the borrower
continues to actively market the remaining properties.  According
to the terms of the modification, the cash flow for each of the
properties is being trapped such that the loan's A note is being
paid current interest, while the payments on the loan's B note,
which is held outside the trust, are accruing.  Additionally, any
sales proceeds together with amortization and trapped excess cash
flow will be applied to pay down the A note.  At this time,
Standard & Poor's does not expect a loss upon resolution of the
loan.  The modified loan matures in October 2010; however, the
special servicer is considering the borrower's request to extend
the loan term.  The master servicer reported a DSC of 2.04x and
75% occupancy for year-end 2009.

                          Rating Lowered

                  Banc of America Large Loan Inc.
  Commercial mortgage pass-through certificates series 2004-BBA4

                                      Rating
                                      ------
                 Class              To       From
                 -----              --       ----
                 K                  D        CCC-

                         Rating Affirmed

                  Banc of America Large Loan Inc.
  Commercial mortgage pass-through certificates series 2004-BBA4

                   Class              Rating
                   -----              ------
                   J                  BBB

                        Ratings Withdrawn

                  Banc of America Large Loan Inc.
  Commercial mortgage pass-through certificates series 2004-BBA4

                                      Rating
                                      ------
                 Class              To       From
                 -----              --       ----
                 X-2                NR       AAA
                 X-3                NR       AAA
                 X-4                NR       AAA


BANC OF AMERICA: S&P Downgrades Ratings on Six 2001-PB1 Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes of commercial mortgage-backed securities from Banc of
America Commercial Mortgage Inc.'s series 2001-PB1 and removed
them from CreditWatch with negative implications.  In addition,
S&P affirmed its ratings on 12 other classes from the same
transaction.

The rating actions follow S&P's analysis of the transaction using
its U.S. conduit and fusion CMBS criteria.  The downgrades reflect
credit support erosion S&P anticipate will occur upon the
resolution of three specially serviced assets.  The rating actions
also reflect the potential for increased interest shortfalls
related to nondefeased loans maturing in 2010 and 2011 totaling
$421.5 million (60.1% of the total pool balance).  Given capital
market conditions, it may be challenging to refinance many of
these loans, prompting special servicing transfers, as well as
potential delinquencies.

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 1.40x and a loan-to-value ratio of 72.5%.  S&P
further stressed the loans' cash flows under S&P's 'AAA' scenario
to yield a weighted average DSC of 1.19x and an LTV ratio of
95.0%.  The implied defaults and loss severity under the 'AAA'
scenario were 22.5% and 27.3%, respectively.  The DSC and LTV
calculations S&P noted above exclude the three specially serviced
loans ($17.4 million; 2.5%), one loan that S&P determined to be
credit-impaired ($19.6 million; 2.8%), and 28 defeased loans
($271.4 million; 38.7%).  S&P separately estimated losses for the
three specially serviced loans and the one loan that S&P
determined to be credit-impaired, which S&P included in its 'AAA'
scenario implied default and loss severity figures.

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

                      Credit Considerations

As of the July 12, 2010, remittance report, three loans
($17.4 million; 2.5%) in the pool were with the special servicer,
C-III Asset Management LLC.  All three loans are 90-plus-days
delinquent, and two of the specially serviced loans have appraisal
reduction amounts in effect totaling $5.7 million.  S&P describe
these loans below.

The Lakeshore apartments loan ($10.4 million; 1.5%) has a total
exposure of $11.1 million, which includes $718,836 of advancing
and interest thereon.  The loan is secured by a 402-unit garden
apartment complex in Reading, Ohio, that was built in 1965 and
renovated in 1990.  This loan was transferred to specially
servicing on Dec. 21, 2009, due to an imminent payment default.
The reported DSC and occupancy as of year-end 2009 were 0.73x and
87%, respectively.  An ARA is in effect against the loan for
$4.5 million.  S&P expects a significant loss upon the resolution
of this loan.

Both of the remaining specially serviced loans ($7.0 million,
1.0%) have balances that individually represent less than 0.7% of
the total pool balance.  S&P estimated a weighted average loss of
28.6% for these two loans.

In addition to the specially serviced loans, S&P determined the
Nokia Office Building loan ($19.6 million; 2.8%), the third-
largest loan in the pool secured by real estate, to be credit-
impaired.  The loan is secured by a 135,000-sq.-ft. research and
development building in San Diego, Calif., that was built in 2000.
The property is 100% leased to Nokia Mobil Phones Inc. pursuant to
a lease maturing on Aug., 31, 2010.  The master servicer reports
that the tenant will not be renewing its lease, and the space
currently has no leasing prospects.

Excluding defeased loans, 78 loans ($421.5 million, 60.1%) mature
in 2010 and 2011.  This includes one loan ($5.9 million; 0.8%)
that was specially serviced and subsequently returned to the
master servicer.  The special servicer is entitled to 1% of all
future principal and interest payments on the loan provided it
continues to perform through maturity and remains with the master
servicer.

                       Transaction Summary

As of the July 12, 2010, remittance report, the transaction had an
aggregate trust balance of $701.1 million (111 loans), compared
with $938.3 million (134 loans) at issuance.  Prudential Asset
Resources, the master servicer, provided financial information for
all of the loans in the pool.  Approximately 95% of this financial
information was full-year 2009 data and 4.6% was partial-year 2010
data.  S&P calculated a weighted average DSC of 1.35x for the
loans in the pool based on the reported figures.  S&P's adjusted
DSC and LTV were 1.40x and 72.5%, respectively, and exclude three
specially serviced loans ($17.4 million; 2.5%), one loan that S&P
determined to be credit-impaired ($19.6 million; 2.8%), and 28
defeased loans ($271.4 million; 38.7%).  The weighted average DSC
was 0.72x for the two specially serviced loans with reported DSCs.
The trust has experienced $6.4 million of principal losses to
date.  Twenty-four loans are on the master servicer's watchlist
($125.8 million; 17.9%).  Three loans ($27.2 million, 3.9%) have a
reported DSC between 1.0x and 1.1x, and 16 loans ($64.8 million,
9.2%) have a reported DSC of less than 1.0x.  S&P separately
estimated losses for the three specially serviced loans and the
one loan that S&P determined to be credit-impaired.

              Summary of Top 10 Real Estate Exposures

The top 10 loans secured by real estate have an aggregate
outstanding balance of $178.7 million (25.5%).  Using servicer-
reported information, S&P calculated a weighted average DSC of
1.39x.  S&P's adjusted DSC and LTV figures for the top 10 loans
were 1.41x and 67.4%, respectively.  These figures exclude the
third-largest loan in the pool secured by real estate, the Nokia
Office Building loan ($19.6 million; 2.8%), which S&P determined
to be credit-impaired and is discussed above.  Two other top 10
loans are on the master servicer's watchlist.

The Village Plaza loan ($14.8 million; 2.1%), the sixth-largest
loan in the pool secured by real estate, is secured by a 272,480-
sq.-ft. office building in Dearborn, Mich., that was built in 1968
and renovated in 1999.  The loan appears on the master servicer's
watchlist due to a low DSC.  For year-end 2009, the reported DSC
was 1.10x.  However, S&P estimates a current DSC of 1.52x due to
an improved occupancy of 90.1% pursuant to a rent roll dated March
2010, compared with 85.1% occupancy at year-end 2008.

The 25, 40 & 45 Hartwell Avenue loan ($14.4 million; 2.1%), the
seventh-largest loan in the pool secured by real estate, is
secured by three adjacent office buildings totaling 114,317 sq.
ft. in Lexington, Mass., that were built between 1961 and 1969 and
renovated between 1996 and 2000.  The loan appears on the master
servicer's watchlist due to a low DSC and upcoming lease roll.
The lease to 1366 Technologies (16,058 sq. ft.; 14.0% of net
rentable area) expires in July 2011.  For year-end 2009, the
reported occupancy and DSC were 100% and 1.31x, respectively.
Based on the March 2010 rent roll, S&P estimate a current DSC of
1.03x.

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 2001-PB1

                  Rating
                  ------
      Class     To     From          Credit enhancement (%)
      -----     --     ----          ----------------------
      K         BBB+   A-/Watch Neg              7.45
      L         BBB-   BBB/Watch Neg             5.44
      M         BB-    BB+/Watch Neg             4.44
      N         B      BB-/Watch Neg             2.77
      O         CCC    B/Watch Neg               2.10
      P         CCC-   B-/Watch Neg              1.43

                        Ratings Affirmed

             Banc of America Commercial Mortgage Inc.
   Commercial mortgage pass-through certificates series 2001-PB1

            Class     Rating   Credit enhancement (%)
            -----     ------   ----------------------
            A-2       AAA                       28.53
            A-2F      AAA                       28.53
            B         AAA                       23.17
            C         AAA                       21.84
            D         AAA                       20.16
            E         AAA                       17.49
            F         AAA                       15.81
            G         AA+                       13.81
            H         AA                        11.80
            J         AA-                       10.13
            XC        AAA                         N/A
            XP        AAA                         N/A

                       N/A - Not applicable.


BEA CBO: Fitch Downgrades Ratings on Various 1998-2 Notes
---------------------------------------------------------
Fitch Ratings downgrades the notes from BEA CBO 1998-2 Ltd./Corp.

The downgrade of the class A-3 notes is based upon the failure to
pay the periodic interest amount, which is considered an event of
default according to the transaction documents.  The class A-3
notes have an aggregate principal balance of $20 million and an
interest shortfall balance of $6.6 million, compared to a
performing collateral balance of just $3.5 million.  There are
three defaulted bonds in the portfolio for which Fitch expects
limited to no recovery.

Recovery Ratings are based on the total future cash flows
projected to be available to the notes.  Recovery Ratings are
designed to provide a forward-looking estimate of recoveries on
currently distressed or defaulted structured finance securities
rated 'CCC' or below.  Fitch expects approximately $3.4 million
from the remaining debt securities, which is equivalent to 12.5%
and representative of an 'RR5'.

BEA 1998-2 is a collateralized bond obligation managed by Credit
Suisse Asset Management that closed on Dec. 3, 1998.  The final
maturity of the transaction is Dec. 15, 2010.

Fitch downgrades the rating on this class:

  -- $20,000,000 class A-3 notes to 'D/RR5' from 'C/RR5'.


BEAR STEARNS: Fitch Downgrades Ratings on 1999-WF2 Certificates
---------------------------------------------------------------
Fitch Ratings downgrades and assigns Loss Severity Ratings,
Recovery Ratings and Rating Outlooks to these Bear Stearns
Commercial Mortgage Securities Trust, series 1999-WF2 commercial
mortgage pass-through certificates:

  -- $9.5 million class J to 'B-/LS3' from 'B+', Outlook Negative;
  -- $10.8 million class K to 'C/RR2' from 'B-', Outlook Negative.

Fitch also upgrades and assigns LS Ratings and Outlooks to this
class:

  -- $10.8 million class F to 'AAA/LS3' from 'AA+', Outlook
     Stable.

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

  -- $18.6 million class C at 'AAA/LS3', Outlook Stable;
  -- $10.8 million class D at 'AAA/LS3', Outlook Stable;
  -- $27.0 million class E at 'AAA/LS3', Outlook Stable;
  -- $21.6 million class G at 'A/LS3', Outlook Stable;
  -- $16.2 million class H at 'BBB/LS3', Outlook Stable;
  -- $8.1 million class I at 'BB/LS3', Outlook Stable.

Fitch revises the recovery rating on class L to 'D/RR6'.  Classes
A1, A2 and B, 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 5.31%
of the remaining pool balance, approximately $7.2 million, from
loans in special servicing and loans that are not expected to
refinance at maturity based on Fitch's refinance test.  Rating
Outlooks reflect the likely direction of any rating changes over
the next one or two years.

As of the July 2010 distribution date, the pool has paid down
87.5% to $134.7 million from $1.1 billion at issuance.  Of the
original 294 loans, 74 remain in the transaction.  Fitch has
identified 10 Loans of Concern (19.1%), including eight loans in
special servicing (18.4%), as well as other loans with
deteriorating performance.

The largest specially serviced loan (3.35%) is collateralized by a
single-tenant retail property in Salt Lake City, UT.  The loan was
transferred to the Special Servicer in August 2009 due to maturity
default.  The borrower has been unable to refinance the loan due
to the near term lease expiration of the single tenant.  The
special servicer is evaluating the borrower's request for a loan
modification while the borrower is working to reconfigure space to
meet the tenant's needs.

Fitch stressed the cash flow of the remaining non-defeased loans
by applying a 5% reduction to 2009 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, all performing loans passed the
refinance test.


CALLIDUS DEBT: Moody's Upgrades Ratings on Three Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
rating of these notes issued by Callidus Debt Partners CDO Fund I,
Ltd.:

  -- US$264,000,000 Class A-2 Floating Rate Senior Secured Term
     Notes due December 20, 2013, Upgraded to Aa3; previously on
     May 18, 2009 Downgraded to Baa2;

  -- US$50,600,000 Class A-3 Floating Rate Senior Secured
     Revolving Notes due December 20, 2013, Upgraded to Aa3;
     previously on May 18, 2009 Downgraded to Baa2;

  -- US$24,700,000 Class B-2 Floating Rate Second Priority Senior
     Secured Notes due December 2013, Upgraded to Caa2; previously
     on May 18, 2009 Downgraded to Caa3.

According to Moody's, the rating actions taken on the notes result
primarily from improvement in the credit quality of the underlying
portfolio, substantial delevering of the transaction and the
improvement in the Class A overcollateralization ratio since the
rating action in May 2009.

Since the last rating action, the Class A-2 and the Class A-3
Notes were paid down by about $65 million, accounting for roughly
44% of the total Class A-2 and A-3 Notes' outstanding balance
reported in May 2009.  This paydown is attributable to principal
amortizations including scheduled payments.  As a result of the
delevering, the Class A overcollateralization ratio has improved
from 119.92% in May 2009 to 131.6% in June 2010.  Moody's expects
delevering to continue as a result of the end of the deal's
reinvestment period in Match 2007.

The Class A-2 and the A-3 Notes are wrapped by Ambac Assurance
Corporation.  The rating on the Class A-2 and the Class A-3 Notes
reflects the actual underlying rating of the notes.  This
underlying rating is based solely on the intrinsic credit quality
of the Class A-2 and the Class A-3 Notes in the absence of the
guarantee from Ambac.  The above action is a result of, and is
consistent with, Moody's modified approach to rating structured
finance securities wrapped by financial guarantors as described in
the press release dated November 10, 2008, titled "Moody's
modifies approach to rating structured finance securities wrapped
by financial guarantors."

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.

Callidus Debt Partners CDO Fund I, Ltd., issued in December 2001,
is a collateralized bond obligation backed primarily by a
portfolio of senior unsecured bonds and senior secured loans.


CAPITAL AUTO: Fitch Affirms Ratings on Various Classes of Notes
---------------------------------------------------------------
Fitch Ratings affirms the Capital Auto Receivables Asset Trust
2007-4 transaction:

  -- Class A-3a notes at 'AAA'; Outlook Stable;

  -- Class A-3b notes at 'AAA'; Outlook Stable;

  -- Class A-4 notes at 'AAA'; Outlook Stable;

  -- Class B notes at 'A'; Outlook Stable;

  -- Class C notes at 'BBB'; Outlook revised to Stable from
     Negative;

  -- Class D notes at 'BB'; Outlook revised to Stable from
     Negative.

The rating affirmations reflect improvements in performance and
increases in credit enhancement available to the notes since
Fitch's last review.  Though the transaction has experienced a
higher loss pace than prior transactions, some stabilization in
performance has been experienced as the loss pace has slowed in
recent months.  As of the June 2010 collection period, the
transaction has total delinquencies of 5.57% and net losses of
2.94%.

Despite the higher losses and delinquencies, the cash flows
available to service the outstanding debt in the transaction
currently continue to allow credit enhancement to build on a
nominal basis.  Fitch analyzed the transaction incorporating
various stressed CNL assumptions.  Based on the analysis, Fitch
concluded that CE is currently adequate to support the existing
ratings under Fitch's stressed assumptions and therefore affirms
all classes of outstanding notes.  In addition, as a result of the
positive performance trends and increasing CE, the Outlooks on the
class C and D notes are being revised to Stable from Negative.


CARLYLE HIGH: Moody's Upgrades Ratings on Two Classes of Notes
--------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Carlyle High Yield Partners VIII,
Ltd.:

* US$28,750,000 Class C Senior Secured Deferrable Floating Rate
  Notes due 2021, Upgraded to Ba1; previously on August 10, 2009
  Downgraded to Ba2;

* US$34,250,000 Class D Secured Deferrable Floating Rate Notes due
  2021 (current balance of $28,492,924), Upgraded to B2;
  previously on August 10, 2009 Downgraded to B3.

In addition, Moody's withdrew the rating of these notes:

* US$13,000,000 Type I Composite Notes due 2021, Withdrawn;
  previously on August 10, 2009 Downgraded to Ba1.

According to Moody's, the rating actions taken on the Class C and
Class D notes result primarily from improvement in the credit
quality of the underlying portfolio and increase of the
overcollateralization ratios of the notes since the previous
rating action in August 2009, which coincides with the
reinvestment of principal repayments and sale proceeds into
substitute assets with higher par and/or higher ratings.

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 proportion
of securities from issuers rated Caa1 and below.  In particular,
based on the latest trustee report dated July 19, 2010, the
weighted average rating factor is 2592 compared to 2836 in July
2009, and securities rated CCC+/Caa1 or lower make up
approximately 4.73% of the underlying portfolio versus 9.81% in
July 2009.  Additionally, defaulted securities have been reduced
to about $7.9 million from $20.6 million in July 2009.  Moody's
also notes that the transaction's overcollateralization levels
have increased since the last rating action and all
overcollateralization tests are currently in compliance.
Specifically, the Class A/B, Class C, and Class D
overcollateralization ratios are reported at 120.72%, 112.84%, and
105.99% in July 2010 versus July 2009 levels of 117.58%, 109.91%,
and 102.56%, respectively.  The Class D overcollateralization
ratio has increased partly due to the diversion of excess interest
to delever the Class D notes as a result of Class D
overcollateralization test failures.  The outstanding balance of
the Class D notes has been reduced by about $3.1 million since
July 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.

The Type I Composite Notes were exchanged for their underlying
components at the noteholder's request.  As a result, the rating
of the notes has been withdrawn.

Carlyle High Yield Partners VIII, Ltd., issued in May 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.


CENTERPOINT ENERGY: Moody's Upgrades Ratings on Debt Obligations
----------------------------------------------------------------
Moody's Investors Service upgraded the ratings of CenterPoint
Energy Houston Electric, LLC's debt and supported obligations and
assigned a stable outlook on the company.  CEHE's senior unsecured
and issuer ratings are upgraded to Baa2 from Baa3 and its senior
secured ratings to A3 from Baa1.  The upgraded debt includes
certain pollution control bonds at CEHE's parent company,
CenterPoint Energy, Inc. (Ba1 senior unsecured/positive outlook),
that are collateralized by CEHE's first and general mortgage
bonds.  These rating actions end a review for possible upgrade
that was initiated on May 3, 2010.  On these rating actions,
Moody's cited CEHE's steady financial performance, a regulatory
environment that has been supportive of its credit profile, and an
improving financial position at its parent company.

"CenterPoint Energy Houston's low business risk profile has
enabled it to show consistent financial results through the
challenges of a major storm, a weak economy and capital market
conditions," said Moody's Vice President Mihoko Manabe.

Moody's noted CEHE is in the midst of a rate case that poses some
uncertainty as to its ultimate financial impact; however, the
rating actions are based on the expectation that the final rate
order will be at least credit-neutral to CEHE.  In Moody's
assessment, the political and regulatory environment in Texas is
generally supportive of the long-term credit quality of utilities
in the state.  The Public Utility Commission of Texas has allowed
for trackers that allow for timely recovery of certain investments
and is considering other similar mechanisms.  After some years of
instability, the competitive framework for the state's retail
electric market is now well established, and the related legacy
issues to CEHE have resolved or have become more manageable as the
company gained financial strength.  Moody's believes that CEHE has
a low business risk as a transmission and distribution utility,
without the risks related to electric generation or being a
provider of last resort.  The state legislature has passed
statutes that have enabled utilities, including CEHE, to issue
securitization bonds to recover stranded costs related to the
transition to retail competition as well as storm restoration
costs.  The latter is an important benefit given CEHE's location
on the Gulf Coast and its vulnerability to hurricanes.

Moody's said that CEHE still had considerable financial leverage
(debt-to-book capitalization 67% at March 31, 2010, after Moody's
standard adjustments), but that its highly stable cash flow has
enabled the company to support somewhat higher financial leverage
at this rating than a typical vertically integrated electric
utility or a T&D utility with POLR obligations.  Moody's debt
calculation includes $2.9 billion of non-recourse securitization
bonds that are serviced by separate customer charges.
Securitization bonds comprise over half of CEHE's debt, a much
higher proportion than most other peers that have securitization
debt, thus having a much greater effect on CEHE's credit metrics.
Without the securitization bonds, CEHE's debt-to-capital ratio
would fall to 48%, which is a more typical range for U.S.
investor-owned utilities at CEHE's rating level.

In the last twelve months ended March 31, 2010, CEHE's cash flow
from operations before working capital changes (CFO pre-w/c) plus
interest-to-interest was 3.4 times.  CFO pre-w/c-to-debt was 12%.
Moody's said that these calculations do not reflect the
$236 million of external investments on CEHE's balance sheet plus
$603 million of CEHE's funds invested in CNP's corporate money
pool at March 31.  Moody's said these resources made CEHE's
liquidity strong, that the company retained the ability to
generate free cash flow even with higher than historical capital
expenditures, and that it would not need to access the debt
markets in the foreseeable near future.

Moody's also considered CNP's positive rating momentum in CEHE's
upgrade.  In June, CNP issued $326 million of common stock in a
public offering, an action that will further the de-leveraging
that is occurring at CenterPoint and ease the implicit burden of
the parent debt on CEHE.

These CEHE debt obligations have been upgraded:

Upgrades:

Issuer: Brazos River Authority, TX

  -- Senior Secured Revenue Bonds, Upgraded to A3 from Baa1

Issuer: CenterPoint Energy Houston Electric, LLC

  -- Issuer Rating, Upgraded to Baa2 from Baa3

  -- Senior Secured Regular Bond/Debenture, Upgraded to A3 from
     Baa1

  -- Senior Unsecured Bank Credit Facility, Upgraded to Baa2 from
     Baa3

Issuer: Gulf Coast Waste Disposal Authority, TX

  -- Senior Secured Revenue Bonds, Upgraded to A3 from Baa1

Issuer: Matagorda County Navigation District 1, TX

  -- Senior Secured Revenue Bonds, Upgraded to A3 from Baa1

Issuer: Reliant Energy HL&P

  -- Senior Secured First Mortgage Bonds, Upgraded to A3 from Baa1

Outlook Actions:

Issuer: CenterPoint Energy Houston Electric, LLC

  -- Outlook, Changed to Stable From Rating Under Review

Issuer: Reliant Energy HL&P

  -- Outlook, Changed to No Outlook From Rating Under Review

Moody's last rating action for CEHE occurred on May 3, 2010, when
Moody's initiated a review for possible upgrade.

CenterPoint Energy Houston Electric, LLC, is an electric
transmission and distribution utility.  It is a subsidiary of
CenterPoint Energy, Inc., an energy company headquartered in
Houston, Texas.


COCONINO COUNTY: Fitch Expects to Assign Ratings on 1998 Bonds
--------------------------------------------------------------
On the effective date of Aug. 10, 2010, Fitch Ratings will assign
a rating of 'AA-/F1+' to the $16,870,000 Coconino County, Arizona
Pollution Control Corporation pollution control revenue bonds
(Arizona Public Service Company Project) series 1998.  The rating
will be based on the support provided by an irrevocable direct-pay
substitute letter of credit to be issued by JPMorgan Chase Bank,
N.A. (rated 'AA-/F1+', with a Stable Outlook by Fitch).  The bonds
are currently outstanding and supported by an LOC issued by KBC
Bank N.V.  Fitch will be assigning credit enhanced ratings to the
bonds for the first time in connection with the provision of the
substitute LOC provided by JPMorgan.  The bonds also have a Fitch
underlying rating of 'BB+', with a Positive Outlook.

The bank is obligated to make payments of principal of and
interest on the bonds upon maturity, acceleration and redemption,
as well as purchase price for tendered bonds.  The ratings will
expire upon the earliest of: (a) Aug. 10, 2013, the initial
stated expiration date of the LOC, unless such date is extended;
(b) conversion to a mode not covered by the LOC; (c) any prior
termination of the LOC; and (d) defeasance of the bonds.  The LOC
provides full and sufficient coverage of principal plus an amount
equal to 34 days of interest at a maximum rate of 12% based on a
year of 365 days and purchase price for tendered bonds, while in
the daily, weekly and monthly rate mode.  The bonds will be
subject to a mandatory tender on or about Aug. 10, at which time
they will be remarketed with the support of the JPMorgan LOC.  At
such time, the Remarketing Agent for the bonds will be J.P. Morgan
Securities Inc.

The bonds bear interest at a daily rate, but may be converted to a
weekly, monthly, term, flexible segment, or rate period mode.
While bonds bear interest in the daily rate mode, interest
payments are on the first business day of each month.  The
trustee/paying agent is obligated to make timely draws on the LOC
to pay principal, interest, and purchase price.  Funds drawn under
the LOC are held uninvested and are free from any lien prior to
that of the bondholders.

Holders may tender their bonds on any business day, provided the
trustee/paying agent is given the requisite prior notice of the
purchase.  The bonds are subject to mandatory tender upon: (1) the
change in upon conversion of the interest rate to a mode other
than daily, weekly or monthly; (2) expiration or termination of
the LOC; (3) substitution of the LOC, unless the trustee/paying
agent receives written notice that the substitution will not
result in a reduction or withdrawal of the then current ratings;
(4) the trustee/paying agent's receipt of notice of an event of
default under the reimbursement agreement and non-reinstatement of
the LOC interest, although the JPMorgan LOC provides for automatic
reinstatement of the interest following a drawing for interest on
a regularly scheduled interest date.  Optional and mandatory
redemption provisions also apply to the bonds.  There are no
provisions for the issuance of additional bonds.


COMMERCIAL MORTGAGE: S&P Downgrades Ratings on 1999-C2 Certs.
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on two
classes of commercial mortgage-backed securities from Commercial
Mortgage Asset Trust's series 1999-C2 and removed them from
CreditWatch with negative implications.  In addition, S&P affirmed
its ratings on five other classes from the same transaction.

The lowered ratings primarily reflect credit support erosion S&P
anticipates will occur upon the eventual resolution of three of
the four assets ($41.7 million, 14.3%) with the special servicer.
The downgrades also reflect the potential for increased interest
shortfalls to the trust.  If this occurs, the downgraded classes
will be more susceptible to interest shortfalls in the future.

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

                      Credit Considerations

As of the July 2010 remittance report, four ($41.7 million, 14.3%)
assets in the pool were with the special servicer, LNR Partners
Inc.  The payment status of the specially serviced assets is: two
($6.3 million, 2.29%) are classified as real estate owned, one
($29.7 million, 10.2%) is 90-plus-days delinquent, and one
($5.7 million, 1.9%) is current.  Appraisal reduction amounts
totaling $14.4 million are in effect against three delinquent
assets.  Three of the four loans with the special servicer are top
10 assets.  Details are:

The Henry W. Oliver loan ($29.7 million, 10.2%) is the third-
largest exposure in the pool and the largest asset with the
special servicer.  The total exposure is $30.7 million, which
includes $1.0 million of advancing and interest thereon.  The loan
is secured by a 471,786-sq.-ft. office property in Pittsburgh,
Pa., built in 1909.  The loan was transferred to the special
servicer in October 2009 due to payment default and is now 90-
plus-days delinquent.  According to the special servicer, the
largest tenant vacated in June 2010 and the property is currently
31% occupied.  As of year-end 2009, the reported DSC and occupancy
were 1.17x and 88%, respectively.  S&P expects a significant loss
upon the eventual resolution of this asset.

The Lakeside Office Park loan ($5.7 million, 1.9%) is the seventh-
largest exposure in the pool and the second-largest asset with the
special servicer.  The loan is secured by a 196,905-sq.-ft. office
property in Wakefield, Mass., built in 1970.  The loan was
transferred to the special servicer in June 2009 due to imminent
maturity default.  According to the special servicer, the loan was
not repaid prior to its anticipated repayment date of Feb. 11,
2009, but the loan payment status is current.  As of year-end
2008, the reported DSC and occupancy were 2.12x and 87%,
respectively.

The Circuit City - Ridgeland asset ($3.9 million, 1.4%) is the
ninth-largest exposure in the pool and the third-largest asset
with the special servicer.  The total exposure of $5.7 million
includes approximately $897,045 of advancing and interest thereon.
The asset is a 32,784-sq.-ft. retail property in Ridgeland, Ms.,
built in 1998.  The asset was transferred to the special servicer
in November 2008 due to payment default and is currently REO.  The
property, formerly occupied entirely by Circuit City, is currently
100% vacant.  S&P expects a severe loss upon the eventual
resolution of this asset.

The Circuit City - Wichita Falls asset ($2.4 million, 0.8%) is the
fourth-largest asset with the special servicer.  The total
exposure of $2.9 million includes approximately $555,591 of
advancing and interest thereon.  The asset is a 21,196-sq.-ft.
retail property in Wichita Falls, Texas, built in 1998.  The asset
was transferred to the special servicer in November 2008 due to
payment default and is currently REO.  The property, formerly
occupied entirely by Circuit City, is currently 100% vacant.  S&P
expects a severe loss upon the eventual resolution of this asset.

                       Transaction Summary

As of the July 2010 remittance report, the collateral pool had
an aggregate trust balance of $292.3 million, down from
$775.2 million at issuance.  The pool includes 24 assets, down
from 80 at issuance.  The master servicer for the transaction is
BNY Mellon.  The master servicer provided financial information
for 96.0% of the assets in the pool, which excludes nine
($135.7 million, 46.4%) defeased loans.  Ninety-two percent of
the reported information was based on full-year 2009 or interim
2010 financial information.  S&P calculated a weighted average
DSC of 1.30x for the pool based on the reported figures.

The master servicer reported two ($44.7 million, 15.3%) loans
on the watchlist, both of which are top 10 loans.  One
($36.4 million, 12.5%) asset in the pool has a reported DSC of
less than 1.0x.  To date, the pool has experienced principal
losses totaling $34.9 million, on 11 assets.

             Summary of Top 10 Real Estate Exposures

The top 10 real estate exposures in the pool have an aggregate
outstanding trust balance of $150.8 million (51.6%).  Using
servicer-reported numbers, S&P calculated a weighted average DSC
of 1.28x for the top 10 exposures.  Three ($39.3 million, 13.5%)
of the top 10 exposures are currently with the special servicer.
Two other top 10 assets appear on the master servicer's watchlist.

The ACCOR Corp. - Pool III - Note B Portfolio loan ($36.4 million,
12.5%) is the largest exposure in the pool.  The loan exposure
consists of 14 limited service Motel 6 hotel properties in six
states, totaling 1,642 rooms, built between 1968 and 1989.  As of
December 2009, reported DSC and occupancy were 0.76x and 56.7%,
respectively.  The DSC figure compares with a December 2008 DSC of
1.23x.  The asset appears on the master servicer's watchlist due
to a decrease in DSC and occupancy.

The Allied Portfolio loan ($8.3 million, 2.8%) is the sixth-
largest exposure in the pool.  The loan exposure consists of four
retail properties in Ohio built between 1975 and 1979 totaling
485,754 sq. ft. For the 12 months ended March 31, 2010, the
reported DSC and occupancy were 1.13x and 76.0%, respectively.
The DSC and occupancy figures compare with December 2008 figures
of 1.20x and 84.0%, respectively.  The asset appears on the master
servicer's watchlist due to a decrease in DSC and occupancy.

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

      Ratings Lowered And Removed From Creditwatch Negative

                 Commercial Mortgage Asset Trust
   Commercial mortgage pass-through certificates series 1999-C2

                  Rating
                  ------
     Class      To      From           Credit enhancement (%)
     -----      --      ----           ----------------------
     E          A       AA+/Watch Neg                   23.22
     F          BB+     AA-/Watch Neg                   17.91

                         Ratings Affirmed

                 Commercial Mortgage Asset Trust
   Commercial mortgage pass-through certificates series 1999-C2

     Class        Rating               Credit enhancement (%)
     -----        ------               ----------------------
     A-3          AAA                                   63.67
     B            AAA                                   50.40
     C            AAA                                   37.14
     D            AAA                                   33.16
     X            AAA                                     N/A

                       N/A - Not applicable.


CREDIT SUISSE: Fitch Downgrades Rating on 1997-C2 Certificates
--------------------------------------------------------------
Fitch Ratings downgrades and assigns a Recovery Rating to Credit
Suisse First Boston Mortgage Securities Corp. commercial mortgage
pass-through certificates, series 1997-C2, as indicated:

  -- $14.7 million class I to 'CC/RR3' from 'CCC/RR2'.

In addition, Fitch affirms the long term credit ratings and Rating
Outlooks, and assigns Loss Severity ratings as indicated:

  -- $10.2 million class D at 'AAA'; Outlook Stable;
  -- $73.3 million class F at 'AA+/LS1'; Outlook Stable;
  -- $14.7 million class G at 'A+/LS2'; Outlook Stable;
  -- $29.3 million class H at 'B+/LS2'; Outlook Negative.

Classes A-1, A-2 and A-3, B and C have paid in full.  Fitch does
not rate the $25.7 million class E or the $1.4 million class J.

In addition, Fitch withdraws the rating of the interest only (IO)
class A-X.

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 commercial mortgage
backed security analysis.  Fitch expects potential losses of 1.73%
of the remaining pool balance, approximately $2.9 million, from
the loans that are not expected to refinance at maturity based on
Fitch's refinance test.  The 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 pool's aggregate
certificate balance has decreased 88.5% to $169.1 million, from
$1.5 billion at issuance.  Four loans (15.2%) have defeased,
including the top remaining loan (12.4%) in the transaction.

Fitch has identified six Loans of Concern (22.1%), including one
loan (3%) that is in special servicing for non-monetary default.
The two largest Loans of Concern, representing 5.5% and 5.2% of
the pool, respectively, remain current.  The largest Fitch Loan of
Concern is secured by a 224,888 sf, single-tenant industrial
property in Belmont, CA, which did not pay off at its anticipated
repayment date of Dec. 11, 2007.  The loan was previously in
special servicing, but was returned to the master servicer in
November 2008.

The second largest Fitch Loan of Concern is secured by a 131,580
square foot office property in Bannockburn, IL, which is part of
the North Suburbs submarket of Chicago.  As of July 2010,
occupancy has declined to 52%, according to the borrower.  The
borrower is actively marketing the vacant space.

The largest non-defeased loan (10.9%) is secured by a 176,682 sf
office property located in Bedminster Township, NJ.  Occupancy was
100% as of March 31, 2010.  A single tenant has leased the entire
space through 2021.

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 ratio of 1.25 times or higher were considered to pay off
at maturity.  Under this scenario, four loans are not expected to
pay off at maturity with three loans incurring a loss when
compared to Fitch's stressed value.


CREDIT SUISSE: Fitch Downgrades Ratings on Two 2004-TFL2 Certs.
---------------------------------------------------------------
Fitch Ratings has downgraded two classes of Credit Suisse First
Boston Commercial Mortgage Securities Corp. commercial mortgage
pass-through certificates, series 2004-TFL2.  While Fitch does not
expect losses to the remaining loan in the base case, the
downgrades are the result of Fitch's prospective views regarding
commercial real estate values and cash flow decline in addition to
the upcoming loss of one of the collateral anchors.  The Negative
Rating Outlooks reflect additional sensitivity analysis related to
further negative credit migration of the underlying collateral.  A
detailed list of rating actions follows at the end of this
release.

The remaining loan in the transaction is the $67.6 million
Seminole Towne 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 less the income from the Belk
lease, as the store has announced its closing.  Fitch analyzed
servicer reported operating statements, rent rolls, sales reports,
in addition to other information received from the master
servicer.

The loan is collateralized by 625,311 sf of a 1.1 million sf
regional mall located in Sanford, FL, in Orlando's northern retail
corridor.  Anchor tenants that are part of the collateral are
Macy's (lease expiration 2016) and Belk (lease expiration 2015).
Non collateral anchors are Dillards, Sears and JC Penney.

The loan returned from special servicing after transferring to
special servicing July 2009 when the borrower indicated the loan
would not pay off by the maturity date of July 10, 2009.  The loan
was modified to include an increase in loan spread from 0.65% to
3%, loan amortization of $2.6 million per year and a loan
extension to August 2010.  An additional extension to August 2011
was allowed for providing a minimum debt yield of 12% and the
purchase of a rate cap of 5%.  In addition, the borrower paid all
modification costs and special servicing fees.  If the loan pays
off at the new final extension date, there will be no fees to the
trust.

Per the May 2010 rent roll, the in-line and total mall occupancies
were 71.3% and 92.1%, respectively, compared to 84.2% and 91.6%,
respectively, at issuance.  There is limited near-term rollover.
As a percent of the total mall space, the rollover is: less than
1% in 2010; 3.1% in 2011; 6.4% (including major tenant United
Artists Theatre) in 2012; 1% in 2013; 2% in 2014; and 16.3% in
2016 (including collateral anchor Macy's).

Although in-line sales have declined approximately 30% since 2007,
they are relatively stable since issuance.  As of March 2010, in-
line sales were $269 compared to $264 at issuance.  Anchor tenant
Belk has stated that they will vacate the mall in October 2010,
but according to the servicer, it will continue to honor the lease
obligation until the lease expiration in 2015.

Fitch downgrades, removes from Rating Watch Negative and assigns
Rating Outlooks to these certificates:

  -- $16.5 million class J to 'AA' from 'AAA'; Outlook Negative;
  -- $15.5 million class K to 'A' from 'AA+'; Outlook Negative;
  -- $8.3 million class L to 'BB' from 'A-'; Outlook Negative.

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

  -- $17.5 million class H at 'AAA'; Outlook Stable.

Fitch affirms this certificate:

  -- $9.8 million class G at 'AAA'; Outlook Stable.

Fitch withdraws the ratings of the interest-only class A-X.

Classes A-1 through F and class A-Y 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 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.


CREDIT SUISSE: Moody's Affirms Ratings on 10 2001-CKN5 Certs.
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings of ten classes and
downgraded five classes of Credit Suisse First Boston Mortgage
Securities Corp., Commercial Mortgage Pass-Through Certificates,
Series 2001-CKN5.  The downgrades are due to higher expected
losses for the pool resulting from anticipated losses from
specially serviced and poorly performing watchlisted loans and
refinancing risk associated with loans approaching maturity in an
adverse environment.  One hundred seven loans, excluding defeased
loans, mature within the next 24 months.  These loans represent
65% of the pool balance.

The affirmations are due to increased subordination resulting from
loan payoffs and amortization and key rating parameters, including
Moody's loan to value ratio, Moody's stressed DSCR and the
Herfindahl Index, remaining within acceptable ranges.  The pool
has paid down 19% since Moody's last review.

As of the July 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 33% to
$713.7 million from $1.07 billion at securitization.  The
Certificates are collateralized by 161 mortgage loans ranging in
size from less than 1% to 9% of the pool, with the top ten non-
defeased loans representing 40% of the pool.  The pool includes
one loan, representing 9% of the pool, with an investment grade
underlying rating.  Forty loans, representing 30% of the pool,
have defeased and are collateralized with U.S. Government
securities.  The pool also includes 49 loans, representing 6% of
the pool, that are secured by residential co-ops.

Thirty-one loans, representing 28% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of CRE
Finance Council (formally Commercial Mortgage Securities
Association) monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Ten loans have been liquidated from the pool, resulting in an
aggregate $13.5 million realized loss (17% loss severity on
average).  Five loans, representing 13% of the pool, are currently
in special servicing.  The largest specially serviced loan is the
Macomb Mall Loan ($42.7 million -- 6% of the pool), which is
secured by a 509,000 square foot regional mall located in
Roseville, Michigan.  The loan was transferred to special
servicing in September 2009 due to payment default but is current.
The property's net operating income has declined 24% since
securitization.  Currently the property is 64% leased.  The
borrower has submitted restructuring proposals to the special
servicer.  The property was appraised in October 2009 for
$23.5 million.  The remaining four specially serviced loans are
real estate owned (REO) or in the process of foreclosure.  Moody's
estimates an aggregate $37.2 million loss for all specially
serviced loans (40% expected loss severity on average).

In addition to recognizing losses from specially serviced loans,
Moody's has assumed a high default probability on seven poorly
performing loans, representing 3% of the pool, due to poor
performance and refinancing risk.  Moody's estimates a
$4.7 million aggregate loss for these troubled loans (20% expected
loss severity on average based on 50% probability of default).
Moody's rating action recognizes potential uncertainty around the
timing and magnitude of loss from these troubled loans.

Moody's was provided with full-year 2009 and partial year 2010
operating results for 94% and 54% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV ratio is 82% compared to 90% at Moody's previous
review.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCR are 1.32X and 1.40X, respectively, compared to
1.25X and 1.26X at last review.  Moody's actual DSCR is based on
Moody's net cash flow and the loan's actual debt service.  Moody's
stressed DSCR is based on Moody's NCF and a 9.25% stressed rate
applied to the loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple-notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 22 compared to 24 at last review.

The loan with an underlying rating is the Ocean Towers Loan
($67.6 million -- 9.5% of the pool), which is secured by a 317-
unit luxury residential cooperative located in Santa Monica,
California.  Occupancy as of December 2009 was 100%, the same as
at securitization.  Moody's current underlying rating is Aa2, the
same as at last review and securitization.

The top three performing conduit loans represent 9% of the pool.
The largest conduit loan is the Bayshore Mall Loan ($30.3 million
-- 4.2% of the pool), which is secured by a 430,000 square foot
retail center located in Eureka, California.  The center is
anchored by Sears and Kohl's (not part of collateral).  The
property was 87% leased as of March 2010 compared to 90% at last
review.  Performance has declined due to lower revenues and higher
expenses.  The loan is on the servicer's watchlist due to low
DSCR.  The loan sponsor is General Growth Properties.  The loan
was included in GGP's bankruptcy filing.  The loan's maturity has
been extended to September 2016.  Moody's LTV and stressed DSCR
are 112% and 0.96X, respectively, compared to 79% and 1.37X at
last review.

The second largest conduit loan is the 850-888 Washington Street
Office Buildings Loan ($17.8 million -- 2.5% of the pool), which
is secured by a 133,000 square foot office property located in
Dedham, Massachusetts.  The property was 86% leased as of March
2010, essentially the same as last review.  The largest tenant is
Salvy Enterprises, which leases 83% of the net rentable area (NRA)
through 2021.  Moody's LTV and stressed DSCR are 99% and 1.09X,
respectively, compared to 98% and 1.10X at last review.

The third largest conduit loan is the Capital Centre Loan
($15.4 million -- 2.2% of the pool), which is secured by a 136,000
square foot office property located in Sacramento, California.
Occupancy is 100%, the same as at last review.  The largest
tenants are the Department of Corporations (33% of NRA) and
Department of Health Services (29% of NRA), with lease expirations
in 2018 and 2011, respectively.  Performance has improved due to
higher revenues.  Moody's LTV and stressed DSCR are 61% and 1.77X,
respectively, compared to 64% and 1.69X at last review.

Moody's rating action is:

  -- Cl. A-X Certificate, Affirmed at Aaa (sf); previously on
     Jan. 26, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-Y Certificate, Affirmed at Aaa (sf); previously on
     Jan. 26, 2005 Definitive Rating Assigned Aaa (sf)

  -- US$507.355M Cl. A-4 Certificate, Affirmed at Aaa (sf);
     previously on Jan. 26, 2005 Definitive Rating Assigned Aaa
     (sf)

  -- US$37.548M Cl. B Certificate, Affirmed at Aaa (sf);
     previously on Aug. 2, 2006 Upgraded to Aaa (sf)

  -- US$18.773M Cl. C Certificate, Affirmed at Aaa (sf);
     previously on July 9, 2007 Upgraded to Aaa (sf)

  -- US$24.138M Cl. D Certificate, Affirmed at Aaa (sf);
     previously on Aug. 28, 2007 Upgraded to Aaa (sf)

  -- US$10.728M Cl. E Certificate, Affirmed at Aa1 (sf);
     previously on Aug. 28, 2007 Upgraded to Aa1 (sf)

  -- US$13.41M Cl. F Certificate, Affirmed at Aa3 (sf); previously
     on Aug. 28, 2007 Upgraded to Aa3 (sf)

  -- US$18.773M Cl. G Certificate, Affirmed at A3 (sf); previously
     on Aug. 28, 2007 Upgraded to A3 (sf)

  -- US$12.069M Cl. H Certificate, Affirmed at Baa2 (sf);
     previously on Aug. 28, 2007 Upgraded to Baa2 (sf)

  -- US$14.751M Cl. J Certificate, Downgraded to Ba3 (sf);
     previously on Jan. 26, 2005 Definitive Rating Assigned Ba1
     (sf)

  -- US$20.114M Cl. K Certificate, Downgraded to Caa1 (sf);
     previously on Jan. 26, 2005 Definitive Rating Assigned Ba2
     (sf)

  -- US$5.364M Cl. L Certificate, Downgraded to Ca (sf);
     previously on Jan. 26, 2005 Definitive Rating Assigned Ba3
     (sf)

  -- US$9.387M Cl. N Certificate, Downgraded to C (sf); previously
     on Oct. 25, 2006 Downgraded to Caa2 (sf)

  -- US$7.865M Cl. O Certificate, Downgraded to C (sf); previously
     on Oct. 25, 2006 Downgraded to Ca (sf)


CREDIT SUISSE: Moody's Downgrades Ratings on Six 2005-C2 Notes
--------------------------------------------------------------
Moody's Investors Service downgraded the rating of six classes of
Credit Suisse First Boston Mortgage Securities Corporation,
Commercial Mortgage Pass-Through Certificates, Series 2005-C2 and
placed 12 classes on review for possible downgrade.

The downgrades are due to realized and anticipated losses from
loans in special servicing.  The pool has experienced an aggregate
$37.3 million loss which resulted in a 100% principal loss for
Classes N, O, and P and a 57% principal loss for Class M.  Moody's
expects significant additional losses from the loans in special
servicing.

Moody's placed Classes A-4 through H on review for possible
downgrade due to higher expected losses for the pool resulting
from anticipated losses from specially serviced and poorly
performing watchlisted loans and interest shortfalls.

As of the July 16, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 16% to $1.4 billion
from $1.6 billion at securitization.  The Certificates are
collateralized by 154 mortgage loans ranging in size from less
than 1% to 11% of the pool, with the top ten loans representing
45% of the pool.  Twelve loans, representing 6% of the pool, have
defeased and are collateralized by U.S. Government securities.

Thirty-six loans, representing 16% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (formerly Commercial Mortgage Securities
Association) monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Three loans have been liquidated from the pool, resulting in an
aggregate $19.1 million loss (90% loss severity on average).  In
addition, the principal balances of two loans were reduced in
conjunction with loan modifications, resulting in an additional
aggregate $18.1 million loss.  Currently ten loans, representing
24% of the pool, are in special servicing.  The special servicer
has recognized an aggregate $263.7 million appraisal reduction for
nine of the specially serviced loans.  The largest specially
serviced loan is The Tri-County Mall Loan ($142.6 million -- 11.2%
of the pool), which is secured by a 1.1 million square foot
regional mall located in Cincinnati, Ohio.  The loan was
transferred to special servicing in August 2009 due to imminent
default and is currently 90+ days delinquent.  The special
servicer has instructed counsel to begin foreclosure proceedings.
The remaining nine loans are secured by a mix of office,
multifamily and retail properties.

As of the most recent remittance date, the transaction has
experienced unpaid accumulated interest shortfalls totaling $5.0
million, affecting Classes D through P.  Interest shortfalls are
caused by special servicing fees, appraisal reductions,
extraordinary trust expenses and loan modifications.  Moody's
anticipates that the pool will continue to experience interest
shortfalls because of the high exposure to specially serviced
loans.

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

Moody's rating action is:

  -- Class A-4, $365,026,000, currently rated Aaa, on review for
     possible downgrade; previously on 9/15/2005 assigned Aaa

  -- Class A-1-A, $362,660,893, currently rated Aaa, on review for
     possible downgrade; previously on 9/15/2005 assigned Aaa

  -- Class A-MFL, $80,000,000, currently rated Aaa, on review for
     possible downgrade; previously on 9/15/2005 assigned Aaa

  -- Class A-MFX, $80,508,000, currently rated Aaa, on review for
     possible downgrade; previously on 9/15/2005 assigned Aaa

  -- Class A-J, $110,350,000, currently rated Aa3, on review for
     possible downgrade; previously on 7/23/2009 downgraded to Aa3
     from Aaa

  -- Class B, $30,095,000, currently rated A2, on review for
     possible downgrade; previously on 7/23/2009 downgraded to A2
     from Aa2

  -- Class C, $16,051,000, currently rated A3, on review for
     possible downgrade; previously on 7/23/2009 downgraded to A3
     from Aa3

  -- Class D, $28,089,000, currently rated Baa3, on review for
     possible downgrade; previously on 7/23/2009 downgraded to
     Baa3 from A2

  -- Class E, $18,057,000, currently rated Ba1, on review for
     possible downgrade; previously on 7/23/2009 downgraded to Ba1
     from A3

  -- Class F, $20,064,000, currently rated Ba3, on review for
     possible downgrade; previously on 7/23/2009 downgraded to Ba3
     from Baa1

  -- Class G, $16,050,000, currently rated B1, on review for
     possible downgrade; previously on 7/23/2009 downgraded to B1
     from Baa2

  -- Class H, $20,064,000, currently rated B2, on review for
     possible downgrade; previously on 7/23/2009 downgraded to B2
     from Baa3

  -- Class J, $8,025,000, downgraded to C from Caa1, previously on
     7/23/2009 downgraded to Caa1 from Ba1

  -- Class K, $8,026,000, downgraded to C from Caa2, previously on
     7/23/2009 downgraded to Caa2 from Ba2

  -- Class L, $8,025,000, downgraded to C from Caa3, previously on
     7/23/2009 downgraded to Caa3 from Ba3

  -- Class M, $859,625, downgraded to C from Ca; previously on
     7/23/2009 downgraded to Ca from B1

  -- Class N, $0, downgraded to C from Ca; previously on 7/23/2009
     downgraded to Ca from B2

  -- Class O, $0, downgraded to C from Ca; previously on 7/23/2009
     downgraded to Ca from B3


CSMC SERIES: S&P Corrects Ratings on 2009-3R Notes to 'B'
---------------------------------------------------------
Standard & Poor's Ratings Services corrected its ratings to 'AAA'
on various classes from CSMC Series 2009-3R and to 'B' on class
30-A-6.  S&P incorrectly lowered the ratings on these classes on
July 22, 2010.  S&P's current ratings reflect its analysis of the
credit support available for these classes to cover the applied
loss amounts as of the June 2010 remittance report.

CSMC Series 2009-3R is a U.S. resecuritized real estate mortgage
investment conduit residential mortgage-backed securities
transaction that contains 30 separate structures backed by 30
classes from 30 separate trusts.  Standard & Poor's rated only 17
classes from three of the structures.  The collateral supporting
the underlying trusts for this transaction consists of prime jumbo
and Alternative-A adjustable-rate, first-lien mortgage loans.

                        Ratings Corrected

                       CSMC Series 2009-3R

                                      Rating
                                      ------
    Class    CUSIP        Current     July 22     Pre-July 22
    -----    -----        -------     -------     -----------
    26-A-1   22943YTV1    AAA         BBB+        AAA
    30-A-1   22943YUR8    AAA         CCC         AAA
    30-A-3   22943YUT4    AAA         CCC         AAA
    30-A-4   22943YUU1    AAA         CCC         AAA
    30-A-5   22943YUV9    AAA         CCC         AAA
    30-A-6   22943YUW7    B           CCC         B+
    30-A-8   22943YUY3    AAA         CCC         AAA


CSMC SERIES: S&P Corrects Ratings on Two 2009-12R Certificates
--------------------------------------------------------------
Standard & Poor's Ratings Services corrected its ratings to 'AAA'
on classes 42A1 and 43A1 from CSMC Series 2009-12R.  S&P
incorrectly lowered the ratings on these classes on July 22, 2010.
S&P's current ratings reflect S&P's analysis of the credit support
available for these classes to cover the applied loss amounts as
of the June 2010 remittance report.

CSMC Series 2009-12R is a U.S. resecuritized real estate mortgage
investment conduit residential mortgage-backed securities (RMBS)
transaction that contains 43 separate structures backed by 43
classes from 43 separate trusts.  Standard & Poor's rated only
three classes from three of the structures.  The collateral
supporting the underlying trusts for this transaction consists of
Alternative A, fixed-rate, first-lien mortgage loans.

                        Ratings Corrected

                       CSMC Series 2009-12R

                                       Rating
                                       ------
     Class    CUSIP        Current     July 22     Pre-July 22
     -----    -----        -------     -------     -----------
     42A1     12642MEC0    AAA         B+          AAA
     43A1     12642MEJ5    AAA         A+          AAA


DRYDEN VI-LEVERAGED: Moody's Upgrades Ratings on Various Notes
--------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Dryden VI-Leveraged Loan CDO 2004
Inc., a synthetic collateralized loan obligation issued in January
2004 referencing a portfolio of primarily senior secured loans:

  -- US$4,000,000 Class B-1 Floating Rate Deferrable Senior
     Subordinate Notes Due 2016, Upgraded to Ba1 (sf); previously
     on February 9, 2010 Upgraded to Ba3 (sf);

  -- US$24,000,000 Class B-2 Fixed Rate Deferrable Senior
     Subordinate Notes Due 2016, Upgraded to Ba1(sf); previously
     on February 9, 2010 Upgraded to Ba3(sf);

  -- US$23,000,000 Class C-1 Floating Rate Deferrable Senior
     Subordinate Notes Due 2016, Upgraded to Caa1(sf); previously
     on June 15, 2009 Downgraded to Caa3(sf);

  -- US$5,000,000 Class C-2 Fixed Rate Deferrable Senior
     Subordinate Notes Due 2016, Upgraded to Caa1(sf); previously
     on June 15, 2009 Downgraded to Caa3(sf);

  -- US$9,000,000 Class Q-1 Securities Due 2016 (current Stated
     Principal of $6,610,330), Upgraded to Ba1(sf); previously on
     June 15, 2009 Downgraded to Ba3(sf);

  -- US$10,000,000 Class Q-2 Securities Due 2016 (current Rated
     Principal of $3,441,343), Upgraded to B1(sf); previously on
     February 9, 2010 Confirmed at B3(sf).

According to Moody's, the rating actions taken on the notes result
primarily from substantial increase in the overcollateralization
of the notes and modest improvement in the credit quality of the
reference collateral since the last rating action in February
2010.

Since the last rating actions taken in February 2010,
overcollateralization available for the Class A, Class B, and
Class C Notes have increased significantly.  Based on the June
2010 trustee report, the Class A, Class B, and Class C Notes
overcollateralization ratios are reported at 255.5%, 155.5% and
111.7%, versus December 2009 levels of 211.7%, 132.2% and 95.3%
respectively.  Moody's also notes that the credit quality of the
reference collateral has modestly improved since the last rating
action in February 2010.  In particular, defaulted securities
currently referenced in the portfolio total about $14.2 million,
accounting for roughly 2.5% of the reference collateral balance
compared to $48.5 million in December 2009, accounting for
approximately 8.5% of the December reference collateral balance.
Additionally, referenced securities rated less than B3 make up
approximately 4.2% of the underlying reference portfolio in June
2010 as compared to 5.3% in December 2009.  Due to the impact of
revised and updated key assumptions described 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.

According to Moody's, the ratings of the Notes also reflect the
risk exposure to Assured Guaranty Municipal Corp. (formerly
Financial Security Assurance Inc.), which acts as Guarantor under
the Investment Agreement in the transaction.  On November 12,
2009, Moody's confirmed the Aa3 insurance financial strength
rating of Assured Guaranty Municipal Corp. with a negative
outlook.


FACTS 2007-1: Moody's Downgrades Ratings on Floating Notes to 'C'
-----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of one tranche of FACTS 2007-1, Ltd.  Moody's has been
notified by the Trustee that the transaction has been terminated
and a final distribution of liquidation proceeds has been
completed.  The notes affected by the rating action are:

* Floating Rate Notes, Downgraded to C; previously on 4/22/2009
  Downgraded to Ca;

The rating action taken reflects the changes in severity of loss
associated with this tranche and reflects the final distribution.


GE CAPITAL: Moody's Confirms Ratings on 2001-1 Certificates
-----------------------------------------------------------
Moody's Investors Service confirmed the rating of two classes,
affirmed three classes and downgraded eight classes of GE Capital
Commercial Mortgage Corp., Commercial Mortgage Pass-Through
Certificates, 2001-1.  The downgrades are due to higher expected
losses for the pool resulting from realized and anticipated losses
from specially serviced and watchlisted loans and concerns about
loans approaching maturity in an adverse environment.  Twenty-four
loans, representing 20% of the pool, mature within the next 12
months and have a Moody's stressed debt service coverage ratio
less than 1.0X.

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

On July 14, 2010, Moody's placed ten classes on review for
possible downgrade.  This action concludes the review of the
transaction.  The rating action is the result of Moody's on-going
surveillance of commercial mortgage backed securities
transactions.

As of the July 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 20% to
$907.1 million from $1.1 billion at securitization.  The
Certificates are collateralized by 135 mortgage loans ranging in
size from less than 1% to 5% of the pool, with the top ten loans
representing 25% of the pool.  Currently, there is one loan,
representing 5% of the pool, with an investment grade underlying
rating.  Forty-eight loans, representing 40% of the pool, have
defeased and are secured by U.S. Government securities.

Twenty seven loans, representing 19% of the pool, are on the
master servicer's watchlist.  The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the CRE Finance Council (formerly Commercial Mortgage Securities
Association) monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Eight loans have been liquidated from the pool, resulting in an
aggregate realized loss of $21.5 million (42% loss severity on
average).  There are 15 loans, representing 11% of the pool,
currently in special servicing.  The largest specially serviced
loan is the Hawthorn Suites Loan ($15.3 million -- 1.7% of the
pool), which is secured by a 280-room extended stay hotel located
in Atlanta, Georgia.  The loan was transferred to special
servicing in April 2009 due to delinquency and is currently 90+
days delinquent.  The master servicer has recognized a
$6.7 million appraisal reduction for this loan.  The remaining 14
specially serviced loans are secured by a mix of property types.
The servicer has recognized a cumulative $25.3 million appraisal
reduction for the ten of the 15 specially serviced loans.  Moody's
estimates an aggregate $40.8 million loss (43% loss severity on
average) for 12 of the specially serviced loans.

In addition to recognizing losses from specially serviced loans,
Moody's has assumed a high default probability on 13 poorly
performing loans, representing 11% of the pool, due to refinancing
risk.  Moody's estimates a $27.1 million aggregate loss for these
troubled loans (27% expected loss on average based on an overall
42% loss given default and an overall 64% probability of default).
Moody's rating action recognizes potential uncertainty around the
timing and magnitude of loss from these troubled loans.

Moody's was provided with full-year 2008 and full-year 2009
operating results for 89% and 74%, respectively, of the pool.
Moody's weighted average LTV ratio, excluding the specially
serviced and troubled loans, is 72% compared to 85% at last
review.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCR are 1.40X and 1.55X, respectively, compared to
1.29X and 1.33X at last review.  Moody's actual DSCR is based on
Moody's net cash flow and the loan's actual debt service.  Moody's
stressed DSCR is based on Moody's NCF and a 9.25% stressed rate
applied to the loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple-notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 41 compared to 67 at last review.

The loan with an underlying rating is the 59 Maiden Lane Loan
($44.3 million -- 5% of the pool), which is secured by a
1.1 million square foot Class B office building located in the
financial district of New York City.  As of October 2009, the
building was 98% leased, essentially the same since last review.
The major tenant is NY Citywide Department of Administrative
Services, which occupies 66% of the net rentable area through
August 2021.  Performance remains stable and in-line with last
review.  The loan matures in April 2011 and has amortized 5% since
last review.  Moody's underlying rating and stressed DSCR are Aaa
and 3.91X, respectively, compared to Aaa and 3.73X at last review.

The top three conduit loans represent 9% of the outstanding pool
balance.  The largest conduit loan is the Long Wharf Maritime
Center I Loan ($33.3 million -- 4% of the pool), which is secured
by a 416,000 square foot office building located in the harbor
area immediately south of downtown New Haven, Connecticut.  As of
March 2009, the property was 60% leased compared to 97.0% at last
review.  The property's largest tenant is AT&T Corp. (AT&T;
Moody's senior unsecured rating A2 -- negative outlook).  AT&T
downsized to 20% of the NRA from 49% NRA when it renewed its lease
in October 2008.  The loan is on the watch-list for low DSCR and
it matures March 2011.  Moody's LTV and stressed DSCR are 152% and
0.68X, compared to 88% and 1.16X, respectively, at last review.

The second largest conduit loan is the Pescadero Apartments Loan
($26 million -- 3% of the pool), which is secured by a 170-unit
Class A apartment complex located 26 miles southeast of San
Francisco in Redwood City, California.  As of June 2010, the
property was 89% leased compared to 95% at last review.  Financial
performance has suffered due to soft market conditions, increased
competition and increased operating expenses.  The loan is on the
master servicer's watchlist due to low debt service coverage.  The
loan matures in March 2011.  Moody's LTV and stressed DSCR are
125% and 0.78X, respectively, compared to 116% and 0.84X,
respectively, at last review.

The third largest conduit loan is the Information Resources Loan
($21.5 million -- 2% of the pool), which is secured by two Class B
office buildings with a total of 252,000 square feet located in
the West Loop submarket of Chicago, Illinois.  The properties were
constructed in 1908 and are 100% leased to Information Resources
Inc. through October 2013.  The loan is on the watchlist for a
technical default related to the tenant improvement and leasing
commission reserve.  Moody's LTV and stressed DSCR are 63% and
1.72X, respectively, compared to 60% and 1.71X, respectively, at
last review.

Moody's rating action is:

  -- Class A-2, $674,543,993, affirmed at Aaa; previously assigned
     Aaa on 7/17/2001

  -- Class X-1, Notional, affirmed at Aaa; previously assigned Aaa
     on 7/17/2001

  -- Class B, $45,157,000, affirmed at Aaa; previously upgraded to
     Aaa from Aa2 on 4/7/2005

  -- Class C, $49,390,000, confirmed at Aaa; previously placed on
     review for possible downgrade on 7/14/2010

  -- Class D, $15,523,000, confirmed at Aa1; previously placed on
     review for possible downgrade on 7/14/2010

  -- Class E, $15,522,000, downgraded to A1 from Aa3; previously
     placed on review for possible downgrade on 7/14/2010

  -- Class F, $15,523,000, downgraded to Baa1 from A2; previously
     placed on review for on 7/14/2010

  -- Class G, $14,112,000, downgraded to Ba3 from Baa2; previously
     placed on review for possible downgrade on 7/14/2010

  -- Class H, $25,400,000, downgraded to Caa2 from Ba1; previously
     placed on review for possible downgrade on 7/14/2010

  -- Class I, $18,345,000, downgraded to Caa3 from Ba2; previously
     placed on review for possible downgrade on 7/14/2010

  -- Class J, $9,878,000, downgraded to Ca from Ba3; previously
     placed on review for possible downgrade on 7/14/2010

  -- Class K, $9,878,000, downgraded to C from B3; previously
     placed on review for possible downgrade on 7/14/2010

  -- Class L, $13,823,944, downgraded to C from Caa2; previously
     placed on review for possible downgrade on 7/14/2010


GREENWICH CAPITAL: Moody's Downgrades Ratings on 2004-FL2 Certs.
----------------------------------------------------------------
Moody's Investors Service downgraded seven classes of Greenwich
Capital Commercial Funding Corp., Commercial Mortgage Pass Through
Certificates, Series 2004-FL2 due to the expectation that the two
remaining loans in the trust, the Southfield Town Center Loan (85%
of the pooled balance) and the Aviation Mall Loan (15%), will have
difficulty refinancing their respective outstanding loan balances
at maturity due to weak collateral performance that is not
expected to appreciably improve over the remaining loan terms.
Moody's also affirmed four pooled classes based upon the loan
exposure per square foot.  Moody's placed seven classes on review
for possible downgrade on July 14, 2010.  This action concludes
Moody's review.  The rating action is a result of Moody's on-going
surveillance of commercial mortgage backed securities.

As of the July 8, 2010 payment date, the transaction's certificate
balance decreased by approximately 80% to $186.0 million from
$921.7 million at securitization due to the payoff of 14 loans
initially in the pool and amortization of the two remaining loans.

Moody's weighted average pooled loan to value ratio is 100%.  The
stressed debt service coverage ratio for pooled loans is 1.09X.

The Southfield Town Center Loan ($158.9 million) is secured by a
four building 2.1 million square foot office complex situated on
35 acres in Southfield, Michigan.  The trust debt, which consists
of $151.2 million of pooled debt and a $7.7 million non-pooled, or
rake class (Class N-SO), is senior to approximately $70.0 million
in non-trust mortgage debt and $25.0 million in mezzanine debt.
The loan matured on July 1, 2009, with no extensions remaining and
was transferred to special servicing in May 2009 due to imminent
default.  The loan was returned to the master servicer in August
2009 as a modified loan.  Significant terms of the loan
modification include an extension of the maturity date to July 1,
2011, with the option to extend for an additional 12 months upon
meeting certain conditions.  Additionally, the loan was converted
from interest-only to amortizing on a 30-year schedule, and
monthly contributions to the rollover reserve account were
increased.

Southfield Town Center has a diverse tenant base with over 200
tenants.  The three largest tenants are Fifth Third Bank (105,041
square feet, lease expiration in 2016), Aon Services (75,698
square feet, lease expiration in 2011) and Microsoft (87,364
square feet, lease expirations in 2017 and 2018).  The complex was
approximately 75% leased, as of April 2010, compared to 82% at
Moody's last review and 73% at securitization.  The property faces
challenges from falling occupancy, declining rents and high market
vacancy.  The Southfield office market vacancy rate was 27% as of
the second quarter 2010, and is projected to increase over the
next three years accompanied by falling rental rates.  The
property has significant roll-over exposure with leases for
approximately 33% of the net rentable area (NRA) expiring through
2012.  The loan is sponsored by a fund controlled by the
Blackstone Group.  Moody's underlying rating is B3, compared to B1
at last review.

The Aviation Mall Loan ($27.0 million) is secured by a portion of
a 630,823 square foot regional mall located in Queensbury, NY.  A
126,000 square foot Target store that was built in 2004 is not
included in the loan collateral.  The trust debt is senior to
approximately $8.8 million of non-trust mortgage debt.  The loan
matured on July 1, 2009 with no extensions remaining and was
transferred to special servicing in May 2009 due to imminent
default.  The loan was returned to the master servicer in June
2009 as a modified loan.  Significant terms of the modification
include a loan extension to July 1, 2011 and a cash trap is in
effect throughout the duration of the extension.

Aviation Mall serves a trade area that includes the Capital
District (the Albany Metropolitan area) and the Glens Falls/Lake
George area with a population of about 174,000 people.  The mall
is anchored by JC Penney, Sears and The Bon-Ton.  Other
significant tenants include Dick's Clothing & Sporting Goods, TJ
Maxx and Regal Cinemas.  As of May 2010, the collateral was
approximately 84% leased and the occupancy rate for mall shop
space was approximately 61%.  Mall shop sales during calendar year
2009 were $273 per square foot.  The loan is sponsored by the
Pyramid Companies.  Moody's underlying rating is B3, compared to
B1 at last review.

Moody's rating action is:

  -- Class B, $11,260,263, affirmed at Aaa (sf); previously on
     September 20, 2005 upgraded to Aaa (sf) from Aa1 (sf)

  -- Class C, $26,363,000, affirmed at Aaa (sf); previously on
     December 14, 2006 upgraded to Aaa (sf) form Aa1 (sf)

  -- Class D, $22,736,000, affirmed at Aaa (sf); previously on
     December 14, 2006 upgraded to Aaa (sf) from Aa2 (sf)

  -- Class E, $12,356,000, affirmed at Aaa (sf); previously on
     December 14, 2006 upgraded to Aaa (sf) from Aa3 (sf)

  -- Class F, $22,804,000, downgraded to Aa2 (sf) from Aaa (sf);
     previously on July 14, 2010 Placed Under Review for Possible
     Downgrade

  -- Class G, $19,519,000, downgraded to A2 (sf) from Aa2 (sf);
     previously on July 14, 2010 Placed Under Review for Possible
     Downgrade

  -- Class H, $14,506,000, downgraded to Baa2 (sf) from A2 (sf);
     previously on July 14, 2010 Placed Under Review for Possible
     Downgrade

  -- Class J, $23,090,000, downgraded to B1 (sf) from Ba1 (sf);
     previously on July 14, 2010 Placed Under Review for Possible
     Downgrade

  -- Class K, $10,337,000, downgraded to B3 (sf) from Ba3 (sf);
     previously on July 14, 2010 Placed Under Review for Possible
     Downgrade

  -- Class L, $15,299,631, downgraded to Caa1 (sf) from B2 (sf);
     previously on July 14, 2010 Placed Under Review for Possible
     Downgrade

  -- Class N-SO, $7,706,398, downgraded to Caa1 (sf) from B2 (sf);
     previously on July 14, 2010 Placed Under Review for Possible
     Downgrade


GS MORTGAGE: DBRS Puts Low-B Provisional Ratings on Class E & F
---------------------------------------------------------------
DBRS has assigned provisional ratings to the following classes of
GS Mortgage Securities Trust, 2010-C1.  The trends are Stable.

  -- Class A-1 at AAA
  -- Class A-2 at AAA
  -- Class B at AAA
  -- Class C at AA
  -- Class D at BBB (high)
  -- Class E at BB
  -- Class F at B
  -- Class G at NR
  -- Class X at AAA

The collateral consists of 23 fixed-rate loans secured by 48
commercial properties.  The portfolio has a balance of
$788,489,108.  The pool benefits from low leverage financing with
a DBRS weighted- average term DSCR and debt yield of 1.64x and
12.7%, respectively based on the trust amount and a 1.54x and
11.7% based on the whole loan.  The pool also benefits from
significant amortization as 19.2% of the pool amortizes down by
maturity.

DBRS shadow-rates eleven loans, representing 58.4% of the pool,
investment grade.  The investment-grade shadow-rated loans
indicate the long-term stability of the underlying assets.


HARLEY-DAVIDSON MOTORCYCLE: S&P Raises Ratings on Various Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B notes from Harley-Davidson Motorcycle Trust's series 2005-3,
2007-1, 2007-2, and 2007-3.  In addition, S&P affirmed 25 of its
ratings on the remaining class A, B, and C notes from HDMT's
series 2005-3, 2006-1, 2006-2, 2006-3, 2007-1, 2007-2, 2007-3,
2008-1, 2009-1, and 2009-2.

The rating actions reflect the collateral performance to date of
each transaction and S&P's views regarding future collateral
performance while taking into account the fact that recoveries,
delinquencies, losses, and other performance data can be higher or
lower depending on the season of the year.  The rating actions
also reflect the respective credit enhancement levels of the
affected series.  Increases in recovery values for the underlying
collateral have helped to improve the cumulative net loss rates
for most of these series, and, as a result, S&P's lifetime net
loss expectations are slightly lower than or equal to S&P's
previous loss expectations for all 10 transactions except for
series 2007-2.

                              Table 1

                    Collateral Performance (%)

                   As of July 2010 distribution

                                           Former      Revised
                Pool    Current  Current   lifetime    lifetime
  Series  Mo.   factor  CRR(i)   CNL(ii)   CNL exp.    CNL exp.
  ------  ---   ------  -------  -------   --------    ---------
  2005-3  59     9.51   51.06    5.02      5.25-5.75   5.00-5.30
  2006-1  53    13.01   53.91    4.35      4.75-5.25   4.60-5.00
  2006-2  50    16.63   54.14    4.65      5.25-5.75   5.00-5.40
  2006-3  47    19.16   53.52    5.01      5.75-6.25   5.40-5.80
  2007-1  42    22.75   52.38    4.99      6.00-6.50   5.90-6.30
  2007-2  38    28.00   51.53    5.78      6.75-7.25   7.00-7.50
  2007-3  35    32.02   51.27    5.02      6.35-6.85   6.35-6.85
  2008-1  29    36.38   50.40    4.34      6.35-6.85   6.35-6.85
  2009-1  14    67.25   46.22    2.51      7.00-7.25   7.00-7.25
  2009-2  12    71.10   46.30    2.02      7.00-7.25   7.00-7.25

  (i) CRR-cumulative recovery rate.  (ii) CNL-cumulative net loss.

All transactions have a sequential principal payment structure,
which pays principal to the senior classes of notes in full before
the subordinate classes receive any principal.  The issuer
initially structured each transaction with credit enhancement in
the form of subordination (for the higher-rated tranches), a
reserve account, and excess spread.  In addition, series 2007-3
was structured with a yield-supplement account to cover interest
payments on lower-yielding loans.

Reserve accounts for HDMT series 2005-3, 2006-1, 2006-2, and 2006-
3 were funded initially with 0.75% of the initial collateral
balance and structured to grow to a target of 2.00% of the current
collateral balance, with a floor of 1.0% of the initial collateral
balance for each transaction.

Reserve accounts for HDMT series 2007-1, 2007-2, 2007-3, and 2008-
1 were funded initially with 0.25% of the initial collateral
balance and structured to grow to a target of 1.5% of the current
collateral balance except for series 2008-1, which has a reserve
account structured to grow to 2.25% of the current collateral
balance, with a floor of 1.0% of the initial collateral balance
for each transaction.

Reserve accounts for HDMT series 2009-1 and 2009-2 were funded
initially with 1.00% of the initial collateral balance and
structured to grow to a target of 2.70% of the current collateral
balance, with a floor of 1.0% of the initial collateral balance
for each transaction.

However, each deal is also structured with three performance
triggers (average loss, average delinquency, and cumulative net
loss) that, if breached, require the reserve accounts to build up
to a target of 6.0% of the current collateral balance.  If at any
point, pool performance improves below the trigger levels for
three consecutive months such that the triggers breach is cured,
the transaction documents allow for all cash above and beyond the
initial required target to be released back to the seller.

As of the July 2010 distribution date, cumulative net losses were
above the highest trigger threshold for each transaction issued
from 2005 through 2008; as a result, Standard & Poor's believes
that the trigger may not be cured for the remainder of the time
the transaction is outstanding.  The 2009 transactions are
currently not in breach of any performance triggers.

                             Table 2

                 Performance Trigger Information

                   As of July 2010 distribution

                                                      Current   Current
                  Initial  Average           Average  required  reserve
         Initial  target   net loss CNL      delinq.  reserve   account
         deposit  (% of    trigger  trigger  trigger  account   (% of
Series  (%)      current) violated violated violated (%)       current)
------  -------  -------- -------- -------- -------- --------- --------
2005-3  1.00     2.00     No       Yes      No       1.0(i)    10.51
2006-1  0.25     2.00     No       Yes      No       1.0(i)    7.69
2006-2  0.25     2.00     No       Yes      No       1.0(i)    6.01
2006-3  0.25     2.00     No       Yes      No       6.0(ii)   6.00
2007-1  0.25     1.50     No       Yes      No       6.0(ii)   6.00
2007-2  0.25     1.50     No       Yes      No       6.0(ii)   6.00
2007-3  0.25     1.50     No       Yes      No       6.0(ii)   6.00
2008-1  0.25     2.25     No       Yes      No       6.0(ii)   6.00
2009-1  0.25     2.70     No       No       No       2.7(ii)   2.70
2009-2  0.25     2.70     No       No       No       2.7(ii)   2.70

               (i)Percent of initial pool balance.
               (ii)Percent of current pool balance.

The upgrades and affirmations of the ratings reflect growth in
credit support, as a percent of the amortizing pool balances,
compared with S&P's expectations for remaining losses.  For each
series, the upgraded or affirmed classes were able to withstand
cash flow stress scenarios at their respective rating levels using
S&P's revised lifetime loss expectations.

                              Table 3

                        Hard Credit Support

                   As of July 2010 distribution

                                               Current
                              Total hard       total hard
                  Pool        credit support   credit support(i)
  Series   Class  factor(%)   at issuance(i)   (% of current)
  ------   -----  ---------   ---------------  -----------------
  2005-3   A      9.51        6.00             65.73
  2005-3   B      9.51        0.75             10.51
  2006-1   A      13.01       6.00             48.05
  2006-1   B      13.01       0.75             7.69
  2006-2   A      16.63       6.75             42.10
  2006-2   B      16.63       0.75             6.01
  2006-3   A      19.16       6.75             37.32
  2006-3   B      19.16       0.75             6.00
  2007-1   A      22.75       8.75             43.37
  2007-1   B      22.75       2.75             16.99
  2007-1   C      22.75       0.25             6.00
  2007-2   A      28.00       9.50             39.03
  2007-2   B      28.00       3.00             15.82
  2007-2   C      28.00       0.25             6.00
  2007-3   A      32.02       9.50             34.89
  2007-3   B      32.02       3.00             14.59
  2007-3   C      32.02       0.25             6.00
  2008-1   A      36.38      10.25             33.49
  2008-1   B      36.38       3.25             14.25
  2008-1   C      36.38       0.25             6.00
  2009-1   A      67.25      23.00             35.41
  2009-2   A      71.10      23.00             33.64

(i) Consists of a reserve account and subordination, and excludes
    excess spread and a yield supplement account that can also
    provide additional enhancement.

S&P incorporated its cash flow analysis, which included a review
of the transactions' current and historical performance to
estimate future performance, into S&P's review of these series.
S&P's cash flow scenarios included forward-looking assumptions on
recoveries, the timing of losses, and voluntary absolute
prepayment speeds that S&P believes are appropriate given each
transaction's current performance.  The results demonstrated, in
S&P's view, that all of the classes from the transactions S&P
reviewed have adequate credit enhancement at their respective
raised and affirmed rating levels.

S&P will continue to monitor the performance of all of the
outstanding Harley-Davidson Motorcycle Trust transactions to
ensure that the credit enhancement remains sufficient, in S&P's
view, to cover S&P's revised cumulative net loss expectations
under its stress scenarios for each of the rated classes.

                          Ratings Raised

                 Harley-Davidson Motorcycle Trust

                                     Rating
                                     ------
                  Series   Class   To       From
                  ------   -----   --       ----
                  2005-3   B       AAA      A
                  2007-1   B       AA       A
                  2007-2   B       AA-      A
                  2007-3   B       AA-      A

                         Ratings Affirmed

                 Harley-Davidson Motorcycle Trust

                      Series   Class   Rating
                      ------   -----   ------
                      2005-3   A-2     AAA
                      2006-1   A-2     AAA
                      2006-1   B       A
                      2006-2   A-2     AAA
                      2006-2   B       A
                      2006-3   A-2     AAA
                      2006-3   B       A
                      2007-1   A-4     AAA
                      2007-1   C       BBB
                      2007-2   A-4     AAA
                      2007-2   C       BBB
                      2007-3   A-3     AAA
                      2007-3   A-4     AAA
                      2007-3   C       BBB
                      2008-1   A-3a    AAA
                      2008-1   A-3b    AAA
                      2008-1   A-4     AAA
                      2008-1   B       A-
                      2008-1   C       BB+
                      2009-1   A-2     AAA
                      2009-1   A-3     AAA
                      2009-1   A-4     AAA
                      2009-2   A-2     AAA
                      2009-2   A-3     AAA
                      2009-2   A-4     AAA


HELLER FINANCIAL: Fitch Downgrades Ratings on 1999 PH-1 Certs.
--------------------------------------------------------------
Fitch Ratings has downgraded and assigned Rating Outlooks to
several classes of Heller Financial Commercial Mortgage Asset
Corp.'s mortgage pass-through certificates, series 1999 PH-1.
Fitch has also assigned Loss Severity ratings and Recovery Ratings
to numerous classes.

The downgrades are due to an increase in expected losses on
specially serviced assets coupled with expected losses following
Fitch's prospective review of potential stresses to the
transaction.  The majority of the total expected losses are
associated with loans currently in special servicing.  Fitch
expects losses of 27.2% of the remaining transaction balance, or
$42.2 million, from loans in special servicing and loans that
cannot refinance at maturity based on Fitch's refinance test.

As of the June 2010 distribution date, the pool's certificate
balance has paid down 84.6% to $155.3 million from $1.0097 billion
at issuance.  Five loans are defeased (8.1% of the current
transaction balance).

There are seven specially serviced loans in the pool (49.6%),
including three of the five largest loans in the pool.  Three
loans are delinquent, one is in foreclosure, one is real estate
owned and two are current.

The largest specially serviced asset (21.1%) is a 444,760 square
foot office property located in Franklin Township, NJ.  The loan
transferred to special servicing in January 2009 and has been REO
as of April 2010.  The property is under contract and closing is
anticipated this month.  Fitch expects losses upon liquidation.

The second largest specially serviced asset (11.2%) is secured by
a two office building portfolio (248,470 sf) in Springfield, IL.
The loan transferred to special servicing in June 2010 and is
currently 30 days delinquent.  The buildings are occupied by the
State of Illinois Department of Public Aid and Health Sisters
Hospital System.  It should be noted that the State is eight
months delinquent on its rent and owes the borrower approximately
$1.5 million.  The State's persistent delinquency has drained the
Borrower's cash reserves.  As of YE 2009, the debt service
coverage ratio and occupancy was 1.40 times net operating income
and 100%, respectively.

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

Similar to Fitch's prospective analysis of recent vintage
commercial mortgage backed securities, 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
refinancing to a DSCR of 1.25x or higher were considered to pay
off at maturity.  Of the non-defeased or non-specially serviced
loans, one (5% of the pool) incurred a loss when compared to
Fitch's stressed value.

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

  -- $15.9 million class G to 'AAA/LS-4' from 'AA+'; Outlook
     Stable.

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

  -- $20.2 million class J to 'B-/LS4' from 'BBB-'; Outlook
     Negative

  -- $11.1 million class K to 'CC/RR4' from 'BB+';

  -- $9.7 million class L to 'C/RR6' from 'CCC/RR1';

  -- $9.7 million class M to 'C/RR6' from 'CC/RR3'.

In addition, Fitch has affirmed, maintained or revised the Outlook
and assigned LS ratings as indicated:

  -- $12.2 million class E at 'AAA/LS3'; Outlook Stable;

  -- $37.9 million class F at 'AAA/LS3'; Outlook Stable;

  -- $35.3 million class H at 'A-/LS3'; Outlook to Negative from
     Stable.

Classes A1, A2, B, C, and D have paid in full.


HELLER SBA: Fitch Downgrades Ratings on 1998-1 Certificates
-----------------------------------------------------------
Fitch Ratings downgrades Heller SBA pass-through adjustable-rate
certificates, series 1998-1 and assigns Rating Outlooks:

  -- Class A to 'AA' from 'AAA';Outlook Negative;
  -- Class M-1 to 'A' from 'AA';Outlook Negative;
  -- Class M-2 to 'BBB' from 'A';Outlook Negative;
  -- Class M-3 to 'BB' from 'BBB';Outlook Negative;
  -- Class B to 'B' from 'BB';Outlook Negative;

Fitch has withdrawn the 'AAA' rating on class X.

The rating withdrawal of the class X note is consistent with
Fitch's revised policy on IO ratings.

The downgrades reflect continued deterioration within the
collateral pool for the transaction.  Delinquencies have continued
to increase and roll through to late stage buckets.  As of the
July 2010 reporting period, 32.61% of the pool is currently
delinquent.  Cumulative net losses to date are 3.45%.  Based on
Fitch's review, detailed below, loss coverage was found to be
limited for the outstanding notes due to asset deterioration.
Furthermore, obligor concentration risk is present for the more
subordinate notes.  The Negative Rating Outlooks are a result of
the higher delinquency roll rate the transaction continues to
experience.  As late-stage delinquencies continue through the
liquidation process, credit enhancement may be materially impacted
if ultimate recoveries are lower than expected.

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 cashflow
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 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 U.S.
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 for 'AAA' to 1.5 for '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.


HOMEEQ SERVICING: Fitch Maintains Ratings on 22 Transactions
------------------------------------------------------------
Fitch Ratings maintains the ratings listed below on 22
transactions currently serviced by HomeEq Servicing.  Fitch has
received a request to confirm these ratings in connection with the
proposed transfer of servicing from HomeEq to Ocwen Financial
Corp. resulting from the proposed acquisition of HomeEq's
servicing business by Ocwen.  Consistent with its statements on
policies regarding rating confirmations in structured finance
transactions (Jan. 13, 2009), Fitch is treating this request as a
notification.

Fitch currently rates both HomeEq and Ocwen as U.S. residential
servicers:

HomEq:

  -- U.S. residential primary servicer rating for Alt-A product
     'RPS1';

  -- U.S. residential primary servicer rating for subprime product
     'RPS1';

  -- U.S. residential special servicer rating 'RSS1'.

Ocwen:

  -- U.S. residential primary servicer rating for subprime product
     'RPS2';

  -- U.S. residential special servicer rating 'RSS2'.

Fitch has reviewed these 22 transactions based on its current
rating methodology, first using HomeEq and then Ocwen as the
primary servicer for the loans expected to be transferred in
connection with the proposed acquisition to see what impact the
proposed transfer would have on the existing ratings.  Servicer
ratings are taken into account when deriving loss expectations.
In almost every case, the loss expectations were higher using
Ocwen as the servicer given their lower servicer rating.  However,
the amount of the increase in expected loss for each transaction
varied based on what percentage of the pool would be affected by
the transfer.  While loss expectations increased, the increase was
not significant enough to cause a downgrade in the existing
ratings at this time.

Fitch expects to confirm that, based on the information provided
to date, the proposed acquisition and subsequent servicing
transfer, in and of itself, will not have an impact on the
existing ratings at the time of the transfer.  Fitch does not
believe that the transfer will be a cause for immediate downgrade
of any of the securities in these transactions.  However, Fitch
notes that this does not preclude the possibility that future
rating actions may be taken, consistent with Fitch residential
mortgage-backed securities rating criteria, which could reflect,
in part, the positive or negative effects arising as a result of
the transfer.  Fitch also notes that events may occur and
additional information may be provided prior to the proposed
acquisition and transfer that may affect its analysis.

The ratings confirmation, if issued, will only address the effect
of transferring the servicing from HomeEq to Ocwen.  It will not
address whether the transfer is permitted by the terms of the
documents, nor will it address whether it is in the best interests
of, or prejudicial to, some or all of the holders of the
aforementioned securities.

The current ratings are:

Asset-Backed Funding Corporation 2003-WMC1

  -- class M-1 (CUSIP: 04542BEA6) rated 'AAA/LS2';
  -- class M-2 (04542BEB4) rated 'A+/LS4';
  -- class M-3 (04542BEC2) rated 'BBB/LS5';
  -- class M-4 (04542BED0) rated 'BB/LS5';
  -- class M-5 (04542BEE8) rated 'B/LS5';
  -- class M-6 (04542BEF5) rated 'B/LS5'.

Asset-Backed Funding Corporation 2005-WMC1

  -- class A1 (CUSIP: 04542BNX6) rated 'AAA/LS5', Outlook Stable;
  -- class A2D (04542BPB2) rated 'AAA/LS5', Outlook Stable;
  -- class A2MZ (04542BPC0) rated 'AAA/LS5', Outlook Stable;
  -- class M1 (04542BPD8) rated 'A/LS4', Outlook Positive;
  -- class M2 (04542BPE6) rated 'CCC/RR2';
  -- class M3 (04542BPF3) rated 'CC/RR5';
  -- class M4 (04542BPG1) rated 'C/RR6';
  -- class M5 (04542BPH9) rated 'C/RR6';
  -- class M6 (04542BPJ5) rated 'D/RR6';
  -- class M7 (04542BPK2) rated 'D/RR6';
  -- class M8 (04542BPL0) rated 'D/RR6';
  -- class M9 (04542BPM8) rated 'D/RR6'.

Asset-Backed Securities Corp. NC 2006-HE2

  -- class A1 (CUSIP: 04541GWB4) rated 'CCC/RR2';
  -- class A1-A (04541GWC2) rated 'CC/RR5';
  -- class A3 (04541GWE8) rated 'CC/RR3';
  -- class A4 (04541GWF5) rated 'CC/RR3';
  -- class M1 (04541GWG3) rated 'C/RR6';
  -- class M2 (04541GWH1) rated 'D/RR6';
  -- class M3 (04541GWJ7) rated 'D/RR6';
  -- class M4 (04541GWK4) rated 'D/RR6';
  -- class M5 (04541GWL2) rated 'D/RR6';
  -- class M6 (04541GWM0) rated 'D/RR6';
  -- class M7 (04541GWN8) rated 'D/RR6';
  -- class M8 (04541GWP3) rated 'D/RR6';
  -- class M9 (04541GWQ1) rated 'D/RR6';
  -- class M10 (04541GWR9) rated 'D/RR6';
  -- class M11 (04541GWS7) rated 'D/RR6'.

Citigroup Mortgage Loan Trust Inc. 2005-HE3

  -- class A-1 (CUSIP: 17307GXJ2) rated 'AAA/LS5', Outlook Stable;
  -- class A-2D (17307GWQ7) rated 'AAA/LS5', Outlook Stable;
  -- class M-1 (17307GWR5) rated 'BBB/LS5', Outlook Positive;
  -- class M-2 (17307GWS3) rated 'CCC/RR2';
  -- class M-3 (17307GWT1) rated 'CC/RR5';
  -- class M-4 (17307GWU8) rated 'C/RR6';
  -- class M-5 (17307GWV6) rated 'C/RR6';
  -- class M-6 (17307GWW4) rated 'C/RR6';
  -- class M-7 (17307GWX2) rated 'C/RR6';
  -- class M-8 (17307GWY0) rated 'C/RR6';
  -- class M-9 (17307GWZ7) rated 'D/RR6';
  -- class M-10 (17307GXA1) rated 'D/RR6';
  -- class M-11 (17307GXK9) rated 'D/RR6';
  -- class M-12 (17307GXL7) rated 'D/RR6'.

Equifirst Mortgage Loan Trust 2004-1

  -- class I-A1 (CUSIP: 29445FAR9) rated 'AAA/LS3', Outlook
     Stable;

  -- class II-A2 (29445FAT5) rated 'AAA/LS3', Outlook Stable;

  -- class II-A3 (29445FAU2) rated 'AAA/LS3', Outlook Negative;

  -- class M-1 (29445FAV0) rated 'AA+/LS4', Outlook Negative;

  -- class M-2 (29445FAW8) rated 'AA-/LS5', Outlook Negative;

  -- class M-3 (29445FAX6) rated 'A+/LS5', Outlook Negative;

  -- class M-4 (29445FAY4) rated 'BBB/LS5', Outlook Negative;

  -- class M-5 (29445FAZ1) rated 'BB/LS5', Outlook Negative;

  -- class M-6 (29445FBA5) rated 'CCC/RR4';

  -- class M-7 (29445FBB3) rated 'C/RR6';

  -- class B-1 (29445FBC1) rated 'D/RR6'.

First Franklin Mortgage Loan Trust 2004-FFH1

  -- class M-1 (CUSIP: 32027NGQ8) rated 'AA+/LS3';
  -- class M-2 (32027NGR6) rated 'BBB/LS4';
  -- class M-3 (32027NGS4) rated 'B/LS5';
  -- class M-4 (32027NGT2) rated 'CC/RR4';
  -- class M-5 (32027NGU9) rated 'D/RR6';
  -- class M-6 (32027NGV7) rated 'D/RR6';
  -- class M-7 (32027NGW5) rated 'D/RR6';
  -- class M-8 (32027NGX3) rated 'D/RR6'.

First Franklin Mortgage Loan Trust 2005-FF5

  -- class A-1 (CUSIP: 32027NRP8) rated 'AAA/LS5', Outlook Stable;
  -- class M-1 (32027NRT0) rated 'AA+/LS4', Outlook Stable;
  -- class M-2 (32027NRU7) rated 'BBB/LS4', Outlook Stable;
  -- class M-3 (32027NRV5) rated 'B/LS5', Outlook Negative;
  -- class M-4 (32027NRW3) rated 'CC/RR5';
  -- class M-5 (32027NRX1) rated 'C/RR6';
  -- class M-6 (32027NRY9) rated 'C/RR6';
  -- class M-7 (32027NRZ6) rated 'D/RR6';
  -- class M-8 (32027NSA0) rated 'D/RR6';
  -- class M-9 (32027NSB8) rated 'D/RR6';
  -- class M-10 (32027NSC6) rated 'D/RR6';
  -- class B (32027NSD4) rated 'D/RR6'.

Finance America Mortgage Loan Trust 2004-2

  -- class M-1 (CUSIP: 317350BD7) rated 'AAA/LS3', Outlook
     Negative;

  -- class M-2 (317350BE5) rated 'BBB/LS3', Outlook Negative;

  -- class M-3 (317350BF2) rated 'B/LS5', Outlook Negative;

  -- class M-4 (317350BG0) rated 'CCC/RR4';

  -- class M-5 (317350BH8) rated 'CC/RR5';

  -- class M-6 (317350BJ4) rated 'C/RR6';

  -- class M-7 (317350BK1) rated 'C/RR6';

  -- class M-8 (317350BL9) rated 'D/RR6';

  -- class M-9 (317350BM7) rated 'D/RR6'.

Mortgage Asset Securitization Transactions, Inc. 2004-FRE1

  -- class M-4 (CUSIP: 57643LDX1) rated 'AA-/LS4';
  -- class M-5 (57643LDY9) rated 'A+/LS4';
  -- class M-6 (57643LDZ6) rated 'A/LS4';
  -- class M-7 (57643LEA0) rated 'B/LS4';
  -- class M-8 (57643LEB8) rated 'C/RR5';
  -- class M-9 (57643LEC6) rated 'D/RR6'.

Mortgage Asset Securitization Transactions, Inc. 2004-WMC2

  -- class M-1 (CUSIP: 57643LDJ2) rated 'BBB/LS2';
  -- class M-2 (57643LDK9) rated 'CCC/RR1';
  -- class M-3 (57643LDL7) rated 'CC/RR2';
  -- class M-4 (57643LDM5) rated 'CC/RR4';
  -- class M-5 (57643LDN3) rated 'C/RR6';

Mortgage Asset Securitization Transactions, Inc. 2005-FRE1

  -- class A-1 (CUSIP: 57643LLV6) rated 'AAA/LS4', Outlook Stable;
  -- class A-4 (57643LLY0) rated 'A/LS4', Outlook Positive;
  -- class A-5 (57643LLZ7) rated 'BBB/LS4', Outlook Positive;
  -- class M-1 (57643LMA1) rated 'CC/RR4';
  -- class M-2 (57643LMB9) rated 'C/RR6';
  -- class M-3 (57643LMC7) rated 'D/RR6';
  -- class M-4 (57643LMD5) rated 'D/RR6';
  -- class M-5 (57643LME3) rated 'D/RR6';
  -- class M-6 (57643LMF0) rated 'D/RR6';
  -- class M-7 (57643LMG8) rated 'D/RR6';
  -- class M-8 (57643LMH6) rated 'D/RR6';
  -- class M-9 (57643LMJ2) rated 'D/RR6';
  -- class M-10 (57643LMK9) rated 'D/RR6'.

Meritage Mortgage Loan Trust 2004-1

  -- class M-1 (CUSIP: 59001FAQ4) rated 'CC/RR2';
  -- class M-2 (59001FAR2) rated 'CC/RR6';
  -- class M-3 (59001FAS0) rated 'D/RR6';
  -- class M-4 (59001FAT8) rated 'D/RR6';
  -- class M-5 (59001FAU5) rated 'D/RR6';
  -- class M-6 (59001FAV3) rated 'D/RR6';
  -- class M-7 (59001FAW1) rated 'D/RR6';
  -- class M-8 (59001FAX9) rated 'D/RR6';
  -- class B-1 (59001FAZ4) rated 'D/RR6'.

Park Place Securities, Inc. 2004-MHQ1

  -- class A-4 (CUSIP: 70069FCU9) rated 'AAA/LS5', Outlook Stable;
  -- class M-1 (70069FCV7) rated 'AA+/LS4', Outlook Stable;
  -- class M-2 (70069FCW5) rated 'BBB/LS4', Outlook Negative;
  -- class M-3 (70069FCX3) rated 'CCC/RR3';
  -- class M-4 (70069FCY1) rated 'CC/RR5';
  -- class M-5 (70069FCZ8) rated 'CC/RR6';
  -- class M-6 (70069FDA2) rated 'C/RR6';
  -- class M-7 (70069FDB0) rated 'D/RR6';
  -- class M-8 (70069FDC8) rated 'D/RR6';
  -- class M-9 (70069FDD6) rated 'D/RR6';
  -- class M-10 (70069FDF1) rated 'D/RR6'.

Park Place Securities, Inc. 2004-WHQ1

  -- class M-1 (CUSIP: 70069FBR7) rated 'AA+/LS4', Outlook Stable;
  -- class M-2 (70069FBS5) rated 'BBB/LS4', Outlook Negative;
  -- class M-3 (70069FBT3) rated 'CCC/RR4';
  -- class M-4 (70069FBU0) rated 'CC/RR5';
  -- class M-5 (70069FBV8) rated 'CC/RR6';
  -- class M-6 (70069FBW6) rated 'C/RR6';
  -- class M-7 (70069FBX4) rated 'C/RR6';
  -- class M-8 (70069FBY2) rated 'D/RR6';
  -- class M-9 (70069FBZ9) rated 'D/RR6';
  -- class M-10 (70069FCA3) rated 'D/RR6'.

Park Place Securities, Inc. 2004-WHQ2

  -- class A-1B (CUSIP: 70069FEU7) rated 'AAA/LS5', Outlook
     Stable;

  -- class A-1D (70069FEW3) rated 'AAA/LS5', Outlook Stable;

  -- class A-2A (70069FEX1) rated 'AAA/LS5', Outlook Stable;

  -- class A-2B (70069FEY9) rated 'AAA/LS5', Outlook Stable;

  -- class A-3A (70069FEC7) rated 'AAA/LS5', Outlook Stable;

  -- class A-3D (70069FEF0) rated 'AAA/LS5', Outlook Stable;

  -- class A-3E (70069FEG8) rated 'AAA/LS', Outlook Stable;

  -- class M-1 (70069FEH6) rated 'AA+/LS5', Outlook Stable;

  -- class M-2 (70069FEJ2) rated 'BBB/LS4', Outlook Negative;

  -- class M-3 (70069FEK9) rated 'CCC/RR3';

  -- class M-4 (70069FEL7) rated 'CC/RR5';

  -- class M-5 (70069FEM5) rated 'C/RR6';

  -- class M-6 (70069FEN3) rated 'C/RR6';

  -- class M-7 (70069FEP8) rated 'C/RR6';

  -- class M-8 (70069FEQ6) rated 'D/RR6';

  -- class M-9 (70069FER4) rated 'D/RR6';

  -- class M-10 (70069FES2) rated 'D/RR6'.

Park Place Securities, Inc. 2005-WHQ1

  -- class A-2A (CUSIP: 70069FGL5) rated 'AAA/LS5', Outlook
     Stable;

  -- class A-2B (70069FGM3) rated 'AAA/LS5', Outlook Stable;

  -- class A-3C (70069FFY8) rated 'AAA/LS5', Outlook Stable;

  -- class A-3D (70069FFZ5) rated 'AAA/LS5', Outlook Stable;

  -- class M-1 (70069FGA9) rated 'AA+/LS5', Outlook Positive;

  -- class M-2 (70069FGB7) rated 'BB/LS5', Outlook Negative;

  -- class M-3 (70069FGC5) rated 'CCC/RR3';

  -- class M-4 (70069FGD3) rated 'CCC/RR5';

  -- class M-5 (70069FGE1) rated 'CC/RR6';

  -- class M-6 (70069FGF8) rated 'CC/RR6';

  -- class M-7 (70069FGG6) rated 'C/RR6';

  -- class M-8 (70069FGH4) rated 'C/RR6';

  -- class M-9 (70069FGJ0) rated 'D/RR6';

  -- class M-10 (70069FGN1) rated 'D/RR6';

  -- class M-11 (70069FGP6) rated 'D/RR6'.

Park Place Securities, Inc. 2005-WHQ2

  -- class A-1A (CUSIP: 70069FHN0) rated 'AAA/LS4', Outlook
     Negative;

  -- class A-1B (70069FHP5) rated 'A/LS4', Outlook Negative;

  -- class A-2D (70069FHT7) rated 'A/LS4', Outlook Negative;

  -- class M-1 (70069FHU4) rated 'B/LS5', Outlook Negative;

  -- class M-2 (70069FHV2) rated 'CCC/RR5';

  -- class M-3 (70069FHW0) rated 'CC/RR5';

  -- class M-4 (70069FHX8) rated 'CC/RR6';

  -- class M-5 (70069FHY6) rated 'C/RR6';

  -- class M-6 (70069FHZ3) rated 'C/RR6';

  -- class M-7 (70069FJA6) rated 'C/RR6';

  -- class M-8 (70069FJB4) rated 'C/RR6';

  -- class M-9 (70069FJC2) rated 'D/RR6';

  -- class M-10 (70069FJD0) rated 'D/RR6';

  -- class M-11 (70069FJE8) rated 'D/RR6';

  -- class M-12 (70069FJF5) rated 'D/RR6'.

Park Place Securities, Inc. 2005-WHQ3

  -- class A-1A (CUSIP: 70069FJG3) rated 'AAA/LS5', Outlook
     Stable;

  -- class A-1B (70069FJH1) rated 'AAA/LS5', Outlook Stable;

  -- class A-2D (70069FJN8) rated 'AAA/LS5', Outlook Stable;

  -- class M-1 (70069FJP3) rated 'AA+/LS5', Outlook Negative;

  -- class M-2 (70069FJQ1) rated 'B/LS5', Outlook Negative;

  -- class M-3 (70069FJR9) rated 'CCC/RR5';

  -- class M-4 (70069FJS7) rated 'CC/RR5';

  -- class M-5 (70069FJT5) rated 'CC/RR6';

  -- class M-6 (70069FJU2) rated 'C/RR6';

  -- class M-7 (70069FJV0) rated 'C/RR6';

  -- class M-8 (70069FJW8) rated 'D/RR6';

  -- class M-9 (70069FJX6) rated 'D/RR6';

  -- class M-10 (70069FJY4) rated 'D/RR6';

  -- class M-11 (70069FJZ1) rated 'D/RR6';

  -- class M-12 (70069FJJ7) rated 'D/RR6'.

Park Place Securities, Inc. 2005-WHQ4

  -- class A-1A (CUSIP: 70069FML8) rated 'B/LS4', Outlook
     Negative;

  -- class A-2C (70069FMQ7) rated 'AAA/LS4', Outlook Stable;

  -- class A-2D (70069FMR5) rated 'CCC/RR3';

  -- class M-1 (70069FMS3) rated 'CC/RR5';

  -- class M-2 (70069FMT1) rated 'C/RR6';

  -- class M-3 (70069FMU8) rated 'C/RR6';

  -- class M-4 (70069FMV6) rated 'C/RR6';

  -- class M-5 (70069FMW4) rated 'D/RR6';

  -- class M-6 (70069FMX2) rated 'D/RR6';

  -- class M-7 (70069FMY0) rated 'D/RR6';

  -- class M-8 (70069FMZ7) rated 'D/RR6';

  -- class M-9 (70069FNA1) rated 'D/RR6';

  -- class M-10 (70069FNB9) rated 'D/RR6';

  -- class M-11 (70069FNC7) rated 'D/RR6'.

Soundview Home Equity Loan Trust 2004-1

  -- class M1 (CUSIP: 83611MBB3) rated 'AA+/LS3';
  -- class M2 (83611MBC1) rated 'BBB/LS4';
  -- class M3 (83611MBD9) rated 'BB/LS5';
  -- class M4 (83611MBE7) rated 'B/LS5';
  -- class M5 (83611MBF4) rated 'CCC/RR5';
  -- class M6 (83611MBG2) rated 'CCC/RR5';
  -- class M7 (83611MBH0) rated 'CC/RR5';
  -- class M8 (83611MBJ6) rated 'CC/RR6';
  -- class M9 (83611MBK3) rated 'C/RR6'.

Soundview Home Equity Loan Trust 2005-CTX1

  -- class A-5 (CUSIP: 83611PBS9) rated 'AAA/LS4', Outlook Stable;
  -- class A-6 (83611PBT7) rated 'AAA/LS4', Outlook Stable;
  -- class M-1 (83611PBU4) rated 'A/LS5', Outlook Stable;
  -- class M-2 (83611PBV2) rated 'B/LS5', Outlook Stable;
  -- class M-3 (83611PBW0) rated 'CCC/RR4';
  -- class M-4 (83611PBX8) rated 'CCC/RR5';
  -- class M-5 (83611PBY6) rated 'CC/RR6';
  -- class M-6 (83611PBZ3) rated 'CC/RR6v;
  -- class M-7 (83611PCA7) rated 'C/RR6v;
  -- class M-8 (83611PCB5) rated 'D/RR6';
  -- class M-9 (83611PCC3) rated 'D/RR6';
  -- class M-10 (83611PCD1) rated 'D/RR6';
  -- class B-1 (83611PCE9) rated 'D/RR6'.

Wachovia Bank, NA 2005-SD1

  -- class A (CUSIP: 92977XAA1) rated 'AAA/LS3', Outlook Negative;
  -- class M-1 (92977XAD5) rated 'AA/LS5', Outlook Negative;
  -- class M-2 (92977XAE3) rated 'AA/LS5', Outlook Negative;
  -- class M-3 (92977XAF0) rated 'BBB/LS5', Outlook Negative;
  -- class B-1 (92977XAB9) rated 'BBB/LS5', Outlook Negative;
  -- class B-2 (92977XAC7) rated 'BBB/LS5', Outlook Negative.

The ratings assigned by Fitch are based on the documents and
information provided to us by the issuer and other parties and are
subject to receipt of final closing documents.  In issuing and
maintaining its ratings, Fitch relies on factual information it
receives from issuers and underwriters and from other sources
Fitch believes to be credible.  Fitch conducts a reasonable
investigation of the factual information relied upon by it in
accordance with its ratings methodology, and obtains reasonable
verification of that information from independent sources, to the
extent such sources are available for a given security or in a
given jurisdiction.

The manner of Fitch's factual investigation and the scope of the
third-party verification it obtains will vary depending on the
nature of the rated security and its issuer, the requirements and
practices in the jurisdiction in which the rated security is
offered and sold and/or the issuer is located, the availability
and nature of relevant public information, access to the
management of the issuer and its advisers, the availability of
pre-existing third-party verifications such as audit reports,
agreed-upon procedures letters, appraisals, actuarial reports,
engineering reports, legal opinions and other reports provided by
third parties, the availability of independent and competent
third-party verification sources with respect to the particular
security or in the particular jurisdiction of the issuer, and a
variety of other factors.

Users of Fitch's ratings should understand that neither an
enhanced factual investigation nor any third-party verification
can ensure that all of the information Fitch relies on in
connection with a rating will be accurate and complete.
Ultimately, the issuer and its advisers are responsible for the
accuracy of the information they provide to Fitch and to the
market in offering documents and other reports.  In issuing its
ratings Fitch must rely on the work of experts, including
independent auditors with respect to financial statements and
attorneys with respect to legal and tax matters.  Further, ratings
are inherently forward-looking and embody assumptions and
predictions about future events that by their nature cannot be
verified as facts.  As a result, despite any verification of
current facts, ratings can be affected by future events or
conditions that were not anticipated at the time a rating was
issued or affirmed.


HSPI DIVERSIFIED: Moody's Junks Ratings on Class S Notes
--------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of one class of notes issued by HSPI Diversified CDO Fund
I, Ltd.  The notes affected by the rating action are:

* US$22,900,000 Class S Senior Secured Floating Rate Notes due
  2014 Notes (current balance of $19,061,334), Downgraded to Caa2;
  previously on Dec 24, 2009 Downgraded to B3.

HSPI Diversified CDO Fund I is a collateralized debt obligation
issuance backed by a portfolio of collateralized loan obligations
and collateralized debt obligations.

According to Moody's, the rating downgrade action is the result of
the continuous 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 the July 2010 trustee report, approximately
$343 million of securities were classified as defaulted and the
reported WARF was 2759.  $14 million of securities are on watch
for downgrade, $18 million of securities have been downgraded
since the beginning of the year, and write-downs have been
continuing as well.  In addition, the Trustee reports that the
transaction is currently failing all of its principal and interest
coverage tests and those tests have been deteriorating since last
rating action in December 2009.  The Class S Senior Notes have not
received any scheduled principal payments since August 2008.

The transaction experienced an Event of Default as reported by the
Trustee on May 12, 2008.

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.

Moody's continues to monitor this transaction using primarily the
methodologies below:

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

  -- Moody's Approach to Rating Structured Finance Securities in
     Default (November 2009)

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


INLAND EMPIRE: Fitch Affirms Ratings on Various 2007 Bonds
----------------------------------------------------------
Fitch Ratings affirms five and downgrades two classes from Inland
Empire Tobacco Securitization Corporation Series 2007:

Current interest turbo term bonds:

  -- $55,150,000 due June 1, 2021 affirmed at 'BB'; Outlook
     Negative;

  -- $32,500,000 due June 1, 2021 affirmed at 'BB'; Outlook
     Negative.

Convertible capital appreciation turbo term bond:

  -- $53,757,703 due June 1, 2026 affirmed at 'B'; Outlook
     Negative.

Capital appreciation bonds:

  -- 2007C-1 downgraded to 'B' from 'B+'; Outlook Negative;
  -- 2007C-2 downgraded to 'B' from 'B+'; Outlook Negative;
  -- 2007D affirmed at 'B'; Outlook Negative;
  -- 2007E affirmed at 'B-'; Outlook Negative.

The various actions are based on the Structured Finance Criteria
'Global Structured Finance Rating Criteria' published Sept. 30,
2009 and the level of stress each class is able to withstand as
indicated by Fitch's breakeven cash flow model.  The model
indicates, for each class of bonds, the level of the annual Master
Settlement Agreement payment percent change the trust would be
able to sustain and still pay the bond in full by the legal final
date.  The base case 'B' corresponds to a 1% increase in the MSA
payment received by the trust every year.  The 'BBB' category
corresponds to an annual MSA payment decline of between 0.3% to
2.5%.  The cash flow model accounts for the amount of the MSA
payment that the transaction has received in 2010, the capital
structure, the reserve account, and the bonds' legal final dates.

The bond payments are also tied to the tobacco companies making
MSA payments.  Tobacco settlement bonds can be rated up to 'BBB+'
based on Fitch's view of the whole tobacco industry and the
executory nature of the MSA.  In the event of a bankruptcy of a
tobacco company, Fitch believes there is an incentive for the
company to continue to make payments under the MSA.

Fitch also accounted for the highly speculative nature of this
transaction tied to the Riverside county's share of California's
population that is adjusted every 10 years based on the Census,
(the next adjustment is in 2011).  Longer-term bonds are exposed
to more uncertainty as they are subject to more population share
adjustments.  The 2007C-1 and 2007C-2 CABs are being downgraded to
'B' from 'B+', as they continue to be come under stress from the
reduced cash flow amount, and the Outlook for all of the bonds
remains Negative as a result of the concern that this stress will
continue.


IXIS REAL: Moody's Downgrades Ratings on 10 RMBS Tranches
---------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 10
tranches and confirmed the ratings of 8 tranches from six RMBS
transactions issued by IXIS.  The collateral backing these deals
primarily consists of first-lien, fixed and adjustable-rate
subprime residential mortgages.

The actions are a result of the continued performance
deterioration in Subprime pools in conjunction with home price and
unemployment conditions that remain under duress.  The actions
reflect Moody's updated loss expectations on subprime pools issued
from 2005 to 2007.

To assess the rating implications of the updated loss levels on
subprime 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.

Complete rating actions are:

Issuer: IXIS Real Estate Capital Trust 2005-HE4

  -- Cl. A-3, Confirmed at A2; previously on Jan. 13, 2010 A2
     Placed Under Review for Possible Downgrade

  -- Cl. M-1, Downgraded to B2; previously on Jan. 13, 2010 Ba3
     Placed Under Review for Possible Downgrade

  -- Cl. M-2, Downgraded to C; previously on Jan. 13, 2010 Caa2
     Placed Under Review for Possible Downgrade

Issuer: IXIS Real Estate Capital Trust 2006-HE1

  -- Cl. A-3, Downgraded to Caa2; previously on Jan. 13, 2010 Ba3
     Placed Under Review for Possible Downgrade

  -- Cl. A-4, Downgraded to Ca; previously on Jan. 13, 2010 Caa2
     Placed Under Review for Possible Downgrade

Issuer: IXIS Real Estate Capital Trust 2006-HE2

  -- Cl. A-3, Downgraded to Ca; previously on Jan. 13, 2010 Caa3
     Placed Under Review for Possible Downgrade

  -- Cl. A-4, Confirmed at Ca; previously on Jan. 13, 2010 Ca
     Placed Under Review for Possible Downgrade

Issuer: IXIS Real Estate Capital Trust 2006-HE3

  -- Cl. A-2, Downgraded to Caa2; previously on Jan. 13, 2010 Ba3
     Placed Under Review for Possible Downgrade

  -- Cl. A-3, Downgraded to Ca; previously on Jan. 13, 2010 Caa3
     Placed Under Review for Possible Downgrade

  -- Cl. A-4, Downgraded to Ca; previously on Jan. 13, 2010 Caa3
     Placed Under Review for Possible Downgrade

Issuer: IXIS Real Estate Capital Trust 2007-HE1

  -- Cl. A-1, Downgraded to Ca; previously on Jan. 13, 2010 B3
     Placed Under Review for Possible Downgrade

  -- Cl. A-2, Confirmed at Ca; previously on Jan. 13, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. A-3, Confirmed at Ca; previously on Jan. 13, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. A-4, Confirmed at Ca; previously on Jan. 13, 2010 Ca
     Placed Under Review for Possible Downgrade

Issuer: Natixis Real Estate Capital Trust 2007-HE2

  -- Cl. A-1, Downgraded to Ca; previously on Jan. 13, 2010 Caa2
     Placed Under Review for Possible Downgrade

  -- Cl. A-2, Confirmed at Ca; previously on Jan. 13, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. A-3, Confirmed at Ca; previously on Jan. 13, 2010 Ca
     Placed Under Review for Possible Downgrade

  -- Cl. A-4, Confirmed at Ca; previously on Jan. 13, 2010 Ca
     Placed Under Review for Possible Downgrade


JP MORGAN: Moody's Affirms Ratings on Seven Pooled Classes
----------------------------------------------------------
Moody's Investors Service affirmed the ratings of seven pooled
classes and downgraded five pooled classes and one non-pooled or
rake class of JP Morgan Chase Commercial Mortgage Securities
Corp., Commercial Mortgage Pass-Through Certificates, Series 2006-
FL1.  The downgrades reflect worse than expected performance,
outstanding interest shortfalls and the pending maturity of five
loans over the course of next six months in a challenged
refinancing market.  These negative factors are partially offset
by pay downs from the amortization of four loans (61% of the trust
balance).  The Holyoke Mall, Crossgate Mall, Independence Mall and
Champlain Mall loans feature amortization schedules of between 20
and 30 years.  The rating action is a result of Moody's on-going
surveillance of commercial mortgage backed securities
transactions.

As of the July 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 3% to
$852 million from $874 million at last review.  The certificates
are collateralized by nine loans ranging in size from less than 1%
to 29% of the trust balance.  Principal is currently paid to the
certificate holders on a modified pro rata basis.  The pool has a
heavy concentrated of regional malls with a common sponsor, Robert
J. Congel (71% of trust balance).  The trust has not realized any
losses since securitization.  Currently, two loans (7% of the
trust balance) are in special servicing including one that will be
returned to master servicer (6% of trust balance) as of August
2010.  Outstanding interest shortfalls total $46,652.

The Holyoke Mall Loan ($243 million including a rake bond
totaling $45 million -- 29% of the trust balance) is secured by a
1.4 million square foot regional mall located in Holyoke, MS.
Class HM1 is a rake class secured solely by the $45 million trust
junior component of this loan.  This loan amortizes on a 25-year
schedule and its current maturity date is February 9, 2011.  The
borrower has two additional 12-month extension options.  Mall shop
occupancy was 95% as of March 2010 and 2009 in-line sales were
$458 per square foot.  Although the top revenue line has been
stable over the last few years, expense items appear to be
increasing at a faster pace negatively impacting the bottom line.
The property's net operating income for 2009 was approximately
$24 million down from 2008 NOI of $28 million.  Moody's 2010
review NOI is $23 million.  The loan's sponsors are Robert J.
Congel and Woodchuck Hill Associates.  Moody's current underlying
rating is Ba1.

The Crossgate Mall Loan ($183 million - 22% of the trust balance)
is secured by a 1.2 MSF regional mall located in Albany, NY.  This
loan amortizes on a 30-year schedule and its current maturity date
is June 9, 2011.  The borrower has one additional 12-month
extension option remaining.  One anchor pad space (143,676 SF) is
dark.  Mall shop occupancy was 76% as of March 2010 and 2009 in-
line sales were $446 PSF.  The property's net operating income for
2009 was approximately $26 million down slightly from 2008 NOI of
$27 million.  Moody's 2010 review NOI is $24 million.  The loan's
sponsors are Robert J. Congel and Madeira Associates.  Moody's
current underlying rating is Baa3.

The DRA Portfolio Loan ($165 million -- 21% of the the trust
balance) is secured by 27 office buildings located in Atlanta, GA,
Houston, TX and Orlando, FL.  The Class A-B properties, which were
built or renovated between 1971 and 2000, contain 2.8 MSF of net
rentable area.  There is additional debt in the form of a
$110 million non-trust junior component and a $36 million
mezzanine loan.  The portfolio's occupancy was 84% as of year-end
2009 and the NOI for 2009 was approximately $26 million down from
2008 NOI of $30 million.  The loan sponsors are DRA Advisors, LLC
and Colonial Properties Trust.  The loan is interest-only during
the loan term and final maturity date is October 9, 2010.  There
are no more extension options available.  Moody's current
underlying rating is B2.

In addition to the DRA Portfolio Loan, there are three loans that
have final maturity dates within the next six months; all are
current.  They are the Orchard Supply Hardware (8% of trust
balance), Salmon Run Mall (6% of trust balance that will be
returned to master servicer as of August 2010) and Brookhollow
Central (3% of trust balance) loans.  Moody's anticipate that some
of these loans will be transferred to special servicing in the
near future.

The Centerpoint loan ($6 million -- 1% of the trust balance) was
transferred to special servicing on January 29, 2010 due to
imminent default.  The final maturity date is August 7, 2010.  The
combined $130.5 million loan was divided into two pari passu notes
consisting of fixed rate A-1 note with an original balance of
$117.45 million (securitized in JPMC 2006-CIBC14 transaction) and
a floating rate A-2 note with an original principal balance of
$13.05 million.  The A-2 note was included in this transaction.
This loan was originally secured by 16 industrial properties in
the Chicago metropolitan statistical area.  Since then, two
properties were released and their proceeds were used to pay down
the A-2 note per the loan documents.  The current principal
balance for the A-2 note is $6,065,000 and the combined
outstanding principal balance for the total loan is $123,515,000.
The sponsor for this loan is CenterPoint Properties Trust and JF
US Industrial Trust.  The portfolio's NOI has been relatively
stable since securitization, and based on the updated appraised
value ($148.45 million) the trust is not expected to incur
principal losses at this time.  Midland Loan Services, Inc, is the
special servicer for this loan.

Moody's loan to value ratio for the pooled trust balance is 79%
compared to 70% at last review.  Moody's stressed debt service
coverage ratio for the pooled trust balance is 1.28X compared to
1.47X at last review.  Although these two credit metrics have
deteriorated since Moody's last review, Moody's believe the senior
classes warrant an affirmation due to their low loan exposure per
square foot and continued deleveraging from amortization.

Moody's rating action is:

  -- Class A1B, $318,739,169, affirmed at Aaa (sf); previously on
     March 22, 2006 assigned Aaa (sf)

  -- Class A-2, $279,894,000, affirmed at Aaa (sf); previously on
     March 22, 2006 assigned Aaa (sf)

  -- Class B, $40,552,699, affirmed at Aaa (sf); previously on
     November 14, 2007 upgraded to Aaa (sf) from Aa1 (sf)

  -- Class C, $34,431,374, affirmed at Aa2 (sf); previously on
     March 11, 2009 downgraded Aa2 (sf) from Aa1 (sf)

  -- Class D, $19,894,505, affirmed at Aa3 (sf); previously on
     March 11, 2009 downgraded to Aa3 (sf) from Aa2 (sf)

  -- Class E, $19,128,453, affirmed at A2 (sf); previously on
     March 11, 2009 downgraded to A2 (sf) from A1 (sf)

  -- Class F, $15,302,920, affirmed at A3 (sf); previously on
     March 11, 2009 downgraded to A3 (sf) from A2 (sf)

  -- Class G, $16,068,184, downgraded to Baa2 (sf) from Baa1 (sf);
     previously on March 11, 2009 downgraded to Baa1 (sf) from A3
     (sf)

  -- Class H, $19,128,453, downgraded to Baa3 (sf) from Baa2 (sf);
     previously on March 11, 2009 downgraded to Baa2 (sf) from
     Baa1 (sf)

  -- Class J, $16,068,184, downgraded to Ba3 (sf) from Baa3 (sf);
     previously on March 11, 2009 downgraded to Baa3 (sf) from
     Baa2 (sf)

  -- Class K, $18,363,189, downgraded to B3 (sf) from Ba1 (sf);
     previously on March 11, 2009 downgraded to Ba1 (sf) from Baa3
     (sf)

  -- Class L, $9,182,553, downgraded to Caa2 (sf) from Ba2 (sf);
     previously on March 11, 2009 downgraded to Ba2 (sf) from Ba1
     (sf)

  -- Class HM1, $44,871,909, downgraded to B2 (sf) from Ba2 (sf);
     previously on March 11, 2009 downgraded to Ba2 (sf) from Baa3
     (sf)


JP MORGAN: Moody's Reviews Ratings on 11 Series 2008-C2 Certs.
--------------------------------------------------------------
Moody's Investors Service placed 11 classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp., Commercial Mortgage Pass-
Through Certificates, Series 2008-C2 on review for possible
downgrade due to higher expected losses for the pool resulting
from realized and anticipated losses from loans in special
servicing and interest shortfalls.

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

As of the July 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 3% to $1.1 billion
from $1.2 billion at securitization.  The Certificates are
collateralized by 78 mortgage loans ranging in size from less than
1% to 11% of the pool, with the top ten loans representing 54% of
the pool.  No loans have defeased.  Two loans, representing 3% of
the pool, have investment grade underlying ratings.

Twenty-four loans, representing 25% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (formerly Commercial Mortgage Securities
Association) monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

One loan has been liquidated from the pool resulting in a
$11.0 million realized loss (45% loss severity).  Five loans,
representing 21% of the pool, are currently in special servicing.
The largest specially serviced loan is The Promenade Shops at Dos
Lagos Loan ($125.2 million -- 11.1%), which is secured by a
350,000 square foot entertainment lifestyle center located in
Corona, California.  The center was 95% leased at securitization,
but has experienced significant tenant issues due to the downturn
in the economy.  The loan was transferred to special servicing in
November 2008 due to imminent default and is now real estate
owned.  The property was appraised at $169.7 million at
securitization.  A January 2010 appraisal valued the property at
$28.5 million, leading the master servicer to recognize a
$108.1 million appraisal reduction in May 2010.

The second largest specially serviced loan is the Westin Portfolio
Loan ($104.0 million -- 9.2%), which represents a pari passu
interest in a $209.0 million first mortgage loan.  The loan is
secured by a 487-unit full service hotel located in Tucson,
Arizona and a 412-unit full service hotel located in Hilton Head,
South Carolina.  The loan was transferred to special servicing in
October 2008 due to imminent default and is now 90+ days
delinquent.  The properties were appraised at $303.8 million at
securitization.  A September 2009 appraisal valued the properties
at $142.0 million.  The special servicer recognized a
$43.7 million appraisal reduction in August 2009.  The remaining
specially serviced loans are secured by a retail, self storage and
office property.

Based on the most recent remittance statement, Classes A-J through
NR have experienced cumulative interest shortfalls totaling
$9.9 million.  Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced loans.  Interest shortfalls are caused by
special servicing fees, including workout and liquidation fees,
appraisal subordinate entitlement reductions and extraordinary
trust expenses.

Moody's rating action is:

  -- Class A-1A, $64,352,885, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 05/29/2008

  -- Class A-4, $354,554,000, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 05/29/2008

  -- Class A-4FL, $145,000,000, currently rated Aaa, on review for
     possible downgrade; previously assigned at Aaa on 05/29/2008

  -- Class A-M, $116,589,000, currently rated Aa3, on review for
     possible downgrade; previously downgraded to Aa3 from Aaa on
     07/31/2009

  -- Class A-J, $61,209,000, currently rated Ba1, on review for
     possible downgrade; previously downgraded to Ba1 from A2 on
     7/31/2009

  -- Class B, $14,574,000, currently rated B1, on review for
     possible downgrade; previously downgraded to B1 from A3 on
     7/31/2009

  -- Class C, $14,574,000, currently rated B3, on review for
     possible downgrade; previously downgraded to B3 from Baa1 on
     7/31/2009

  -- Class D, $10,201,000, currently rated Ca, on review for
     possible downgrade; previously downgraded to Ca from Baa2 on
     7/31/2009

  -- Class E, $10,202,000, currently rated Ca, on review for
     possible downgrade; previously downgraded to Ca from Baa3 on
     7/31/2009

  -- Class F, $13,116,000, currently rated Ca, on review for
     possible downgrade; previously downgraded to Ca from Ba1 on
     7/31/2009

  -- Class G, $11,659,000, currently rated Ca, on review for
     possible downgrade; previously downgraded to Ca from Ba3 on
     7/31/2009


JP MORGAN: Moody's Reviews Ratings on 27 2006-LDP9 Certificates
---------------------------------------------------------------
Moody's Investors Service placed 27 classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp. Commercial Mortgage Pass-
Through Certificates Series 2006-LDP9 on review for possible
downgrade due to higher expected losses for the pool resulting
from realized and anticipated losses from specially serviced and
highly leveraged watchlisted loans and concerns about refinance
risk associated with loans approaching maturity in an adverse
environment.  Twenty-one loans, representing 14% of the pool,
mature within the next 24 months.

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

As of the July 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 2% to
$4.8 billion from $4.9 billion at securitization.  The
Certificates are collateralized by 244 mortgage loans ranging in
size from less than 1% to 8% of the pool, with the top 10 non-
defeased loans representing 42% of the pool.

Sixty-six loans, representing 36% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (formerly Commercial Mortgage Securities
Association) monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.  The largest watchlisted loan is the Belnord Loan
($375.0 million -- 7.9% of the pool), which is secured by a
multifamily property located in Manhattan, New York.  The
borrower's plans to significantly increase the property's revenues
by converting rent controlled/stabilized units to market rate
units has not progressed as anticipated.  Performance has been
further impacted by increased operating expenses.  The loan is on
the watchlist due to a low debt service ratio.

Eight loans have been liquidated from the pool since
securitization, resulting in an aggregate $34.7 million loss (90%
loss severity on average).  Currently 19 loans, representing 4% of
the pool, are in special servicing.  The largest specially
serviced loan is the Tucson Portfolio Loan ($29.6 million -- 0.6%
of the pool), which is secured by five multifamily properties,
totaling 881 units, located in Tucson, Arizona.  The loan was
transferred to special servicing in April 2009 due to monetary
default and is now in foreclosure.  The remaining 14 loans are
secured by a mix of multifamily, retail, office, hospitality and
mixed use properties.

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

Moody's rating action is:

  -- Class A-3, $1,652,984,000, currently rated Aaa, on review for
     possible downgrade; previously assigned to Aaa on 1/22/2007

  -- Class A-3SFL, $145,282,000, currently rated Aaa, on review
     for possible downgrade; previously assigned to Aaa on
     1/22/2007

  -- Class A-1A, $687,212,395, currently rated Aaa, on review for
     possible downgrade; previously assigned to Aaa on 1/22/2007

  -- Class A-M, $363,993,000, currently rated Aaa, on review for
     possible downgrade; previously assigned to Aaa on 1/22/2007

  -- Class A-MS, $121,432,000, currently rated Aaa, on review for
     possible downgrade; previously assigned to Aaa on 1/22/2007

  -- Class A-J, $318,494,000, currently rated A2, on review for
     possible downgrade; previously downgraded to A2 from Aaa on
     2/11/2009

  -- Class A-JS, $106,253,000, currently rated A2, on review for
     possible downgrade; previously downgraded to A2 from Aaa on
     2/11/2009

  -- Class B, $72,799,000, currently rated Baa1, on review for
     possible downgrade; previously downgraded to Baa1 from Aa2on
     2/11/2009

  -- Class B-S, $24,287,000, currently rated Baa1, on review for
     possible downgrade; previously downgraded to Baa1 from Aa2 on
     2/11/2009

  -- Class C, $22,750,000, currently rated Baa2, on review for
     possible downgrade; previously downgraded to Baa2 from Aa3 on
     2/11/2009

  -- Class C-S, $7,589,000, currently rated Baa2, on review for
     possible downgrade; previously downgraded to Baa2 from Aa3 on
     2/11/2009

  -- Class D, $50,049,000, currently rated Ba1, on review for
     possible downgrade; previously downgraded to Ba1 from A2on
     2/11/2009

  -- Class D-S, $16,697,000, currently rated Ba1, on review for
     possible downgrade; previously downgraded to Ba1 from A2 on
     2/11/2009

  -- Class E, $40,949,000, currently rated Ba2, on review for
     possible downgrade; previously downgraded to Ba2 from A3 on
     2/11/2009

  -- Class E-S, $13,661,000, currently rated Ba2, on review for
     possible downgrade; previously downgraded to Ba2 from A3 on
     2/11/2009

  -- Class F, $40,949,000, currently rated Ba3, on review for
     possible downgrade; previously downgraded to Ba3 from Baa1 on
     2/11/2009

  -- Class F-S, $13,661,000, currently rated Ba3, on review for
     possible downgrade; previously downgraded to Ba3 from Baa1 on
     2/11/2009

  -- Class G, $36,399,000, currently rated B1, on review for
     possible downgrade; previously downgraded to B1 from Baa2 on
     2/11/2009

  -- Class G-S, $12,144,000, currently rated B1, on review for
     possible downgrade; previously downgraded to B1 from Baa2 on
     2/11/2009

  -- Class H, $45,500,000, currently rated B3, on review for
     possible downgrade; previously downgraded to B3 from Baa3 on
     2/11/2009

  -- Class H-S, $15,179,000, currently rated B3, on review for
     possible downgrade; previously downgraded to B3 from Baa3 on
     2/11/2009

  -- Class J, $18,203,000, currently rated Caa1, on review for
     possible downgrade; previously downgraded to Caa1 from Ba1 on
     2/11/2009

  -- Class K, $18,204,000, currently rated Caa1, on review for
     possible downgrade; previously downgraded to Caa1 from Ba2 on
     2/11/2009

  -- Class L, $12,135,000, currently rated Caa2, on review for
     possible downgrade; previously downgraded to Caa2 from Ba3 on
     2/11/2009

  -- Class M, $12,136,000, currently rated Caa2, on review for
     possible downgrade; previously downgraded to Caa2 from B1 on
     2/11/2009

  -- Class N, $6,068,000, currently rated Caa3, on review for
     possible downgrade; previously downgraded to Caa3 from B2 on
     2/11/2009

  -- Class P, $12,135,000, currently rated Caa3, on review for
     possible downgrade; previously downgraded to Caa3 from B3 on
     2/11/2009


KINGSLAND V: 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 Kingsland V, Ltd.:

  -- US$295,975,000 Class A-1 Senior Secured Floating Rate Notes
     Due 2021 (current balance of $292,288,115), Upgraded to Aa3
     (sf); previously on September 29, 2009 Downgraded to A1 (sf);

  -- US$60,000,000 Class A-2R Secured Revolving Floating Rate
     Notes Due 2021 (current balance of $59,101,557), Upgraded to
     Aa1 (sf); previously on September 29, 2009 Downgraded to Aa2
     (sf);

  -- US$12,125,000 Class A-2B Senior Secured Floating Rate Notes
     Due 2021, Upgraded to A2 (sf); previously on September 29,
     2009 Downgraded to A3 (sf);

  -- US$22,900,000 Class B Senior Secured Floating Rate Notes Due
     2021, Upgraded to Baa2 (sf); previously on September 29, 2009
     Downgraded to Baa3 (sf);

  -- US$25,000,000 Class C Senior Secured Deferrable Floating Rate
     Notes Due 2021, Upgraded to Ba2 (sf); previously on September
     29, 2009 Downgraded to Ba3 (sf);

  -- US$13,000,000 Class D-1 Senior Secured Deferrable Floating
     Rate Notes Due 2021, Upgraded to Caa1 (sf); previously on
     September 29, 2009 Downgraded to Caa2 (sf);

  -- US$5,000,000 Class D-2 Senior Secured Deferrable Fixed Rate
     Notes Due 2021, Upgraded to Caa1 (sf); previously on
     September 29, 2009 Downgraded to Caa2 (sf);

  -- US$15,330,000 Composite Notes Due 2021 (current rated balance
     of $13,033,269), Upgraded to B2 (sf); previously on
     September 29, 2009 Downgraded to Caa1 (sf).

According to Moody's, the rating actions taken on the notes result
primarily from improvement in the credit quality of the underlying
portfolio and increases in the overcollateralization ratios since
the last rating action in September 2009.

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 July 4, 2010, the weighted average rating
factor was 2241 as compared to 2650 in September 2009 and in
compliance with the trigger level of 2338.  Based on the same
report, securities rated Caa1 or lower make up approximately 4.75%
of the underlying portfolio versus 11.55% in September 2009.
Additionally, defaulted assets have decreased from $15.9 million
in September 2009 to $2.9 million in July 2010.

Additionally, the overcollateralization ratios have increased
since the last rating action in September 2009 and are currently
all in compliance.  The Class A/B, Class C, Class D and Class E
Overcollateralization Test ratios are reported at 119.17%,
111.93%, 107.24%, and 103.64%, respectively versus September 2009
levels of 116.14%, 107.90%, 102.65%, and 98.68%.  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.

Kingsland V, Ltd., issued on May 24, 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.


LB-UBS COMMERCIAL: Moody's Affirms Ratings on 2005-C1 Certs.
------------------------------------------------------------
Moody's Investors Service affirmed the ratings of seven classes
and downgraded 12 classes of LB-UBS Commercial Mortgage Trust
2005-C1, Commercial Mortgage Pass-Through Certificates, Series
2005-C1.  The downgrades are due to higher expected losses for the
pool resulting from realized and anticipated losses from specially
serviced and highly leveraged watchlisted loans and increased
credit quality dispersion.

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

On July 21, 2010, Moody's placed 12 classes of this transaction on
review for possible downgrade.  This action concludes Moody's
review of this transaction.  The rating action is the result of
Moody's on-going surveillance of commercial mortgage backed
securities transactions.

As of the July 16, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 22%
to $1.2 billion from $1.5 billion at securitization.  The
Certificates are collateralized by 76 mortgage loans ranging in
size from less than 1% to 13% of the pool, with the top 10 non-
defeased loans representing 65% of the pool.  The pool includes
four loans with investment grade underlying ratings, representing
31% of the pool.

Twenty loans, representing 17% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (formerly Commercial Mortgage Securities
Association) monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Four loans have been liquidated from the pool since
securitization, resulting in an aggregate $6.6 million loss (30%
loss severity on average).  Currently seven loans, representing 7%
of the pool, are in special servicing.  The largest specially
serviced loan is the Atlantic Building Loan ($28.2 million -- 2.4%
of the pool), which is secured by a 315,993 square foot office
building located in Philadelphia, Pennsylvania.  The loan was
transferred to special servicing in April 2010 due to monetary
default.  The property was 74% leased as of January 2010 and
performance has declined since securitization.  All of the
remaining six specially serviced loans are real estate owned or in
the process of foreclosure.  Moody's estimates an aggregate $29.1
million loss for the specially serviced loans (33% expected loss
on average).

In addition to recognizing losses from specially serviced loans,
Moody's has assumed a high default probability on seven loans,
representing 5% of the pool, due to refinancing risk or
performance issue.  Moody's estimates a $15.9 million aggregate
expected loss for these troubled loans (28% expected loss on
average based on overall 38% loss severity and 75% overall default
probability).  Moody's rating action recognizes potential
uncertainty around the timing and magnitude of loss from these
troubled loans.

Moody's was provided with full-year 2008 and partial or full-year
2009 operating results for 99% and 88% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV ratio is 97% compared to 96% at Moody's prior review.
Although the overall LTV is relatively unchanged, the pool has
experienced increased credit quality dispersion.  Based on Moody's
analysis, 50% of the conduit pool has an LTV greater than 100%
compared to 37% at last review.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCR are 1.46X and 1.03X, respectively, compared to
1.45X and 1.21X at last review.  Moody's actual DSCR is based on
Moody's net cash flow and the loan's actual debt service.  Moody's
stressed DSCR is based on Moody's NCF and a 9.25% stressed rate
applied to the loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple-notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 15 compared to 20 at last review.

The largest loan with an underlying rating is the 11 West 42nd
Street Loan ($155.7 million -- 13.0% of the pool), which is
secured by a 877,138 SF Class A office building located in the
Grand Central submarket of New York City.  The property is also
encumbered by a $48.5 million mezzanine loan.  The largest tenants
include CIT (17% of the net rentable area; lease expiration
October 2021) and Empire Healthchoice (12% of the NRA; lease
expiration December 2015).  As of April 1, 2010 the property was
96% leased, essentially the same as at year end 2008.  The loan
was interest only for the first three years.  Moody's underlying
rating and stressed DSCR are Baa2 and 1.49X, respectively,
compared to Baa2 and 1.40X at last review.

The second largest loan with an underlying rating is the Mall Del
Norte Loan ($113.4 million -- 9.5% of the pool), which is secured
by the borrower's interest in a 1.2 million SF regional mall
(683,493 SF as collateral) located in Laredo, Texas.  The largest
tenants include Dillard's, Inc. (13% of the NRA; lease expiration
December 2035), Sears, Roebuck and Co (10% of the NRA; lease
expiration December 2035) and JC Penny Co. Inc. (10% of the NRA;
lease expiration December 2035).  As of March 30, 2010, the
property was 99% leased, the same as at year end 2008.  The loan
is interest only for its entire 10 year term.  Moody's underlying
rating and stressed DSCR are Baa3 and 1.36X, respectively,
compared to Baa3 and 1.37X at last review.

The third largest loan with an underlying rating is the IBM
Gaithersburg Loan ($46.4 million -- 3.9% of the pool), which is
secured by a 393,000 SF office building located in Gaithersburg,
Maryland.  The building is 100% leased to IBM Corporation (senior
unsecured rating A1; stable outlook) through March 2016 and
functions as a mission critical data center.  The loan is interest
only for its entire seven year term.  Moody's underlying rating
and stressed DSCR are A1 and 1.47X, respectively, compared to A1
and 1.48X at last review.

The fourth largest loan with an underlying rating is the United
States District Courthouse Loan ($15.7 million-- 1.3% of the
pool), which is secured by a 46,813 SF office building located in
El Centro, California.  The building is 100% leased to the US
Magistrate Courthouse through September 2019.  Moody's underlying
rating and stressed DSCR are Aaa and 1.49X, respectively, compared
to Aaa and 1.45X at last review.

The top three conduit loans represent 27% of the pool.  The
largest conduit loan is the 2100 Kalakaua Avenue Loan
($130.0 million -- 10.9% of the pool), which is secured by a
92,671 SF anchored retail shopping center located in Honolulu,
Hawaii.  The property is also encumbered by a $15.0 million
mezzanine loan.  The largest tenants include Gucci (20% of the
NRA; lease expiration November 2027), Chanel (20% of the NRA;
lease expiration October 2027) and Tiffany & Co. (12% of the NRA;
lease expiration October 2027).  The property was 85% leased as of
December 2009.  Moody's LTV and stressed DSCR are 81% and 1.06X,
respectively, compared to 84% and 1.03X at last review.

The second largest conduit loan is the Wilshire Rodeo Plaza
Portfolio Loan ($112.7 million -- 9.4% of the pool), which is
secured by a 208,145 SF office building and a 56,855 SF anchored
retail building located in Beverly Hills, California.  The largest
tenants include United Talent Agency (30% of the NRA; lease
expiration August 2017), UBS Financial Services (27% of the NRA;
lease expiration February 2015) and Merrill Lynch (14% of the NRA;
lease expiration February 2015).  The property was 97% leased as
of December 2009.  Moody's LTV and stressed DSCR are 111% and
0.83X, respectively, compared to 105% and 0.87X at last review.

The third largest conduit loan is the Macquarie DDR Portfolio Loan
($85.0 million -- 7.1% of the pool), which is secured by four
retail properties located in Texas, Colorado and South Carolina.
The four community centers contain approximately 1.9 million SF
(collateral is approximately 799,898 SF).  Approximately 136,715
SF of the portfolio is subject to ground leases.  Moody's LTV and
stressed DSCR are 102% and 0.93X, respectively, compared to 99%
and 0.94X at last review.

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

Moody's rating action is:

  -- Class A-2, $40,075,679, affirmed at Aaa; previously assigned
     Aaa on 2/10/2005

  -- Class X-CL, Notional, affirmed at Aaa; previously assigned
     Aaa on 2/10/2005

  -- Class X-CP, Notional, affirmed at Aaa; previously assigned
     Aaa on 2/10/2005

  -- Class A-3, $162,000,000, affirmed at Aaa; previously assigned
     Aaa on 2/10/2005

  -- Class A-AB, $51,319,749, affirmed at Aaa; previously assigned
     Aaa on 2/10/2005

  -- Class A-4, $531,842,000, affirmed at Aaa; previously assigned
     Aaa on 2/10/2005

  -- Class A-1A, $112,724,874, affirmed at Aaa; previously
     assigned Aaa on 2/10/2005

  -- Class A-J, $102,769,000, downgraded to Aa2 from Aaa,
     previously placed on review for possible downgrade on
     7/21/2010

  -- Class B, $26,704,000, downgraded to Aa3 from Aa1, previously
     placed on review for possible downgrade on 7/21/2010

  -- Class C, $26,704,000, downgraded to A2 from Aa2, previously
     placed on review for possible downgrade on 7/21/2010

  -- Class D, $19,073,000, downgraded to A3 from Aa3, previously
     placed on review for possible downgrade on 7/21/2010

  -- Class E, $24,796,000, downgraded to Baa2 from A2, previously
     placed on review for possible downgrade on 7/21/2010

  -- Class F, $15,259,000, downgraded to Baa3 from A3, previously
     placed on review for possible downgrade on 7/21/2010

  -- Class G, $17,167,000, downgraded to Ba3 from Baa1, previously
     placed on review for possible downgrade on 7/21/2010

  -- Class H, $17,166,000, downgraded to B3 from Baa2, previously
     placed on review for possible downgrade on 7/21/2010

  -- Class J, $22,889,000, downgraded to Caa3 from Ba1, previously
     placed on review for possible downgrade on 7/21/2010

  -- Class K, $5,717,000, downgraded to Ca from Ba2, previously
     placed on review for possible downgrade on 7/21/2010

  -- Class L, $7,623,000, downgraded to C from Ba3, previously
     placed on review for possible downgrade on 7/21/2010

  -- Class M, $3,811,000, downgraded to C from B1, previously
     placed on review for possible downgrade on 7/21/2010


LB-UBS COMMERCIAL: S&P Downgrades Ratings on Four 2000-C4 Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
classes of commercial mortgage-backed securities from LB-UBS
Commercial Mortgage Trust's series 2000-C4 and removed three of
them from CreditWatch with negative implications.  In addition,
S&P affirmed its ratings on three other classes from the same
transaction.

The downgrades primarily reflect S&P's analysis of interest
shortfalls that have impacted the trust.  As of the June 2010
remittance report, the trust had experienced current interest
shortfalls of $295,070 and had amassed cumulative interest
shortfalls in the aggregate amount of $5,786,002.  The downgrade
of class H to 'D' reflects recurring interest shortfalls primarily
due to appraisal subordinate entitlement reduction amounts and
special servicer fees.  S&P expects these interest shortfalls to
continue for the foreseeable future.

The downgrades of the other classes reflect a reduction of
available interest to the trust and the potential for these
classes to experience interest shortfalls in the future.  These
anticipated shortfalls will most likely be related to assets that
are currently specially serviced (50.5% of the pool) and assets
that S&P has determined to be credit-impaired (0.4%) and,
therefore, at increased risk of default and loss.

The current interest shortfalls primarily relate to four of the
13 assets with the special servicer, CWCapital Asset Management
LLC.  These four assets have appraisal reduction amounts in
effect totaling $8.3 million.  The current ASERs resulting from
the ARAs total $26,482.  In addition, the master servicer,
KeyBank Real Estate Capital, has made a nonrecoverable advance
declaration on one of the four assets (which has a total exposure
of $9.2 million, 7.6%), for which it is not advancing interest or
expenses.  S&P provide more details on this asset in the Credit
Considerations section.

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 rating on the class X
interest-only certificate based on its current criteria.

                      Credit Considerations

As of the July 2010 remittance report, 13 assets ($61.5 million,
50.5%) in the pool were with the special servicer, CWCapital.
The payment status of the specially serviced assets is: nine
are matured balloon loans ($35.6 million, 29.2%), one is real
estate owned (REO; $6.2 million, 5.1%), one is in foreclosure
($2.5 million, 2.0%), one is 90-plus-days delinquent
($10.9 million, 8.9%), and one is 30-days delinquent
($6.4 million, 5.3%).  Excluding the asset that the master
servicer determined to be nonrecoverable, $3.8 million in
total ARAs are in effect for three specially serviced assets.

The three largest specially serviced assets are:

The 111 Franklin Plaza loan, which has a total exposure of
$11.3 million (9.2%), is the largest loan in the pool and the
largest loan currently with the special servicer.  The loan is 90-
plus-days delinquent and is secured by a 138,801-sq.-ft.
office building in downtown Roanoke, Va.  The loan was transferred
to the special servicer on April 9, 2010, due to imminent monetary
default.  As of year-end 2009, the reported debt service coverage
(DSC) and occupancy were 1.02x and 86.9%, respectively, compared
with 1.24x and 90.0% at issuance.  Standard & Poor's anticipates a
minimal loss upon the eventual resolution of this asset.

The Clocktower Place Shopping Center loan, which has a total
exposure of $9.8 million (8.1%), is the second-largest loan in the
pool and the second-largest loan currently with the special
servicer.  The loan has a matured balloon status and is secured by
a 206,365-sq.-ft. anchored retail center built in 1987 in
Florissant, Mo., a suburb of St.  Louis.  The loan was transferred
to the special servicer on Feb. 19, 2010, due to imminent maturity
default.  The anchor tenant, Dierberg's Market (36% of net
rentable area {NRA}), vacated on Nov. 30, 2007, when its lease
expired.  T.J.  Maxx (13% of NRA) also vacated when its lease
expired on Jan. 31, 2008.  Two new tenants, Florissant Furniture
(12.6% of NRA) and Aldi (9.0% of NRA), took occupancy in late
2009.  As of year-end 2009, the reported DSC and occupancy were
0.37x and 67.4%, respectively, compared with 1.30x and 90.0% at
issuance.  Standard & Poor's anticipates a moderate loss upon the
eventual resolution of this asset.

The Western Select Properties loan ($7.6 million total exposure,
6.3%) is the fourth-largest loan in the pool and the third-largest
loan currently with the special servicer.  The loan has a matured
balloon status and is secured by a 1.5 million-sq.-ft. industrial
complex in Indianapolis, Ind.  The loan was transferred to the
special servicer on June 1, 2010, due to imminent maturity
default.  As of year-end 2009, the reported DSC and occupancy were
2.22x and 85.2%, respectively, compared with 1.34x and 90.0% at
issuance.

The master servicer, KeyBank, has declared future servicing
advances nonrecoverable on The Grapevine I and II Professional
Building asset ($9.2 million total exposure, 7.6%), the seventh-
largest asset in the pool and the sixth-largest asset with the
special servicer.  The loan was transferred to the special
servicer in August 2006 and is now REO.  The asset consists of a
58,860-sq.-ft. office building located in Grapevine, Texas.
KeyBank made a nonrecoverable advance declaration for this loan on
July 12, 2010.  KeyBank has declared $1.1 million of outstanding
advances to be nonrecoverable and will hold back approximately
$250,000 each month from trust cash flow for approximately five
months to reimburse itself for those advances.  Standard & Poor's
anticipates a significant loss upon the eventual resolution of
this asset.

The nine remaining specially serviced assets listed in the July
2010 remittance report ($27.1 million, 22.2%) have balances that
individually represent less than 5.6% of the total pool balance.
S&P estimated losses for five of these assets, resulting in a
weighted average loss severity of 32.6%.  Four of these assets
have matured balloon balances and one is in foreclosure.  Of the
remaining four assets, one was recently transferred to special
servicing, two have loan modifications that the special servicer
is reviewing, and one is expected to be returned to the master
servicer in the next few months.

In addition to the specially serviced assets, S&P determined one
loan ($454,243, 0.4%) to be credit-impaired.  The Oak Creek
Apartments loan is secured by a 32-unit multifamily property in
Baytown, Texas, constructed in 1959 and renovated in 1998.  As of
year-end 2009, the reported DSC was 0.59x, and occupancy as of
March 2010 was 50.0%, down from 1.30x and 93.8%, respectively, at
issuance.  As a result, S&P view this loan to be at an increased
risk of default and loss.

Excluding the two defeased loans and 13 specially serviced assets,
approximately 26.5% of the loans in the pool, by balance, mature
by July 2010.

                       Transaction Summary

As of the July 2010 remittance report, the collateral pool balance
was $121.7 million, which is 12.2% of the balance at issuance.
The pool includes 34 loans, down from 167 loans at issuance.  As
of the July 2010 remittance report, the master servicer, KeyBank,
had provided financial information for 100.0% of the nondefeased
loans in the pool, all of which was full-year 2008, interim-2009,
or full-year 2009 data.  S&P calculated a weighted average DSC of
1.09x for the pool based on the reported figures.

Ten loans ($30.5 million, 25.1%) are on the master servicer's
watchlist, including two of the top 10 loans.  Sixteen loans
($65.5 million, 53.8%) have a reported DSC below 1.10x, and 11 of
these loans ($40.5 million, 33.3%) have a reported DSC of less
than 1.00x.  To date, the pool has experienced principal losses
totaling $26.1 million on 14 assets.

                     Summary Of Top 10 Loans

The top 10 exposures have an aggregate outstanding balance of
$71.3 million (58.5%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.14x for the top 10 loans.
Six of the top 10 loans ($47.6 million, 39.1%) were with the
special servicer as of the July 2010 remittance report.  Two of
the top 10 loans ($9.9 million, 8.2%) appear on the master
servicer's watchlist, which S&P discuss in detail below.

The Towneplace Suites Sterling loan is the ninth-largest loan in
the pool and the largest loan on the master servicer's watchlist.
The loan has a trust balance of $5.5 million (4.5%) and is secured
by a 95-room limited-service hotel in Sterling, Va., built in
1998.  This loan appears on the watchlist due to low DSC.
Reported DSC for the trailing 12 months ended March 31, 2010, was
1.03x, down from 1.42x at issuance.

The Glenview Office Building loan is the 10th-largest loan in the
pool and the second-largest loan on the master servicer's
watchlist.  The loan has a trust balance of $4.5 million (3.7%)
and is secured by a 58,137-sq.-ft. office building in Wilmette,
Ill.  This loan appears on the watchlist due to imminent maturity
on July 11, 2010.  KeyBank reports that the borrower has indicated
that it is working on refinancing this loan.

According to KeyBank, the Moore Self-Storage loan, ($2.5 million,
2.1%), one of the loans on the servicer's watchlist, paid off in
full after the July remittance date.  The loan had a matured
balloon status and was secured by a 38,400-sq.-ft. self storage
facility in Staten Island, N.Y.

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

                         Rating Lowered

                 LB-UBS Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2000-C4

                     Rating
                     ------
         Class     To      From      Credit enhancement (%)
         -----     --      ----      ----------------------
         E         A-      AA+                        66.82

       Ratings Lowered And Removed From Creditwatch Negative

                 LB-UBS Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2000-C4

                     Rating
                     ------
         Class     To      From      Credit enhancement (%)
         -----     --      ----      ----------------------
         F         BB-     A/Watch Neg                52.46
         G         CCC+    BBB+/Watch Neg             42.20
         H         D       BB+/Watch Neg              23.73

                         Ratings Affirmed

                 LB-UBS Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2000-C4

           Class     Rating      Credit enhancement (%)
           -----     ------      ----------------------
           C         AAA                          83.23
           D         AAA                          72.98
           X         AAA                            N/A

                       N/A - Not applicable.


LNR CDO: Moody's Downgrades Ratings on Eight Classes of Notes
-------------------------------------------------------------
Moody's Investors Service downgraded eight classes of Notes issued
by LNR CDO 2003-1, Ltd., due to deterioration in the credit
quality of the underlying portfolio as measured by the weighted
average rating factor.  The rating action, which concludes Moody's
current review, is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation
transactions.

LNR CDO 2003-1, Ltd., is a static Re-Remic CRE CDO transaction
backed by a portfolio of commercial mortgage backed securities.
As of July 21, 2010, the aggregate Notes balance of the
transaction, including the Preferred Shares, has decreased to
$687.9 million from $762.7 million at issuance, due to
approximately $6.6 million in pay-downs to the Class A Notes and
$68.1 million of realized losses.

Eleven assets (approximately $31.9 million of par amount, 4.6% of
the pool balance) were listed as defaulted and another sixty-four
assets (approximately $311.5 million of par amount, 45.3% of the
pool balance) were listed as impaired securities as of July 21,
2010.  The deal passes all of its overcollateralization and
interest coverage tests.

Moody's has identified these parameters as key indicators of the
expected loss within CRE CDO transactions: WARF, weighted average
life, weighted average recovery rate, and Moody's asset
correlation.  WARF is a primary measure of the credit quality of a
CRE CDO pool.  Moody's have completed updated credit estimates for
the entire pool and the results will be reflected in a future
Trustee Report.  The bottom-dollar WARF is a measure of the
default probability within a collateral pool.  Moody's modeled a
bottom-dollar WARF of 4,506 compared to 3,573 at last review.

WAL acts to adjust the probability of default of the collateral
pool for time.  Moody's modeled to the actual WAL of 3.8 years
compared to 4.8 years at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool.  Moody's modeled the actual
WARR of 9.2% compared to 7.1% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 20.5% compared to 25.7% at last review.

Moody's review incorporated CDOROM v2.6, one of Moody's CDO rating
models, which was released on May 27, 2010.  The cash flow model,
CDOEdge v3.2, was used to analyze the cash flow waterfall and its
effect on the capital structure of the deal.  As always, Moody's
ratings are determined by a committee process that considers both
quantitative and qualitative factors.  Therefore, the rating
outcome may differ from the model output.

The rating actions are:

  -- Class A, Downgrade to Aa2 (sf); previously on January 30,
     2009 Downgraded to Aa1 (sf)

  -- Class B, Downgraded to Baa1 (sf); previously on January 30,
     2009 Downgraded to A1 (sf)

  -- Class C-FL, Downgraded to Baa3 (sf); previously on
     January 30, 2009 Downgraded to A3 (sf)

  -- Class C-FX, Downgraded to Baa3 (sf); previously on
     January 30, 2009 Downgraded to A3 (sf)

  -- Class D-FL, Downgraded to Ba3 (sf); previously on January 30,
     2009 Downgraded to Baa3 (sf)

  -- Class D-FX, Downgraded to Ba3 (sf); previously on January 30,
     2009 Downgraded to Baa3 (sf)

  -- Class E-FL, Downgraded to B3 (sf); previously on January 30,
     2009 Downgraded to Ba2 (sf)

  -- Class E-FX, Downgraded to B3 (sf); previously on January 30,
     2009 Downgraded to Ba2 (sf)

Moody's monitors transactions on both a monthly basis through a
review of the available Trustee Reports and a periodic basis
through a full review.  Moody's prior full review is summarized in
a press release dated January 30, 2009.


MANUFACTURED HOUSING: S&P Corrects Rating on Class A to 'CCC-'
--------------------------------------------------------------
Standard & Poor's Ratings Services corrected to 'CCC-' from 'A'
its long-term rating on the class A notes from Manufactured
Housing Contract Senior/Subordinate Pass-Through Certificates
Series 2001-2.

The corrected rating reflects Standard & Poor's underlying rating
('CCC-') on the class A note.  The class A note benefits from a
bond insurance policy issued by Ambac Assurance Corp. ('R').
Under S&P's criteria, the issue credit rating on a fully credit-
enhanced bond issue is the higher of (i) the rating on the credit
enhancer; and (ii) the SPUR on the class.

On June 24, 2009, July 28, 2009, and March 25, 2010, S&P lowered
its rating on Ambac, but, due to an error, did not
contemporaneously lower its long-term rating on the class A note
to reflect the higher of the rating on Ambac or the SPUR.

                    Long-Term Rating Corrected

         Manufactured Housing Contract Senior/Subordinate
             Pass-Through Certificates Series 2001-2

                                Rating
                                ------
                      Class   To       From
                      -----   --       ----
                      A       CCC-     A


MERRILL LYNCH: Fitch Affirms Ratings on 2004-MKB1 Securities
------------------------------------------------------------
Fitch Ratings has affirmed, assigned Loss Severity Ratings and
Rating Outlooks to Merrill Lynch Mortgage Trust commercial
mortgage securities, series 2004-MKB1:

  -- $87.1 million class A-2 at 'AAA/LS1'; Outlook Stable;
  -- $65 million class A-3 at 'AAA/LS1'; Outlook Stable;
  -- $169.7 million class A-4 at 'AAA/LS1'; Outlook Stable;
  -- $105.1 million class A-1A at 'AAA/LS1'; Outlook Stable;
  -- $27 million class B at 'AAA/LS3'; Outlook Stable;
  -- $11 million class C at 'AAA/LS4'; Outlook Stable;
  -- $25.7 million class D at 'AA/LS3'; Outlook Stable;
  -- $11 million class E at 'A+/LS4'; Outlook Stable;
  -- $13.5 million class F at 'A-/LS4; Outlook Stable.
  -- $12.3 million class G at 'BBB/LS4'; Outlook Stable;
  -- $11 million class H at 'BBB-/LS4'; Outlook Stable;
  -- $3.7 million class J at 'BB+/LS5'; Outlook Stable;
  -- $4.9 million class K at 'BB/LS5'; Outlook Stable;
  -- $4.9 million class L at 'BB-/LS5'; Outlook Negative;
  -- $4.9 million class M at 'B+/LS5'; Outlook Negative;
  -- $2.5 million class N at 'B/LS5'; Outlook Negative;
  -- $3.7 million class P at 'B-/LS5'; Outlook Negative.

Fitch withdraws the ratings on the interest-only classes XC and
XP.

Fitch does not rate the $9.8 million class Q.  Class A-1 has been
paid in full.

The affirmations are due to sufficient credit protection to offset
Fitch expected losses following Fitch's prospective review of
potential stresses and expected losses associated with specially
serviced assets.  Fitch expects losses of 1.8% of the remaining
pool balance, approximately $10.8 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 July 2010 distribution date, the pool's collateral
balance has paid down 41.6% to $572.5 million from $980 million at
issuance.  Thirteen of the remaining loans have defeased (29.8%).

As of July 2010, there are two specially serviced loans (3%).  The
largest specially serviced loan (1.8%), is secured by a 113,556
square foot office building located in Memphis, TN.  The loan
transferred to special servicing in April 2009 and the special
servicer foreclosed on the property in October 2009.  The special
servicer is currently marketing the property for sale.

The second largest specially serviced loan (1.1%) is secured by
228-unit multifamily property located in Tampa, FL.  The loan
transferred to special servicing in February 2009 and the borrower
filed bankruptcy a year later.  The special servicer working
through the bankruptcy court and recently voted against the
borrowers reorganization plan.

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
commercial mortgage backed securities, 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, fifteen loans are not expected to pay off at maturity
with three loans incurring a loss when compared to Fitch's
stressed value.


MERRILL LYNCH: Moody's Reviews Ratings on 2004-KEY2 Certificates
----------------------------------------------------------------
Moody's Investors Service placed 15 classes of Merrill Lynch
Mortgage Trust 2004-Key2, Commercial Mortgage Pass-Through
Certificates, Series 2004-KEY2 on review for possible downgrade
due to higher expected losses from the pool resulting from
realized and anticipated losses from specially serviced and poorly
performing loans as well as interest shortfalls.

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

As of the July 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 25% to
$838.4 million from $1.1 billion at securitization.  The
Certificates are collateralized by 107 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 36% of the pool.  Sixteen loans, representing 12% of
the pool, have defeased and are collateralized by U.S. Government
securities.

Twenty-eight loans, representing 22% of the pool, are on the
master servicer's watchlist.  The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the CRE Finance Council (formerly Commercial Mortgage Securities
Association) monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Four loans have been liquidated from the pool, resulting in a
$19.4 million aggregate loss (38% loss severity on average).
Currently ten loans, representing 7% of the pool, are in special
servicing.  The largest specially serviced loan is the 1200
Ashwood Loan ($14.7 million -- 1.8% of the pool), which is secured
by a 183,000 square foot office property located in Atlanta,
Georgia.  The property was 61% leased as of September 2009.
Foreclosure proceedings are underway.  The remaining eight loans
are secured by multifamily, hotel, office and industrial
properties.

As of the most recent remittance date, the transaction has
experienced unpaid accumulated interest shortfalls totaling $1.4
million affecting Classes D through Q.  Interest shortfalls are
caused by special servicing fees, appraisal reductions,
extraordinary trust expenses and loan modifications.  Moody's
expects that interest shortfalls may increase because of the
pool's exposure to specially serviced loans.

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

Moody's rating action is:

  -- Class A-1A, $182,184,269, currently rated Aaa, on review for
     possible downgrade; previously assigned Aaa on 10/25/2004

  -- Class A-4, $345,746,000, currently rated Aaa, on review for
     possible downgrade; previously assigned Aaa on 10/25/2004

  -- Class B, $26,474,000, currently rated Aa2, on review for
     possible downgrade; previously assigned Aa2 on 10/25/2004

  -- Class C, $8,361,000, currently rated Aa3, on review for
     possible downgrade; previously assigned Aa3 on 10/25/2004

  -- Class D, $22,295,000, currently rated A2, on review for
     possible downgrade; previously assigned A2 on 10/25/2004

  -- Class E, $12,540,000, currently rated A3, on review for
     possible downgrade; previously assigned A3 on 10/25/2004

  -- Class F, $15,328,000, currently rated Baa1, on review for
     possible downgrade; previously assigned Baa1 on 10/25/2004

  -- Class G, $11,147,000, currently rated Baa2, on review for
     possible downgrade; previously assigned Baa2 on 10/25/2004

  -- Class H, $15,328,000, currently rated Baa3, on review for
     possible downgrade; previously assigned Baa3 on 10/25/2004

  -- Class J, $6,967,000, currently rated Ba1, on review for
     possible downgrade; previously assigned Ba1 on 10/25/2004

  -- Class K, $5,573,000, currently rated Ba2, on review for
     possible downgrade; previously assigned Ba2 on 10/25/2004

  -- Class L, $4,181,000, currently rated Ba3, on review for
     possible downgrade; previously assigned Ba3 on 10/25/2004

  -- Class M, $2,786,000, currently rated B2, on review for
     possible downgrade; previously downgraded to B2 from B1 on
     9/18/2008

  -- Class N, $2,787,000, currently rated B3, on review for
     possible downgrade; previously downgraded to B3 from B2 on
     9/18/2008

  -- Class P, $2,912,949, currently rated Caa2, on review for
     possible downgrade; previously downgraded to Caa2 from B3 on
     9/18/2008


MKP CBO: Fitch Takes Rating Actions on Three Classes of Notes
-------------------------------------------------------------
Fitch Ratings has downgraded one and affirmed two classes of notes
issued by MKP CBO III, Ltd.

Since Fitch's last rating action in November 2009, approximately
26.2% of the portfolio has been downgraded.  Currently, 18.5% is
on Rating Watch Negative.  Defaulted assets as reported by the
trustee now total $31,319,773 (or 30.5%) of the portfolio compared
to $25,809,667 (or 23.2%) at last review.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  The default levels were then
compared to the breakeven levels generated by Fitch's cash flow
model of the CDO under the various default timing and interest
rate stress scenarios, as described in the report 'Global Criteria
for Cash Flow Analysis in CDOs - Amended'.

Following an event of default in July 2009, the required majority
of the controlling class voted to accelerate the transaction.
Interest and principal proceeds available after paying various
fees and the hedge counterparty, have been used to pay interest
due and principal of the class A-2 notes.

Although the class A-2 notes have paid down 13.4% of their balance
outstanding at last review, this was offset by the negative
migration in the portfolio.  Based on the cash flow model
analysis, the class A-2 notes' breakeven rates are generally
consistent with the 'A' rating category.

As a result of the acceleration, the class B notes have not been
receiving interest due.  Class B is non-deferrable and
accordingly, is affirmed at 'D'.

The principal balance of the class C notes is being written up by
the amount of interest owed.  The class C notes do not pass the
'CCC' rating hurdles, the lowest rating hurdles in the cash flow
analysis.  Fitch compared the credit enhancement with the amount
of underlying assets considered distressed (rated 'CCC' and
lower).  The class C notes have credit enhancement of 6.9% as
compared to the 36.1% of the portfolio considered distressed.
Therefore, Fitch views default as inevitable and these notes have
been affirmed at 'C'.

The Rating Outlook on the class A-2 notes remains Negative due to
Fitch's expectation of continuing rating volatility in the
underlying portfolio.

Fitch has also revised the Loss Severity rating on the class A-2
notes.  An LS rating indicates a tranche's potential loss severity
given default and was assigned based on the ratio of the tranche
size to the 'B' rating stress loss level.  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.  Fitch currently does not assign Recovery
Ratings to notes of structured finance CDOs.

MKP III is a structured finance collateralized debt obligation (SF
CDO) that closed on April 7, 2004, and is monitored by MKP Capital
Management, LLC.  The collateral is composed of 71.8% residential
mortgage-backed securities (RMBS), 23.8% commercial mortgage-
backed securities, 3.9% CDOs, and 0.5% asset backed securities
(ABS).

Fitch has taken these rating actions:

  -- $39,118,282 class A-2 notes downgraded to 'A/LS4' from
     'AA/LS3', Outlook Negative;

  -- $45,000,000 class B notes affirmed at 'D';

  -- $13,247,156 class C notes affirmed at 'C'.


MORGAN STANLEY: Moody's Reviews Ratings on 16 2005-HQ7 Notes
------------------------------------------------------------
Moody's Investors Service placed 16 classes of Morgan Stanley
Capital I 2005-HQ7 on review for possible downgrade due to higher
expected losses for the pool resulting from realized losses and
anticipated losses from specially serviced and watchlisted loans.
The rating action is the result of Moody's on-going surveillance
of commercial mortgage backed securities transactions.

As of the July 14, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 7% to $1.8 billion
from $1.9 billion at securitization.  The Certificates are
collateralized by 263 mortgage loans ranging in size from less
than 1% to 8% of the pool, with the top ten non-defeased loans
representing 28% of the pool.  Three loans, representing 3% of the
pool, have defeased and are collateralized by U.S. Government
securities.

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

Seven loans have been liquidated from the pool, resulting in an
aggregate realized loss of $15 million (53% loss severity on
average).  Fifteen loans, representing 4% of the pool, are
currently in special servicing.  The largest specially serviced
loan is the Padden Market Center Loan ($13.8 million -- 0.8% of
the pool), which is secured by a 42,000 square foot retail center
located in Vancouver, Washington.  This loan was transferred to
special servicing on April 23, 2010 due to monetary default.  The
remaining 14 specially serviced loans are secured by a mix of
retail, office, hotel, industrial and self storage properties.

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

Moody's rating action is:

  -- US$139.408M Cl. A-J Certificate, Aaa (sf) Placed Under Review
     for Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned Aaa (sf)

  -- US$14.675M Cl. B Certificate, Aa1 (sf) Placed Under Review
     for Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned Aa1 (sf)

  -- US$26.903M Cl. C Certificate, Aa2 (sf) Placed Under Review
     for Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned Aa2 (sf)

  -- US$17.121M Cl. D Certificate, Aa3 (sf) Placed Under Review
     for Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned Aa3 (sf)

  -- US$17.12M Cl. E Certificate, A1 (sf) Placed Under Review for
     Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned A1 (sf)

  -- US$19.566M Cl. F Certificate, A2 (sf) Placed Under Review for
     Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned A2 (sf)

  -- US$19.566M Cl. G Certificate, A3 (sf) Placed Under Review for
     Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned A3 (sf)

  -- US$26.904M Cl. H Certificate, Baa1 (sf) Placed Under Review
     for Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned Baa1 (sf)

  -- US$19.566M Cl. J Certificate, Baa2 (sf) Placed Under Review
     for Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned Baa2 (sf)

  -- US$19.566M Cl. K Certificate, Baa3 (sf) Placed Under Review
     for Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned Baa3 (sf)

  -- US$7.337M Cl. L Certificate, Ba1 (sf) Placed Under Review for
     Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned Ba1 (sf)

  -- US$9.783M Cl. M Certificate, Ba2 (sf) Placed Under Review for
     Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned Ba2 (sf)

  -- US$4.892M Cl. N Certificate, Ba3 (sf) Placed Under Review for
     Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned Ba3 (sf)

  -- US$4.891M Cl. O Certificate, B1 (sf) Placed Under Review for
     Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned B1 (sf)

  -- US$4.892M Cl. P Certificate, B2 (sf) Placed Under Review for
     Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned B2 (sf)

  -- US$9.783M Cl. Q Certificate, B3 (sf) Placed Under Review for
     Possible Downgrade; previously on Dec. 5, 2005 Definitive
     Rating Assigned B3 (sf)


MORGAN STANLEY: S&P Downgrades Ratings on 2006-6 Notes to 'D'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on classes
IVA, IVB, and IVC from Morgan Stanley Managed ACES SPC's series
2006-6, a synthetic corporate investment-grade collateralized debt
obligation transaction, to 'D' from 'CC'.

S&P lowered the ratings to 'D' because the notes incurred complete
principal losses.


MORGAN STANLEY: S&P Withdraws 'CCC-' Rating on Class IIC Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its 'CCC-' rating on
the class IIC notes from Morgan Stanley ACES SPC's series 2007-2,
a synthetic corporate investment-grade collateralized debt
obligation transaction.

The rating withdrawal follows the July 28, 2010, redemption of the
notes.

                         Rating Withdrawn

               Morgan Stanley ACES SPC Series 2007-2

                     Rating                Balance (mil. $)
                     ------                ----------------
       Class     To          From       Current     Previous
       -----     --          ----       -------     --------
       IIC       NR          CCC-          0.00        6.000

                         NR - Not rated.


N-45 FIRST: Moody's Affirms Ratings on Four Classes of Notes
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings of four classes and
upgraded three classes of N-45 First CMBS Issuer Corporation,
Commercial Mortgage-Backed Bonds, Series 2002-1.  The upgrades are
due to the stable to improving performance of the assets in the
pool and increased subordination resulting from principal
amortization and loan payoffs.  The affirmations are due to key
rating parameters, including Moody's loan to value ratio, Moody's
stressed DSCR and the Herfindahl Index, remaining within
acceptable ranges.

As of the July 15, 2010 distribution date, the pool balance has
decreased by approximately 58% to $143 million from $336 million
at securitization.  The Certificates are collateralized by ten
mortgage loans secured by office, retail, and industrial
properties.  The loans range in size from 1% to 26% of the pool
balance with the top three loans representing 65%.

The pool has not realized any losses since securitization and no
loans are on the master servicer's watchlist or in special
servicing.

Moody's pooled net cash flow and value are $28.8 million and
$285.3 million, respectively, compared to $28.6 million and
$289.6 million at last review.  Moody's weighted average LTV for
the transaction is 54% compared to 60% at last review.  Moody's
stressed debt service coverage ratio for the deal is 2.18x
compared to 2.04x at last review.

The largest loan in the pool is the Royal Bank Building Loan
($36.3 million -- 25.5% of the pool), which is secured by a
313,000 square foot Class A office building located in Toronto,
Ontario.  The property is approximately 92% leased as of April
2010 compared to 95% at last review.  The largest tenants are the
Government of Canada (64% of the net rentable area (NRA); lease
expiration April 2012; Moody's LT country ceiling rating Aaa,
stable outlook;) and Royal Bank of Canada (13% NRA; lease
expiration August 2011; Moody's senior unsecured rating Aaa,
negative outlook).  The loan is structured with an 18-year
amortization schedule and has amortized by approximately 32% since
securitization.  The loan is recourse to the principal of the
borrower.  Moody's LTV and stressed DSCR are 79% and 1.27X,
respectively, compared 86% and 1.06X at last review.

The second largest loan is the Maison Trust Royal Loan
($31.1 million -- 21.8% of the pool), which is secured by a
638,000 square foot Class A office building located in the
financial district of Montreal, Quebec.  The property was 83%
leased as of June 2010 compared to 91% at last review.  The
largest tenant is the Royal Bank of Canada, which leases 15% of
the NRA through January 2015.  The loan is structured with a 16-
year amortization schedule and has amortized by approximately 35%
since securitization.  Moody's LTV and stressed DSCR are 41% and
2.65X, respectively, compared 45% and 2.31X at last review.

The third largest loan is the Galeries de Granby Loan
($24.9 million -- 17.4% of the pool), which is secured by a
512,000 square foot community shopping center located in Granby,
Quebec.  The center was 99% leased as of May 3009, compared to
100% at last review.  Anchors include Wal-Mart Stores, Inc. (25%
gross leaseable area; lease expiration May 2020; Moody's senior
unsecured rating Aa2 -- stable outlook) and Sears Canada Inc. (23%
NRA; lease expiration November 2019).  The loan is structured on a
20-year schedule and has amortized by approximately 27% since
securitization.  Moody's LTV and stressed DSCR are 44% and 2.67X,
respectively, compared 53% and 2.18X at last review.

Moody's rating action is:

  -- CAD$72,107,937 Cl. A-2, affirmed at Aaa (sf); previously on
     6/10/2002 assigned Aaa (sf)

  -- CAD$0 Cl. IO, Notional, affirmed at Aaa (sf); previously on
     6/10/2002 assigned Aaa (sf)

  -- CAD$28,520,000 Cl. B, affirmed at Aaa (sf); previously on
     7/5/2007 upgraded to Aaa from Aa1 (sf)

  -- CAD$13,421,000 Cl. C Bond, Upgraded to Aaa (sf); previously
     on Jul 5, 2007 Upgraded to Aa2 (sf)

  -- CAD$10,066,000 Cl. D Bond, Upgraded to A1 (sf); previously on
     Jul 5, 2007 Upgraded to A2 (sf)

  -- CAD$8,388,000 Cl. E Bond, Upgraded to Baa3 (sf); previously
     on Jul 5, 2007 Upgraded to Ba1 (sf)

  -- CAD$5,035,930 Cl. F, affirmed at B2 (sf), previously on
     6/10/2002 assigned B2 (sf)


NAVIGATOR CDO: Moody's Upgrades Ratings on Various Notes
--------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Navigator CDO 2003, Ltd.:

  -- US$22,000,000 Class A-3A Floating Rate Senior Notes Due 2015,
     Upgraded to Aaa; previously on September 10, 2008 Upgraded to
     Aa1;

  -- US$16,000,000 Class A-3B Fixed Rate Senior Notes Due 2015,
     Upgraded to Aaa; previously on September 10, 2008 Upgraded to
     Aa1;

  -- US$26,000,000 Class B Floating Rate Senior Subordinate Notes
     Due 2015, Upgraded to Aa1; previously on September 10, 2008
     Upgraded to Aa2.

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 February 13, 2009, the Class A-1
Notes have been paid down by approximately $61.4 million, or
roughly 92% of their outstanding balance reported in January 2009.
Moody's expects delevering to continue as a result of the end of
the deal's reinvestment period in May 2007.  As a result of the
delevering, the overcollateralization ratios have increased since
the last rating action.  Based on the latest trustee report dated
July 3, 2010, the Class A and Class B overcollateralization ratios
increased to 173.9%, and 139.4% respectively, compared to January
2009 levels of 151.4%, and 131.0% respectively.

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 3, 2010, the weighted average rating factor is 2626
compared to 2695 in January 2009, and securities rated Caa1 or
lower make up approximately 6.8% of the underlying portfolio
versus approximately 8.8% in January 2009.  Additionally,
defaulted securities have been reduced to about $7 million from
$11.5 million in January 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.

In addition, Moody's withdrew the ratings of these notes:

  -- US$10,000,000 Class Q-1 Notes Due 2015, Withdrawn; previously
     on February 13, 2009 Downgraded to Ba1;

  -- US$5,333,333 Class Q-2 Notes Due 2015, Withdrawn; previously
     on February 13, 2009 Downgraded to Ba1.

The Class Q-1 and Class Q-2 Notes were exchanged for their
underlying components at the noteholder's request.  As a result,
the ratings of the notes have been withdrawn.

Navigator CDO 2003, Ltd., issued in December 2003, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.


OAKWOOD HOMES: S&P Downgrades Ratings on 23 Classes of Certs.
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 23
classes of certificates and affirmed its ratings on 33 classes of
certificates from 24 Oakwood Homes Corp. -related manufactured
housing asset-backed securities transactions.

The downgrades reflect S&P's view of the continued deterioration
in collateral performance for these transactions.  Higher default
frequencies and lower recoveries have resulted in higher-than-
expected cumulative net losses, which have caused reductions in
available credit support for these transactions.  Based on the
current adverse collateral performance trends, S&P has increased
its cumulative net loss expectations for all transactions.  As a
result of this increase and the deterioration in credit
enhancement, S&P believes that the available credit enhancement
remaining is no longer consistent with S&P's current ratings.

Most of the affirmations reflect S&P's view of the growth in
credit enhancement levels (as a percent of an amortizing
collateral balance), which S&P believes are sufficient to cover
its revised expected cumulative net losses 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

                                              Revised
                           Pool     Current   lifetime
          Series      Mo.  factor   CNL       CNL exp.(i)
          ------      ---  ------   -------   -----------
          1995-A      181  4.32     16.58     16.75-17.25
          1995-B      177  6.65     15.30     15.50-16.50
          1996-B      167  9.74     18.16     19.25-20.25
          1996-C      164  11.48    19.73     21.75-22.75
          1997-A      161  13.36    17.33     19.50-20.50
          1997-B      158  14.66    19.25     22.00-23.00
          1997-C      155  16.98    18.01     21.00-22.00
          1998-A      149  14.80    23.27     26.25-27.25
          1998-B      146  13.98    27.70     31.50-32.50
          1998-D      141  18.73    27.87     33.75-34.75
          1999-C      133  20.78    29.34     35.50-36.50
          1999-D      131  21.64    28.23     34.50-35.50
          1999-E      128  23.29    26.05     32.50-33.50
          2000-A      124  23.63    27.41     34.50-35.50
          2000-B      121  19.66    32.86     39.50-40.50
          2000-C      118  17.88    33.05     39.50-40.50
          2000-D      115  17.55    40.93     48.25-49.25
          2001-C      110  18.84    44.49     52.50-53.50
          2001-D      107  24.80    35.27     45.00-46.00
          2001-E      104  27.20    31.81     41.50-42.50
          2002-A      101  28.61    30.58     41.50-42.50
          2002-B      98   27.77    30.71     41.50-42.50
          2002-C      95   31.75    29.48     42.00-43.00
          2004-OAK1   78   32.61    N/A(ii)   39.50-40.50

(i) Revised lifetime CNL expectations based on current performance
    data.

CNL - cumulative net loss.

(ii) Series 2004-OAK1 is a resecuritization backed by the
     underlying collateral of the class A-1 certificates for
     series 2000-B and 2000-C.

Subordination (for the higher-rated tranches),
overcollateralization, and excess spread provided initial credit
enhancement for these transactions.  Since the transactions are
experiencing higher-than-expected cumulative net losses, all of
the transactions, except for series 2004-OAK1, no longer contain
overcollateralization.  Furthermore, many of the transactions are
experiencing full or partial write-downs on the mezzanine and
subordinate certificates.  Series 2000-A, 2000-B, 2000-D, 2001-C,
and 2001-D, which all contain outstanding class A certificates
rated 'CCC-', have collateral balances that are currently less
than the outstanding certificate balance.  In S&P's view, the
class A certificates from these deals are highly vulnerable to
nonpayment of full and timely interest or ultimate principal at
each certificate's legal final maturity date.

                             Table 2

                     Hard Credit Support (%)

               As of the June 2010 performance month


      Series    Class(i)             Current hard support (%)
      ------    --------             ------------------------
      1995-A    B-1                   0.00
      1995-B    B-1                   0.00
      1996-B    A-6                  58.08
      1996-C    A-6                  64.42
      1997-A    A-6                  67.42
      1997-A    B-1                   0.00
      1997-B    M-1                  43.66
      1997-C    A                    88.18
      1997-C    M-1                  41.06
      1998-A    A                    67.51
      1998-A    M-1                  15.14
      1998-B    A                    58.31
      1998-B    M-1                   2.89
      1998-D    A                    38.73
      1999-C    A-2                   9.99
      1999-D    A-1                  16.39
      1999-E    A-1                  10.73
      2000-A    A                    -2.48
      2000-B    A-1                 -34.07
      2000-C    A-1                  22.97
      2000-D    A                    -9.76
      2001-C    A                   -40.02
      2001-D    A                    -1.88
      2001-E    A                     4.64
      2002-A    A                    29.44
      2002-B    A                    28.26
      2002-C    A-1                  30.04
      2004-OAK1 A-2                  72.76
      2004-OAK1 A-3                  72.76
      2004-OAK1 A-4                  49.01

(i) Class A credit support pertains to all class A certificates
    issued from the transaction.

Clayton Homes Inc., a subsidiary of Berkshire Hathaway Inc.,
acquired Oakwood Mortgage Corp. in April 2004, and Vanderbilt
Mortgage and Finance Inc. has assumed the servicing
responsibilities for the Oakwood portfolio.

Standard & Poor's will continue to monitor the performance of
these transactions to assess whether the credit enhancement
remains adequate, in S&P's view, to support its ratings under
various stress scenarios.

                         Ratings Lowered

                  Oakwood Mortgage Investors Inc.

                                       Rating
                                       ------
                Series    Class     To        From
                ------    -----     --        ----
                1995-A    B-1       CCC-      BB-
                1995-B    B-1       CCC-      B-
                1997-B    M-1       A         AA
                1998-A    M-1       CCC       B-
                1998-B    A-3       A         AA
                1998-B    A-4       A         AA
                1998-B    A-5       A         AA
                1998-B    M-1       CCC-      CCC
                1998-D    A         BB        BBB+
                1998-D    A-1 ARM   BB        BBB+

                            OMI Trust

                                       Rating
                                       ------
                Series    Class     To        From
                ------    -----     --        ----
                1999-C    A-2       CCC-      B-
                1999-D    A-1       CCC-      BB-
                1999-E    A-1       CCC-      B
                2000-C    A-1       CCC-      CCC+
                2002-A    A-1       B-        BB-
                2002-A    A-2       B-        BB-
                2002-A    A-3       B-        BB-
                2002-A    A-4       B-        BB-
                2002-B    A-1       B-        BB-
                2002-B    A-2       B-        BB-
                2002-B    A-3       B-        BB-
                2002-B    A-4       B-        BB-
                2002-C    A-1       B-        B

                         Ratings Affirmed

                  Oakwood Mortgage Investors Inc.

                     Series    Class    Rating
                     ------    -----    ------
                     1996-B    A-6      AAA
                     1996-C    A-6      AAA
                     1997-A    A-6      AAA
                     1997-A    B-1      CC
                     1997-C    A-3      AAA
                     1997-C    A-4      AAA
                     1997-C    A-5      AAA
                     1997-C    A-6      AAA
                     1997-C    M-1      A
                     1998-A    A-4      AA-
                     1998-A    A-5      AA-

                             OMI Trust

                     Series    Class    Rating
                     ------    -----    ------
                     2000-A    A-2      CCC-
                     2000-A    A-3      CCC-
                     2000-A    A-4      CCC-
                     2000-A    A-5      CCC-
                     2000-B    A-1      CCC-
                     2000-D    A-3      CCC-
                     2000-D    A-4      CCC-
                     2001-C    A-1      CCC-
                     2001-C    A-2      CCC-
                     2001-C    A-3      CCC-
                     2001-C    A-4      CCC-
                     2001-D    A-1      CCC-
                     2001-D    A-2      CCC-
                     2001-D    A-3      CCC-
                     2001-D    A-4      CCC-
                     2001-E    A-1      CCC-
                     2001-E    A-2      CCC-
                     2001-E    A-3      CCC-
                     2001-E    A-4      CCC-

    ABSC Manufactured Housing Contract Resecuritization Trust
                             2004-OAK1

                         Class    Rating
                         -----    ------
                         A-2      BBB+
                         A-3      BBB+
                         A-4      BB+


PARCS-R MASTER: S&P Downgrades Rating on Series 2007-19 to 'D'
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the trust
units from PARCS-R Master Trust's series 2007-19 to 'D' from 'CC'.

The downgrade follows a number of recent losses the transaction
incurred due to credit events affecting underlying reference
entities, which have caused the notes to incur a complete
principal loss.


PARTS 2007-CT1: Fitch Affirms Ratings on Various Classes of Notes
-----------------------------------------------------------------
Fitch Ratings has affirmed the senior notes and downgraded the
subordinate notes from the private student loan transaction PARTS
2007-CT1.  Fitch's Global Structured Finance Rating Criteria and
Private Student Loan Asset-Backed Securities Criteria are applied
for the review of the transaction.

Fitch affirms the ratings on the senior notes as the loss multiple
was sufficient to affirm the ratings, reflective of adequate
credit enhancement.  Fitch downgrades the ratings on the mezzanine
and junior subordinate notes as the loss multiples were indicative
of lower ratings tied to the higher than expected default levels.
Fitch has removed all ratings from Rating Watch Negative and
assigned Negative Outlooks, reflecting Fitch's concern that the
collateral performance may continue to deteriorate and Fitch's
view on the private student loan sector in general.

Loss multiples based on the latest performance data were derived
to determine the appropriate ratings.  The projected net loss
amounts were compared to available credit enhancement to determine
the loss multiples for each rating category, given a loss timing
curve representative of each pool depending on loan composition.
After giving credit for seasoning of loans in repayment, Fitch
applied the trust's current cumulative gross loss level to this
loss timing curve to derive the expected gross losses over the
projected remaining life.  A recovery rate was applied, at the
level assumed during the transaction's initial review.  The loss
multiples for each rating category took into consideration the
remaining gross loss projections against the original pool
balance.

Credit enhancement consists of excess spread,
overcollateralization, and a reserve fund for the senior and
subordinate notes and subordination for the senior and mezzanine
notes.  Fitch assumed excess spread to be the lesser of the
average historical excess spread (earning on the assets minus
interest payments to bondholders and fees) and the most recent 12-
month average excess spread, and applied that same rate over the
remaining life.

The private student loan collateral consists of private student
loans that were originated either by TERI or LEARN underwriting
guidelines by Liberty Bank, N.A. or Charter One Bank, N.A. Loan
losses are guaranteed by a TERI guaranty for TERI originated loans
and by the LEARN account for LEARN originated loans.  The trust
portfolio is comprised of 80.8% of LEARN loans and 19.2% of TERI
loans.

Fitch has taken these rating actions:

  -- Class A affirmed at 'AAA', Outlook Negative;
  -- Class B downgraded to 'A-' from 'A', Outlook Negative;
  -- Class C downgraded to 'BB-' from 'BBB', Outlook Negative.

Fitch has removed the above-referenced notes from Rating Watch
Negative.


PPM AMERICA: Moody's Upgrades Ratings on Two Classes of Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by PPM America High Grade CBO I,
Ltd.:

* US$48,000,000 Class B-1 Senior Subordinated 9.036% Fixed Rate
  Notes Due January 15, 2013 (current balance of $6,957,432),
  Upgraded to A2; previously on May 7, 2009 Downgraded to Caa3;

* US$10,000,000 Class B-2 Senior Subordinated Floating Rate Notes
  Due January 15, 2013 (current balance of $1,449,465), Upgraded
  to A2; previously on May 7, 2009 Downgraded to Caa3.

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 significant increases in
the overcollateralization of the Class B Notes.  In addition, the
transaction has benefited from significant improvement in the
credit quality of the remaining underlying portfolio.

On the last payment date on July 15, 2010, the Class A-2A Notes
and the Class A-2B Notes were repaid in full, and the Class B-1
Notes and the Class B-2 Notes were repaid about $49.6 million or
86% of their original note balances.  A substantial proportion of
this repayment is attributable to sales of the underlying
securities in the portfolio in addition to scheduled principal
proceeds.  For example, in the past month, the collateral manager
has sold approximately $87 million of bonds at an average price
above par.  There are currently five bonds remaining in the
portfolio with a principal balance of $24.7 million,
collateralizing $8.4 million of the Class B-1 Notes and B-2 Notes.
As a result of the deleveraging of the capital structure, the
Class B overcollateralization ratio has increased significantly to
over 200% as of July 2010 (as measured by performing par over
outstanding liabilities) from 102.7% in April 2009.  Moody's
expects deleveraging to continue as a result of the end of the
deal's reinvestment period in January 2005.

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).  In particular,
as of the latest trustee report dated July 1, 2010, the weighted
average rating factor is 1071 (an average rating of Ba1/Ba2)
compared to 2484 in April 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.

PPM America High Grade CBO I, Ltd., issued in December 2000, is a
collateralized bond obligation backed primarily by a portfolio of
senior unsecured bonds.


REVE SPC: Moody's Downgrades Ratings on Class C Notes to 'C'
------------------------------------------------------------
Moody's Investors Service announced that it has downgraded its
ratings of REVE SPC Segregated Portfolio Series 52, a corporate
synthetic obligation referencing a managed portfolio of corporate
entities.

The rating action is:

* US$5,000,000 ING Managed Synthetic 2007-2 Class C Notes, due
  2012, Downgraded to C; previously on October 23, 2008 Downgraded
  to Ca;

Moody's explained that the rating action taken is the result of
the rated tranche experiencing 100% losses due to credit events on
Federal Home Loan Mortgage Corporation, Federal National Mortgage
Association, Lehman Brothers Holdings Inc., Washington Mutual
Inc., Glitnir Bank HF, Kaupthing Bank HK, SuperMedia Inc., JSC
Bank Turanalen, and Syncora Guarantee Inc.  A notice of final
payment has been given and the notes are no longer outstanding.
The rating will thus be subsequently withdrawn.


REVE SPC: S&P Downgrades Rating on Class B Notes to 'D'
-------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
B notes from REVE SPC's series 58 to 'D' from 'CC'.

The downgrade follows a number of recent losses the transaction
incurred due to credit events affecting underlying reference
entities, which have caused the notes to incur a complete
principal loss.


SALOMON BROTHERS: Moody's Upgrades Ratings on Five 2000-C1 Certs.
-----------------------------------------------------------------
Moody's Investors Service upgraded the ratings of three classes,
affirmed two classes and downgraded five classes of Salomon
Brothers Securities VII, Inc., Commercial Mortgage Pass-Through
Certificates, Series 2000-C1.

The upgrades are due to increased credit support from loan payoffs
and principal amortization.  The deal has paid down 86% since
Moody's prior review.  The affirmations are due to key rating
parameters, including Moody's loan to value ratio and Moody's
stressed debt service coverage ratio, remaining within acceptable
ranges.  The downgrades are due to higher expected losses for the
pool resulting from realized and anticipated losses from the
specially serviced loans and a decline in loan diversity.

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

As of the July 19, 2010 statement date, the transaction's
aggregate certificate balance has decreased 89% to $82.2 million
from $713.3 million at securitization.  The certificates are
collateralized by 30 mortgage loans ranging in size from less than
1% to 30% of the pool.  Six loans, representing 10% of the pool,
have defeased and are collateralized by U.S. Government
securities.  Excluding specially serviced and defeased loans, the
conduit pool consists of 11 loans.  Eight of these loans,
representing 77% of the conduit pool, are secured by single-tenant
retail or office properties with leases that are co-terminus with
the respective loan maturity.  These loans have a weighted average
time to maturity of approximately five years.

One loan, representing 2% of the pool, is on the master servicer's
watchlist.  The watchlist includes loans which meet certain
portfolio review guidelines established as part of the CRE Finance
Council (formerly Commercial Mortgage Securities Association)
monthly reporting package.  As part of Moody's ongoing monitoring
of a transaction, Moody's reviews the watchlist to assess which
loans have material issues that could impact performance.

Thirteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of approximately $17.8 million (36% loss
severity on average).  Thirteen loans, representing approximately
37% of the pool, are currently in special servicing.  All of these
loans have passed their respective maturity dates.  The largest
specially serviced loan is the Los Altos Woods Office Building
Loan ($6.9 million -- 8% of the pool), which is secured by a
39,000 square foot suburban office building located in Los Altos,
California.  The loan was transferred to special servicing in
November 2009 for maturity and payment default and is currently
90+ days delinquent.  As of December 2009, the property was 84%
leased with all of the leases expiring within the next four years.
The remaining 12 specially serviced loans are secured by a mix of
property types.  Moody's estimates an aggregate $15.8 million loss
for 12 of the specially serviced loans (overall 52% expected
loss).

Moody's was provided with full-year 2008 and full-year 2009
operating results for 100% and 98%, respectively, of the conduit
pool.  Excluding specially serviced and troubled loans, Moody's
conduit weighted average LTV is 68% compared to 83% at Moody's
prior review.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.25X and 1.75X, respectively, compared to
1.30X and 1.47X at last review.  Moody's actual DSCR is based on
Moody's net cash flow and the loan's actual debt service.  Moody's
stressed DSCR is based on Moody's NCF and a 9.25% stressed rate
applied to the loan balance.

Moody's uses a variation of the Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf is 40.  The pool
has a Herf of 7 compared to 61 at Moody's prior review.

The top three non-defeased conduit loans represent 45% of the
pool.  The largest loan is the Putnam Building Loan ($24.7 million
- 30% of the pool), which is secured by a 231,000 square foot
office building located in Norwood, Massachusetts, approximately
13 miles southwest of Boston.  Built in 1978, the property is 100%
triple net leased to Putnam Investments, a subsidiary of Great-
West Life Assurance Company (Moody's senior unsecured rating Aa2;
stable outlook) through July 2013.  The loan has amortized 5%
since last review.  Performance remains in-line with last review.
Moody's LTV and stressed DSCR are 82% and 1.25X compared to 87%
and 1.18X, respectively, at last review.

The second largest conduit loan is the Sports Arena Village Loan
($8.0 million -- 10% of the pool), which is secured by a 282,000
square foot retail and office property located in San Diego,
California.  As of March 2010, the property was 91% leased
compared 93% at last review.  The largest tenant is Science
Applications Corp. (24% of the net rentable area; lease expires in
August 2015).  Property performance has declined since last review
but the decline has been offset by amortization.  The loan is
fully amortizing and has amortized 17% since last review.  The
loan matures in June 2018.  Moody's LTV and stressed DSCR are 39%
and 3.04X, respectively, compared to 42% and 2.81X, respectively,
at last review.

The third largest conduit loan is The Sports Authority Loan
($3.9 million -- 5% of the pool), which is secured by a 46,000
square foot retail property located along the Northern Boulevard
retail corridor in Long Island City, New York.  The property is
100% leased to The Sports Authority through February 2015.
Performance remains in-line with last review.  The loan matures in
February 2015 and has amortized 5% since last review.  Moody's LTV
and stressed DSCR are 61% and 1.63X compared to 65% and 1.50X,
respectively, at last review.

Moody's rating action is:

  -- Class X, Notional, affirmed at Aaa; previously assigned Aaa
     on 3/7/2001

  -- Class E, $3,923,291, upgraded to Aaa from Aa1; previously
     upgraded to Aa1 from Aa2 on 9/25/2008

  -- Class F, $14,266,000, upgraded to Aa3 from A1; previously
     upgraded to A1 from A2 on 9/25/2008

  -- Class G, $10,7000,000, upgraded to A2 from A3; previously
     upgraded to A3 from Baa1 on 9/25/2008

  -- Class H, $14,266,000, affirmed at Ba1; previously assigned
     Ba1 on 3/7/2001

  -- Class J, $17,832,000, downgraded to Ba3 from Ba2; previously
     assigned Ba2 on 3/7/2001

  -- Class K, $5,350,000, downgraded to Ca from Ba3; previously
     assigned Ba3 on 3/7/2001

  -- Class L, $3,566,000, downgraded to C from B1; previously
     assigned B1 on 3/7/2001

  -- Class M, $7,133,000, downgraded to C from B3; previously
     downgraded to B3 from B2 on 9/8/2006

  -- Class N, $5,153,348, downgraded to C from Caa2; previously
     downgraded to Caa2 from B3 on 9/8/2006


SALT CREEK: Fitch Withdraws Ratings on Class B-6$L Notes
--------------------------------------------------------
Fitch Ratings has withdrawn its ratings on the class B-6$L notes
issued by Salt Creek High Yield CSO 2005-1 Ltd.

In October 2009, Fitch downgraded the rating of the class B-6$L
notes to 'D' from 'B+'.  The downgrade was due to losses incurred
following credit events in the reference portfolio.  In March
2010, the Initial Mandatory Redemption Date occurred, and the
eligible investments were liquidated to repay the remaining
principal balances to noteholders.  Class B-6$L was paid $932,520
representing the remaining principal balance after realized losses
on the $2 million original principal amount.  All other classes in
Salt Creek 2005-1 were paid in full.

Salt Creek was a synthetic collateralized debt obligation that
closed in March 2005 and was managed by TCW Asset Management Co.
Salt Creek provided investors leveraged access to the credit risk
of a diverse portfolio of credit default swaps referencing
primarily non-investment-grade corporate obligations.  Salt Creek
gained access to the credit risk of the portfolio via a credit
default swap with J.P. Morgan Securities Ltd., as swap
counterparty.

Fitch has withdrawn the 'D' rating on this class:

  -- Series B-6$L notes.


SENIOR HOUSING: Moody's Upgrades Senior Unsec. Rating From 'Ba1'
----------------------------------------------------------------
Moody's Investors Service has upgraded the senior unsecured rating
of Senior Housing Property Trust to Baa3, from Ba1.  The rating
outlook is stable.

This rating action reflects the substantial progress made by
Senior Housing in terms of growth and diversity, as well as its
maintenance of consistently sound credit metrics.  Since 2008,
Senior Housing has increased property type diversity by
establishing a presence in the medical office building sub-sector,
much of which was accomplished via the acquisition of a large MOB
portfolio from CommonWealth REIT, an affiliated REIT with whom it
shares an external manager.  MOBs comprised 23% of Senior
Housing's annualized current rents as of 1Q10 and Moody's expects
the REIT will continue to increase its investment in this sub-
sector.  Moody's views the addition of MOBs as a strategic plus
for the REIT which already has a firm foothold in the senior
housing sub-segment, with additional smaller holdings of skilled
nursing facilities, wellness centers and rehabilitation hospitals.
The MOB sub-sector has historically been a more stable asset class
with higher occupancy rates and lower turnover.  Furthermore, this
property sub-type lends itself to tenant diversification and has
modest government reimbursement exposure.

Moody's notes that Senior Housing has achieved increased size
(gross assets of $3.4 billion at 1Q10, up from $2.0 billion at
YE07) and diversification without compromising its balance sheet.
The REIT maintains modest leverage, with Net Debt/EBITDA of 3.6x
and effective leverage (debt plus preferred as a % of gross
assets) of 30% at 1Q10.  In addition, fixed charge coverage was
solid at 3.8x for 1Q10.  Liquidity remains adequate as the REIT
has modest near-term debt maturities ($64M maturing in 2010 and
$9M in 2011) and a sizable $550M unsecured line, which had $58M
drawn at 1Q10.  Senior Housing further enhanced its liquidity with
the issuance of $200M of senior unsecured bonds in April 2010,
which was used to redeem $97.5 million of senior unsecured bonds
due in 2015 and repay the $58M line of credit balance.

These strengths are counterbalanced by still challenging senior
housing fundamentals, material tenant concentration with Five
Star, and increased secured debt levels.  The senior housing
sector has shown good resilience through this economic downturn,
particularly given its close relationship to the single-family
housing market.  However, even as occupancy levels appear to be
bottoming, the risk of a double dip recession has increased in
recent months, and such a scenario would likely pressure senior
housing fundamentals further.  Senior Housing has good cushion
with its property level rent coverage ratios, but risks remain.
Furthermore, these risks are particularly acute for Senior Housing
given its material tenant concentration with Five Star Quality
Care.  Senior Housing's exposure to Five Star, a healthcare
operator which is a related entity, has decreased but remains a
significant portion of its portfolio at 57% of annualized rents.
Moody's further notes that Senior Housing's secured debt levels
have increased (19% of gross assets as of 1Q10) due to the REIT's
$513 million Fannie Mae financing originated in 2009.  While this
level of secured debt is high, Moody's acknowledges that the REIT
has not historically been a large issuer of mortgage debt and that
this financing was completed during a severe credit contraction.
Moody's anticipates Senior Housing to fund itself primarily on an
unsecured basis going forward.

The stable rating outlook reflects Moody's expectation that Senior
Housing will continue to execute its growth and diversification
strategy while maintaining adequate property level coverage ratios
and conservative credit metrics.

A rating upgrade would be difficult unless Senior Housing is able
to reduce its Five Star concentration to below 25% of annualized
rents.  Increased size (gross assets above $5 billion) and further
enhancement of property type diversification would be a plus.
Continued improvement in property coverage ratios and maintenance
of a conservative capital strategy with modest overall leverage
and secured debt would also be necessary for an upgrade.

Negative rating pressure would likely occur from the sustained
deterioration in property-level coverage ratios.  Given Senior
Housing's Five Star concentration, Moody's expect the REIT to
maintain relatively conservative balance sheet metrics for its
rating category.  Therefore, a sustained increase in leverage
above 35% or a sustained decline in fixed charge coverage below 3x
would also be viewed negatively.

These ratings were upgraded with a stable outlook:

* Senior Housing Properties Trust, Inc. -- senior unsecured rating
  to Baa3 from Ba1; senior unsecured shelf rating to (P)Baa3 from
  (P)Ba1; preferred stock shelf rating to (P)Ba1 from (P)Ba2.

Moody's last rating action with respect to Senior Housing was on
November 17, 2009, when the rating was affirmed at Ba1 with a
positive outlook.

Senior Housing Properties Trust, headquartered in Newton,
Massachusetts, USA, is a REIT that owns independent and assisted
living properties, continuing care retirement communities, nursing
homes, hospitals, wellness centers and medical office, clinic and
biotech laboratory buildings located throughout the United States.
As of March 31, 2010, the REIT reported assets of approximately
$3.0 billion, and shareholders' equity of approximately
$1.9 billion.


SLM STUDENT: Fitch Affirms Ratings on Various 2003-12 Notes
-----------------------------------------------------------
Fitch Ratings has affirmed the senior student loan bond and
downgraded the subordinate bond issued by SLM Student Loan Trust
2003-12 and assigned Outlooks as outlined below:

  -- Class A-4 affirmed at 'AAA/LS1'; Outlook Stable

  -- Class A-5 affirmed at 'AAA/LS1'; Outlook Stable

  -- Class A-6 affirmed at 'AAA/LS1'; Outlook Stable

  -- Class B downgraded to 'BB/LS3' from 'AAA/LS3'; Outlook
     Stable.

Additionally, Fitch has removed the subordinated bond from Rating
Watch Negative.

Fitch used its Global Structured Finance Rating Criteria and FFELP
student loan ABS rating criteria, as well as the refined basis
risk criteria outlined in Fitch's June 29 press release ('Fitch to
Begin Review of U.S. FFELP SLABS Applying Updated Criteria') to
review the ratings.


SLM STUDENT: Fitch Affirms Ratings on Various 2004-8 Bonds
----------------------------------------------------------
Fitch Ratings has affirmed the senior student loan bond and
downgraded the subordinate bond issued by SLM Student Loan Trust
2004-8 and assigned Outlooks as outlined below:

  -- Class A-4 affirmed at 'AAA/LS1'; Outlook Stable

  -- Class A-5 affirmed at 'AAA/LS1'; Outlook Stable

  -- Class A-6 affirmed at 'AAA/LS1'; Outlook Stable

  -- Class B downgraded to 'BB/LS3' from 'AAA/LS3'; Outlook
     Stable.

Additionally, Fitch has removed the subordinated bond from Rating
Watch Negative.

Fitch used its Global Structured Finance Rating Criteria and FFELP
student loan ABS rating criteria, as well as the refined basis
risk criteria outlined in Fitch's June 29 press release ('Fitch to
Begin Review of U.S. FFELP SLABS Applying Updated Criteria') to
review the ratings.


STARTS 2007-21: Moody's Upgrades Ratings on Various Classes
-----------------------------------------------------------
Moody's Investors Service announced that it has upgraded its
rating of notes issued by STARTS 2007-21 LSS, a leverage super
senior collateralized debt obligation transaction referencing a
portfolio static of corporate entities.  If the accumulated loss
of the portfolio has exceeded the predefined loss trigger for the
relevant predetermined times, the investors of the leverage senior
tranche may choose to incur the mark-to-market loss of the super
senior tranche up to the initial investment or increase the size
of their investment.  Moody's explained that its rating
methodology applicable to this transaction address the probability
of a Trigger Event and assumes no recovery for a leveraged super
senior note once a Trigger Event is breached.  Such loss triggers
increase with the passage of time, reducing the likelihood of a
Trigger Event as long as the losses of the transaction increase at
a slower rate than the loss triggers.

The rating action is:

* US$25,000,000 STARTS 2007-21 LSS CREDIT LINKED NOTES Notes,
  Upgraded to B1; previously on Sept. 30, 2009 Downgraded to Caa1

Moody's explained that the rating action taken is the result of
the improvement of the credit quality of the reference portfolio,
the higher loss triggers due to the passage of time, and the
higher than expected recovery rates from the credit events of CIT
Group, Inc, and Cemex, S.A.B. de C.V.  The 10 year weighted
average rating factor of the portfolio, has improved from 1273 to
1235.  Netting off the credit events and the C rated entities, the
10 year WARF has improved from 725 to 692.  Since the inception of
the transaction, the subordination of the rated tranche has been
reduced due to credit events on Lehman Brothers Holdings Inc.,
Federal Home Loan Mortgage Corp, Federal National Mortgage
Association, CIT Group, Inc., and Cemex, S.A.B. de C.V.  These
credit events lead to a decrease of approximately 1.2% of the
subordination of the tranche while at during the same period, the
loss trigger has increased from 4.25% to 6.15%.  The reference
portfolio has the highest industry concentration in insurance
(9.2%), telecommunications (8.3%), Sovereign & Public Finance
(7.5%) and Banking (7.5%).


STRUCTURED INVESTMENTS: Moody's Raises Ratings on Series 81 Notes
-----------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
rating of these notes issued by Structured Investments Corporation
Series 81:

* US$800,000 Structured Investments Corporation Series 81 Secured
  Medium Term Notes due 2016 (current rated balance of $559,890),
  Upgraded to B2 (sf); previously on June 22, 2009 Downgraded to
  B3(sf).

The transaction is a repackaged security whose rating is based
primarily upon the transaction's structure and the credit quality
of the Term Assets, which consist of $700,000 of the Class C-1
Floating Rate Deferrable Senior Subordinate Notes Due 2016 and
$100,000 of the Income Notes, both issued by Dryden VI-Leveraged
Loan CDO 2004 Inc., a synthetic CLO referencing primarily a
portfolio of senior secured loans.  The Class C-1 Notes were
upgraded from Caa3 (sf) to Caa1(sf) on August 4, 2010.


SYCAMORE CBO: Moody's Downgrades Ratings on Three Classes of Notes
------------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by Sycamore CBO (Cayman) Ltd.:

  -- US$29,000,000 Class B-1 Senior Secured Floating Rate Notes
     Due 2011 (current balance of $32,457,503), Downgraded to C;
     previously on February 26, 2003 Downgraded to Ca;

  -- US$10,000,000 Class B-2 Senior Secured Fixed Rate Notes Due
     2011 (current balance of $14,239,076), Downgraded to C;
     previously on February 26, 2003 Downgraded to Ca;

  -- US$18,000,000 Class C Senior Secured Fixed Rate Notes Due
     2011(current balance of $51,071,894), Downgraded to C;
     previously on March 8, 2002 Downgraded to Ca.

According to Moody's, the rating actions taken on the notes
reflect increased concerns about the insufficient
collateralization of the notes.  The underlying portfolio consists
of $10.4 million of performing securities supporting $97.7 million
of outstanding liabilities.  As of the latest trustee report,
dated July 3, 2010, the Class B Overcollateralization Ratio was
reported at 27.81% versus a test level of 110% and the Class C
Overcollateralization Ratio was reported at 18.79% versus a test
level of 100%.  Additionally, interest payments on the Class B and
Class C Notes are presently being deferred as a result of interest
shortfalls and the failures of the Class B and Class C
Overcollateralization Ratio Tests and Interest Coverage Tests.  On
February 17, 2010, the trustee provided notice of the occurrence
of an event of default due to a default in the payment of interest
on the Class B-1 Notes and Class B-2 Notes on the February 10,
2010 payment date.  Moody's believes that there is a high
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 significant losses to
holders of the notes consistent with a C rating.

Sycamore CBO (Cayman) Ltd., issued on February 10, 2000, is a
collateralized bond obligation backed primarily by a portfolio of
senior unsecured bonds.


TOWNSHIP OF WEEHAWKEN: Moody's Assigns 'Ba1' Rating on Bonds
------------------------------------------------------------
Moody's Investors Service has assigned an initial Ba1 rating to
the Township of Weehawken's (New Jersey) $5 million General
Obligation Bonds, Series 2010A (Tax-Exempt) & 2010B (Taxable).
The bonds are also secured by the general obligation unlimited tax
pledge of the township.  The Ba1 rating incorporates Moody's
expectation that the township's financial position will remain
narrow in the coming years due to limited reserves, and the need
for cash flow borrowing.  The rating additionally factors the
township's moderate tax base which is expected to continue to grow
and an above average debt burden.  Proceeds of the current sale
will provide permanent financing for Bond Anticipation Notes used
to make various capital improvements in the township, and fund the
township's self insurance program.

     Historical Operating Deficits; Negative Net Cash Position

The township's budgets have historically relied heavily on one-
time revenues and deferred charges to balance the budget.  The
township has experienced significant operating deficits of at
least $1 million in each of the last three years, continuing a
trend that began at least a decade ago.  During the past seven
years, the township's Current Fund balance has averaged $179,000,
or less than 2% of Current Fund revenues, while only increasing
above $250,000 despite rapid growth in property taxes from new
ratables.  Net of deferred charges, the Current Fund balance would
have been negative in each of those years, peaking at negative
$3.1 million, or -9.3% of Current Fund revenues, in fiscal 2008.
None of the deferred charges relate to the ability to defer the
school tax levy, making it necessary to expend deferred charges in
subsequent years' budgets.  This continued stress has resulted in
the need for Tax Anticipation Notes and other operating loans.
Over the last seven years, the township has averaged a net cash
balance of negative $3.1 million, and has seen cash borrowing
increase in the past five years ending in fiscal 2009.

In fiscal 2008, the township's financial position remained narrow,
ending with a Current Fund balance of $210,000, or minimal 0.62%;
net of deferred charges, the Current Fund balance would be a
negative $3.1 million, or -9.3% of Current Fund revenues.  In
fiscal 2008, the township relied on deferred charges of
$3.3 million to balance its budget.  The township's operating
deficit was driven by expenditure overruns in public safety
unbudgeted increases to the North Hudson Regional Fire District,
and health benefit premiums.  Included in the deferred charge was
a cash deficit of $2 million due to the overbudgeting of PILOT
payments from the Port Authority of New York and New Jersey
(Revenue debt rated Aa2/stable)., taxes from added assessments and
construction fees.  Fiscal 2009 produced similar results,
including deferred charges of $1.5 million due to public safety
overtime and retirement costs, and a $377,000 cash deficit in the
township's Special District (solid waste collection related
services).  These operating results continued the already
extremely narrow liquidity position (net cash equal to -3.3% of
Current Fund revenues) and reserve levels (Current Fund balance
equal to 0.6% of Current Fund revenues).  The township has
$4 million in unreserved receivables, including $2.8 million from
the Union City School District related to two years of failure to
pay rent on a building owned by the township and $1.2 million from
the Port Authority.  The township indicated that a portion of both
receivables were paid in fiscal 2010.  Moody's believes that the
Union City School District's ability to cure these receivables
will be strained given significant state aid reductions.

More than a month after the close of the fiscal year (ended
June 30), the township has still not produced an Annual Financial
Statement.  Township officials indicate that significant
expenditure reductions were made during the fiscal year, which
prevented the need for an Emergency Authorization or other
deferred charges during the year.  The township, however, remained
reliant on cash flow borrowing, issuing $19 million in TANs during
the year, as well as a property tax levy waiver of $1.7 million.
Future property tax levy waivers may be more difficult to obtain,
given a change in the law, which now includes the requirement of
voter approval for the waiver.  The township reports it will need
$10 million in TANs for ongoing operations in fiscal 2011.  Given
the city's significantly eroded financial position and the
tightened credit markets, Moody's believes the city may be
challenged to sell their notes.  Officials have outlined more than
$4 million in ongoing expenditure reductions to be made in the
fiscal 2011 budget, although the township will remain pressured by
reductions to state aid, the more restrictive 2% property tax levy
cap, and substantial fixed expenditures.

         Sizable Tax Base With Proximity To New York City

Moody's expects increased growth in the township's moderate
$2.2 billion tax base given ongoing economic development efforts
and its location across the Hudson River from New York City (G.O.
rated Aa2/stable outlook), at the mouth of the Lincoln Tunnel.
Over the last five years, the township has averaged strong annual
assessed value growth of 3.7% due to continued commercial and
residential construction, primarily the result of redevelopment of
riverfront properties.  Equalized value growth, reflective of
market appreciation, has averaged a strong 7.5% over the same
period, and has nearly tripled since 1999.  Though the ongoing
pace of development has slowed recently, several large retail
developments and high-end residential developments along the
waterfront contributed to the 1.9% assessed value growth in fiscal
2010.  Several other major commercial and high-end residential
developments are under construction, which management expects will
strengthen the demographic profile and tax base.  RealtyTrac.com
indicates that single-home property values have declined by a
fifth in the past year.  Long-term development opportunities and
property values will be enhanced by ferry, light rail and bus
service offering convenient access to New York City and Jersey
City (GO rated A2/stable).  Wealth and income levels are average
with per capita income levels at 108% of the state, and equalized
value per capita is an above-average $181,302.

        Average Debt Burden With Limited Future Debt Plans

Moody's believes the township's overall debt burden (3.4% of
equalized valuation) will remain above average, but manageable
over the medium-term, given tax base growth projected over the
next few years, moderate future borrowing plans and an average
amortization of principal (66.1% in 10 years).  The township's
overall debt burden includes significant overlapping Hudson County
Improvement Authority (G.O.  rated A1/positive outlook) and local
school district debt obligations.  The township has $4.3 million
of outstanding variable rate debt, issued through the HCIA, for
which it budgets a 5% interest rate.  Current interest rates are
approximately 3.5%.  The township is not party to any derivative
agreements.

                          Key Statistics

* 2008 Estimated population: 12,370 (-8.4% since 2000 census)

* 2010 Equalized Valuation: $2.2 billion

* Equalized Value Per Capita: $181,302

* 2000 Per Capita Income (as % of NJ and US): $29,269 (108.4% and
  135.6%)

* 2000 Median Family Income (as % of NJ and US): $52,612 (80.5%
  and 105.1%)

* Direct Debt Burden: 2.8%

* Overall Debt Burden: 3.4%

* Payout of Principal (10 years): 66.1%

* FY09 Current Fund balance: $224,000 (0.6% of Current Fund
  revenues)

* FY09 Current Fund balance net Deferred Charges: negative
  $1.3 million (-3.3% of Current Fund revenues)

* Post-sale long-term township and township-guaranteed debt
  outstanding: $59.5 million


UCFC FUNDING: S&P Corrects Rating on Class M-1 Notes to 'D'
-----------------------------------------------------------
Standard & Poor's Ratings Services corrected its rating on the
class M-1 notes from UCFC Funding Corp. Manufactured Housing
Contract Pass-Through Certificates Series 1998-3.  S&P corrected
the rating on the class M-1 notes to 'D' from 'CCC-'.

This transaction did not make the full interest payment on the
class M-1 notes on its March 15, 2010, distribution date.  Due to
an error, S&P's rating action on this class did not occur
contemporaneously with the interest payment shortfall.

                         Rating Corrected

         UCFC Funding Corp. Manufactured Housing Contract
                    Pass-Through Certificates
                          Series 1998-3

                                   Rating
                                   ------
                    Class       To        From
                    -----       --        ----
                    M-1         D         CCC-


VINACASA CLO: Moody's Upgrades Ratings on Four Classes of Notes
---------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Vinacasa CLO, Ltd.:

  -- US$477,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Notes Due 2015 (current balance of
     $328,503,607), Upgraded to Aa1; previously on August 24, 2009
     Downgraded to Aa2;

  -- US$33,975,000 Class A-2 Second Priority Senior Secured
     Floating Rate Notes Due 2015, Upgraded to A1; previously on
     August 24, 2009 Downgraded to A3;

  -- US$30,600,000 Class B Third Priority Mezzanine Secured
     Deferrable Floating Rate Notes Due 2015, Upgraded to Baa3;
     previously on August 24, 2009 Downgraded to Ba1;

  -- US$22,600,000 Class C Fourth Priority Mezzanine Secured
     Deferrable Floating Rate Notes Due 2015 (current balance of
     $23,757,096), Upgraded to B3; previously on August 24, 2009
     Downgraded to Caa1.

According to Moody's, the rating actions taken on the notes are a
result of deleveraging of the transaction and an improvement in
the credit quality of the underlying portfolio since the previous
rating action in August 2009.  In particular, the Class A-1 Notes
were paid a total of about $84 million since the previous rating
action, accounting for roughly 20% of the total Class A
outstanding balance reported in July 2009.  As a result of the
deleveraging and sales of defaulted securities at recoveries
higher than previously anticipated, the collateral coverage of the
notes has increased significantly.

Moody's also notes that as of June 2010, defaulted securities
total about $8.8 million, which is significantly less than the
$24.97 million of defaulted collateral reported in the July 2009
report.  Based on the same report, the weighted average rating
factor has also improved over the past year and is currently 3180
versus 3334 in July 2009.

Finally, Moody's noted that the portfolio includes a number of
investments in securities that mature after the maturity date of
the notes.  These investments potentially expose the notes to
market risk in the event of liquidation at the time of the notes'
maturity, which Moody's will continue to monitor.

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.

Vinacasa CLO, Ltd., issued in March 2008, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.


WACHOVIA BANK: Moody's Affirms Ratings on Nine 2004-C11 Certs.
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings of nine classes and
downgraded eleven classes of Wachovia Bank Commercial Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series 2004-
C11.  The downgrades are due to higher expected losses for the
pool resulting from anticipated losses from specially serviced and
highly leveraged watchlisted loans and concerns about refinancing
risk associated with loans approaching maturity in an adverse
lending environment.  Twenty-two loans, representing 20% of the
pool, mature within the next three years.  Five of these loans (8%
of the pool) have a Moody's stressed debt service coverage ratio
below 1.0X.  The affirmations are due to key rating parameters,
including Moody's loan-to-value ratio, Moody's stressed DSCR and
the Herfindahl Index, remaining within acceptable ranges.

On July 14, 2010, Moody's placed 11 classes of this transaction on
review for possible downgrade.  This action concludes Moody's
review of this transaction.  The rating action is the result of
Moody's on-going surveillance of commercial mortgage backed
securities transactions.

As of the July 17, 2010 statement date, the transaction's
aggregate certificate balance has decreased 13% to $905.1 million
from $1.04 billion at securitization.  The 54 mortgage loans that
collateralize these Certificates range in size from less than 1%
to 12% of the pool, with the top ten loans representing 31% of the
pool.  The pool contains three loans, representing 18% of the
pool, with investment grade underlying ratings.  A fourth loan,
representing 12% of the pool, formerly had an underlying rating
but due to declines in performance and increased leverage it is
now analyzed as part of the conduit pool.  Six loans, representing
16% of the pool, have defeased and are secured with U.S.
Government securities.

Thirteen loans, representing 25% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (formerly Commercial Mortgage Securities
Association) monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

No loans have been liquidated from the pool since securitization.
Three loans, representing 6% of the pool, are currently in special
servicing.  The largest specially serviced loan is the Bay City
Mall Loan, ($23.5 million, 2.6% of the pool), which is secured by
a 361,194 square foot enclosed regional shopping mall located in
Bay City, Michigan.  This loan was transferred to special
servicing April 2009 due to the GGP bankruptcy filing.  This loan
is included in a list of "special consideration properties" under
GGP's bankruptcy plan.  The proposal for these loans includes a
mechanism for the debtors and the lender to negotiate a
fundamental restructuring of the loan.  In addition, either party
can, under certain circumstances, call for delivery of the
property in satisfaction of the loan obligations.

The remaining two specially serviced loans are secured by two
multi-family properties.  Moody's estimates an aggregate
$14.4 million loss for the specially serviced loans, which
represents an overall 28% expected loss.  The special servicer has
recognized an aggregate $5.0 million appraisal reduction for one
of the specially serviced loans.

In addition to recognizing losses from specially serviced loans,
Moody's has assumed a high default probability on 13 watchlisted
loans, representing 25% of the pool, due to concerns about
declining property performance.  Moody's estimates a $10.0 million
aggregate loss for these troubled loans (overall 21% expected loss
based on a 50% probability of default).  Moody's rating action
recognizes potential uncertainty around the timing and magnitude
of loss from these troubled loans.

Moody's was provided with full year 2008 and 2009 operating
statements for 96% of the pool.  Moody's weighted average LTV for
the conduit pool, excluding specially serviced and troubled loans,
is 87% compared to 92% at last review.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCR is 1.17x compared to 1.28x at last review.
Moody's actual DSCR is based on Moody's net cash flow and the
loans' actual debt service.  Moody's stressed DSCR is based on
Moody's NCF and a 9.25% stressed rate applied to the loan balance.

Moody's uses a variation of Herf to measure loan size diversity,
where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple-notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has an all-in Herf of 16 compared to 17 at last review.

There are three loans with underlying ratings.  The largest loan
is the Four Seasons Town Center Loan ($84.9 million -- 9.4% of
the pool), which is secured by the borrower's interest in a
1.1 million square foot regional mall located in Greensboro, North
Carolina.  JC Penney, Dillard's and Belk anchor this center.  As
of December 2009, the property was 94% leased, similar to Moody's
last review.  Financial performance has been stable and the loan
has benefited from 5% amortization since last review.  Moody's
current underlying rating and stressed DSCR are A3 and 1.54X,
respectively, compared to A3 and 1.42X at last review.

The second largest loan with an underlying rating is the Starrett-
Lehigh Building Loan ($55.1 million -- 6.1% of the pool), which is
secured by the borrower's interest in the fee and leasehold
interest in a 2.3 million square foot office building located in
New York, New York.  Performance has improved since last review
due to higher occupancy.  Moody's current underlying rating and
stressed DSCR are Aa2 and >4.0X, respectively, the same as last
review.

The third largest loan with an underlying rating is the University
Mall Loan ($18.1 million -- 2.0% of the pool), which is secured by
a single level enclosed regional shopping mall located in
Tuscaloosa, Alabama.  JC Penney, Belk and Sears anchor this
650,000 square foot mall.  Moody's current underlying rating and
stressed DSCR are Aa3 and 1.85X, respectively, compared to Aa3 and
1.88X at last review.

The loan that previously had an underlying rating is the Brass
Mill Center and Commons Loan ($110.4 million -- 12.2% of the
pool), which is secured by the borrower's interest in a
1.2 million square foot regional mall and adjacent 197,000 square
foot community center.  The properties are located approximately
28 miles southwest of Hartford in Waterbury, Connecticut.  Sears,
Macy's, JC Penney and Burlington Coat Factory anchor the mall.
The in-line mall stores were 88% leased as of year-end 2009
compared to 91% at last review.  The loan has a 25-year
amortization schedule and has amortized 15% since securitization.
Despite the benefits of amortization, both occupancy and financial
performance have declined since last review.  Moody's LTV and DSCR
are 90% and 1.08x, respectively, compared to 76% and 1.31X at last
review.

The top three conduit loans represent 17.1% of the pool.  The
largest conduit loan is the Bank of America Tower Loan
($71.1 million -- 7.9% of the pool), which is secured by a 661,000
square foot Class A office building and 36,000 square foot annex
building in Jacksonville, Florida.  Performance has declined since
last review due to a decline in overall occupancy from 87% at last
review to 80% as of year-end 2009.  Moody's LTV and DSCR are 94%
and 1.10X, respectively, compared to 91% and 1.13X at last review.

The second largest conduit loan is the Westland Mall Loan
($55.8 million -- 6.2% of the pool), which is secured by the
borrower's interest in a 835,000 square foot regional mall located
approximately five miles north of the Miami International Airport
in Hialeah, Florida.  Macy's, Sears and JC Penney anchor this
center.  Occupancy levels have remained consistent since last
review at 94%.  Moody's LTV and stressed DSCR are 73% and 1.29X,
respectively, compared to 81% and 1.26X at last review.

The third largest conduit loan is the Amargosa Commons Shopping
Center Loan ($28.0 million -- 3.1% of the pool), which is secured
by a power center located in Palmdale, California.  The largest
tenants include Bed Bath & Beyond, TJ Maxx, Petsmart and Trader
Joe's.  Property performance has declined due to the loss of
Circuit City, which formerly leased 19% of the center.  The center
was 73% leased as of March 2010 compared to 92% on December 2008.
The loan is on the servicer's watchlist due to the decline in
occupancy and DSCR.  Moody's is concerned that this loan has a
high probability of default due to poor performance.  Moody's LTV
and DSCR are 148% and 0.64X, respectively, compared to 104% and
0.91X at last review.

Moody's rating action is:

  -- Cl. X-C Certificate, Affirmed at Aaa (sf); previously on May
     10, 2004 Definitive Rating Assigned Aaa (sf)

  -- Cl. X-P Certificate, Affirmed at Aaa (sf); previously on May
     10, 2004 Definitive Rating Assigned Aaa (sf)

  -- US$2.225M Cl. A-2 Certificate, Affirmed at Aaa (sf);
     previously on May 10, 2004 Definitive Rating Assigned Aaa
     (sf)

  -- US$87.715M Cl. A-3 Certificate, Affirmed at Aaa (sf);
     previously on May 10, 2004 Definitive Rating Assigned Aaa
     (sf)

  -- US$52.829M Cl. A-4 Certificate, Affirmed at Aaa (sf);
     previously on May 10, 2004 Definitive Rating Assigned Aaa
     (sf)

  -- US$454.9M Cl. A-5 Certificate, Affirmed at Aaa (sf);
     previously on May 10, 2004 Definitive Rating Assigned Aaa
     (sf)

  -- US$148.566M Cl. A-1A Certificate, Affirmed at Aaa (sf);
     previously on May 10, 2004 Definitive Rating Assigned Aaa
     (sf)

  -- US$28.641M Cl. B Certificate, Affirmed at Aaa (sf);
     previously on Oct. 9, 2008 Upgraded to Aaa (sf)

  -- US$13.018M Cl. C Certificate, Affirmed at Aa2 (sf);
     previously on Oct. 9, 2008 Upgraded to Aa2 (sf)

  -- US$23.434M Cl. D Certificate, Downgraded to A3 (sf);
     previously on July 14, 2010 A2 (sf) Placed Under Review for
     Possible Downgrade

  -- US$11.717M Cl. E Certificate, Downgraded to Baa1 (sf);
     previously on July 14, 2010 A3 (sf) Placed Under Review for
     Possible Downgrade

  -- US$14.32M Cl. F Certificate, Downgraded to Baa2 (sf);
     previously on July 14, 2010 Baa1 (sf) Placed Under Review for
     Possible Downgrade

  -- US$13.019M Cl. G Certificate, Downgraded to Ba1 (sf);
     previously on July 14, 2010 Baa2 (sf) Placed Under Review for
     Possible Downgrade

  -- US$10.415M Cl. H Certificate, Downgraded to B1 (sf);
     previously on July 14, 2010 Baa3 (sf) Placed Under Review for
     Possible Downgrade

  -- US$16.924M Cl. J Certificate, Downgraded to Caa3 (sf);
     previously on July 14, 2010 Ba1 (sf) Placed Under Review for
     Possible Downgrade

  -- US$5.207M Cl. K Certificate, Downgraded to Ca (sf);
     previously on July 14, 2010 Ba2 (sf) Placed Under Review for
     Possible Downgrade

  -- US$2.604M Cl. L Certificate, Downgraded to Ca (sf);
     previously on July 14, 2010 Ba3 (sf) Placed Under Review for
     Possible Downgrade

  -- US$2.604M Cl. M Certificate, Downgraded to C (sf); previously
     on July 14, 2010 B1 (sf) Placed Under Review for Possible
     Downgrade

  -- US$2.603M Cl. N Certificate, Downgraded to C (sf); previously
     on July 14, 2010 B2 (sf) Placed Under Review for Possible
     Downgrade

  -- US$2.604M Cl. O Certificate, Downgraded to C (sf); previously
     on July 14, 2010 B3 (sf) Placed Under Review for Possible
     Downgrade


WEIRTON MUNICIPAL: Fitch Downgrades Ratings on 2001A Bonds to 'BB'
------------------------------------------------------------------
Fitch Ratings has downgraded approximately $7.055 million of
Weirton Municipal Hospital Building Commission's hospital revenue
bonds series 2001A to 'BB' from 'BB+'.  The bonds were issued on
behalf of Weirton Medical Center.  Fitch does not rate
approximately $14 million of series 2001B adjustable-rate demand
hospital revenue bonds which are supported by a PNC Bank letter of
credit, nor the $4.8 million series 2005A fixed-rate bonds.  Fitch
has also revised the Rating Outlook to Negative from Stable.

Rating Rationale:

  -- The downgrade and Negative Outlook are primarily based on
     continued operating losses of $4.2 million (negative 4.8%
     operating margin and negative 0.7% operating EBITDA margin)
     through the 11-month interim period ended May 31, 2010.
     Management anticipates improvements in fiscal 2011, although
     still expects an operating loss.

  -- WMC failed to meet its debt service coverage covenant in the
     bank reimbursement agreement at June 30, 2009 and has failed
     to meet it each quarter subsequently.  WMC was granted a
     waiver by the bank through March 2010 and is currently in
     negotiations to extend the waiver.

  -- Inpatient volumes, which had mild year over year declines
     between fiscal 2007 and 2009, have significantly deteriorated
     through the interim period, declining nearly 12% on a like-
     for-like basis (not including discontinued services) and 17%
     overall.  However, certain outpatient services have seen
     modest increases.

  -- Approximately 54% of WMC's outstanding debt consists of VRDBs
     backed by a one-year letter of credit, which exposes them to
     put, renewal, and counterparty risk.

  -- WMC's liquidity is the primary credit strength.  At May 31,
     2010, unrestricted cash and investments measured
     $35.6 million, equating to 152 days cash on hand, 12 times
     cushion ratio, and 138.5% cash to debt, all of which compare
     well to investment grade level credits.

What May Trigger A Downgrade?

  -- The Board of Directors has hired Quorum Health Resources for
     a two-year engagement to implement a turnaround plan
     effective May 2010, which Fitch views favorably.  QHR's
     inabilty to implement the turnaround plan and meet budgeted
     goals could lead to further negative action.  Crucial to this
     effort will be favorable managed care contract negotiations
     as current rates are insufficient to support profitability.

  -- Continued deterioration of inpatient volumes, such that they
     outpace management's ability to control costs.

  -- WMC's one-year letter of credit on its variable-rate
     debt is not renewed, or WMC fails to continue to secure
     waivers for its ongoing debt service coverage covenant
     violations.

Security:

  -- Debt payments are secured by a pledge of gross revenues and a
     debt service reserve fund.  The series 2001 bonds are also
     secured by a first mortgage lien.

Credit Summary:

The downgrade and Negative Outlook are largely based on WMC's
continued operating losses and the expectation for further losses
in the near term.  Through the 11-month interim period, WMC posted
an operating loss of $4.2 million (negative 4.8% operating margin
and negative 0.7% operating EBITDA margin).  This compares with an
operating loss of $3.5 million in fiscal 2009 (negative 3.6% and
positive 1%, respectively).  Fiscal 2010 will mark the ninth
consecutive year that WMC has reported negative income from
operations.  The weaker results have occurred in spite of
continued expense and wage reductions (staffing was reduced by 42
FTEs in January 2009 plus another 19 as of January 2010), and
revenue cycle initiatives.  Driving the operating loss is
significantly lower inpatient volumes and poor reimbursement rates
from managed care providers (coupled with poor coding on the
hospital's side), which have resulted in an 8% decrease in total
operating revenue year over year.

The board of directors brought in an interim CFO from QHR in
November 2009 and then signed a two-year turnaround engagement
effective May 1, 2010.  Fitch views the engagement with QHR
favorably.  QHR operates 150 community hospitals across the
country and has significant experience working with financially
stressed hospitals similar to WMC.  As part of the engagement, QHR
has brought on a COO, interim CNO, and additional consultants in
order to evaluate and revamp revenue cycle management, payor
contracts, human resources, labor negotiations, and case
management.  In fiscal 2011, management is budgeting for an
improvement in operating performance, although still an operating
loss.  Fiscal 2012 is expected to be breakeven at a minimum.

At the end of fiscal 2009, WMC was not in compliance with its debt
service coverage covenant of 1.5x as defined in the bank
reimbursement agreement associated with the series 2001B bonds.
It received a waiver for the violation through March 2010.  At the
end of March, WMC was again not in compliance with the covenant
and is seeking an additional waiver.  This ratio is tested
quarterly and management noted that they will likely not be able
to meet this requirement for at least several quarters.

Additional credit concerns include deteriorating inpatient
volumes, WMC's variable rate debt exposure, poor service area
characteristics, and high average age of plant.  Inpatient
admissions declined 1.8%, 0.8%, and 2.9% between fiscal years
2006-07, 2007-08, and 2008-09.  Through the interim period,
admissions declined drastically, falling 16.6% year over year or
11.7% not including inpatient psychiatry which was discontinued in
the first quarter of 2010.  Management attributed the decline to
generally lower volumes across the area and certain operational
issues.  However, certain outpatient services have seen increased
demand year over year, including surgeries and physical therapy
which are up 4.3% and 20.3%, respectively.

Approximately 54% of WMC's outstanding debt is in variable rate
demand bonds backed by a one-year letter of credit from WesBanco
and United Bank which are wrapped by PNC Bank.  This structure
exposes WMC to renewal, put, and counterparty risk.  The LOC
expires in January 2011 and carries a yearly renewal option.
Continuation of the banks support is key to maintaining the
current rating level.  Should the banks decide not to renew, WMC
does have adequate liquidity to repay an accelerated amortization
of the debt.

WMC's service area can be characterized by socioeconomic
indicators generally worse than US averages, as well as high
unemployment rates within the metropolitan statistical area,
ranging from 12.4% to 13.4%.  These factors present significant
challenges from a reimbursement standpoint as self-pay and
Medicaid represents roughly 9% and 13% of gross revenues,
respectively, while Medicare accounts for an additional 45%.  Bad
debt as a percentage of revenue is also high, hovering near 11%.

The primary credit strength for WMC is its liquidity position
which provides a cushion while WMC works to turnaround operations
and sufficiently covers put risk.  Unrestricted cash and
investments stood at $35.6 million at May 31, 2010, up from
$32.6 million at June 30, 2009.  These funds equate to 152 days
cash on hand, a 12x cushion ratio, and 138.5% cash to debt, all of
which are characteristic of an investment grade credit.  The
liquidity cushion has historically helped to offset operating
losses, although it has likely been maintained at such a high
level as a result of a deferral of capital projects as
demonstrated by the very high average age of plant.  Also
concerning is WMC's asset allocation which is held almost entirely
in equities (69% within mutual funds and 28.5% in common stocks as
of June 30, 2009).

WMC is a 238-bed acute care hospital located in Weirton, WV,
approximately 35 miles west of downtown Pittsburgh.  The hospital
had total revenues of $97 million in fiscal 2009 and $86.6 million
through the interim period.  WMC covenants to provide annual and
quarterly disclosure to bondholders; however, quarterly disclosure
is not done through the NRMSIRS.  Weirton is not party to any swap
transactions.


* Moody's Takes ABCP Rating Actions Ending August 2, 2010
---------------------------------------------------------
Moody's ABCP rating actions for the seven-day period ended
August 2, 2010.

The ratings of these ABCP Programs were affirmed at Prime-1 during
the period July 27, 2010, through August 2, 2010:

            WESTLB'S Compass Amends Liquidity Structure

Compass Securitization LLC/Compass Securitisation Ltd, a
previously partially supported, multiseller ABCP programme
sponsored and administered by WestLB AG (rated A3/Prime-1/E+), has
amended the liquidity facility structure such that all
transactions in the portfolio are now fully support.  Compass'
programme-level credit enhancement, which was previously in the
form of a letter of credit provided by WestLB AG, London Branch in
favor of Compass Holdings Ltd, has been cancelled.  Under the
amended structure, the liquidity facility covers, among other
things, transaction costs and the administrator continues to be
responsible for ensuring proper hedge arrangements exist to fully
protect Compass.  The potential losses arising from transaction
costs or from unhedged exposures are covered by an indemnity
provided by the administrator on a same day basis in case the
liquidity coverage should be insufficient.  Moody's rating
affirmation is based on the structural features of the liquidity
agreement and other programme documents and the Prime-1 rating of
WestLB as liquidity facility provider.

As part of the amendments, a collateral agreement under which
WestLB must post collateral under certain conditions has been
implemented.  Although this agreement is beneficial to CP
investors, Moody's rating does not rely on this arrangement.

Compass is authorized to issue up to US$3.5 billion of ABCP and
has no programme-level credit enhancement.

   Deutsche Banks' Rhein-Main Adds EUR90 Million Note Facility

Rhein-Main Securitisation Limited, a partially supported,
multiseller ABCP conduit sponsored by Deutsche Bank AG (Aa3/Prime-
1/C+), has added a GBP 100 million multi-currency variable funding
note to its portfolio.

The transaction is backed by equipment lease receivables for
middle-market and end-users originated by two UK based
subsidiaries of a global commercial finance company.  This
transaction is fully supported by a liquidity facility provided by
Prime-1 rated Deutsche Bank.  The liquidity facility is sized at
103% of the maximum amount (GBP103 million).

Rhein-Main is authorised to issue up to approximately
EUR3.1 billion of ABCP and its program-level credit enhancements
remains at EUR425 million.

These ABCP Program was placed under review for possible downgrade
during the period July 27, 2010, through August 2, 2010:

* Suntrust Bank's Three Pillars Funding Llc Placed On Review For
  Possible Downgrade


* S&P Affirms Ratings on Eight Classes From Seven NIMS RMBS Deals
-----------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on eight
classes from seven U.S. net interest margin securities residential
mortgage-backed securities transactions issued between 2005 and
2007.  Radian Insurance Inc. ('B+') insures all of the classes in
this review.   Assured Guaranty Municipal Corp. ('AAA') also
provides a backup note insurance policy on the notes from Option
One Mortgage Securities III Corp. Re-NIM Trust 2007-1 Series 2007-
1.

The affirmations reflect the higher of the rating on the related
bond insurer and Standard & Poor's underlying rating on the
securities.  During this review, S&P applied the performance tests
described in "Standard & Poor's Surveillance Methodology For U.S.
RMBS Net Interest Margin Securities," published March 17, 2009.
S&P analyzed whether each NIM is receiving what S&P views to be
sufficient cash flows to make appropriate payments of applicable
interest and principal due to the NIMS holders.

Standard & Poor's will continue to monitor NIMS as applicable and
may further adjust the ratings as S&P deem appropriate in
accordance with S&P's criteria.

                         Ratings Affirmed

            Long Beach Asset Holdings Corp. CI 2006-WL2
                          Series 2006-WL2

                  Class      CUSIP         Rating
                  -----      -----         ------
                  N-2        54240KAB8     B+

   OPTION ONE Mortgage Securities III Corp. RE-NIM TRUST 2007-1
                           Series 2007-1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  NOTES      68402UAA2     AAA

                     Park Place NIM 2005-WHQN2
                         Series 2005-WHQN2

                  Class      CUSIP         Rating
                  -----      -----         ------
                  B          70070AAB1     B+

                WM Asset Holdings Corp. CI 2006-10
                          Series 2006-10

                  Class      CUSIP         Rating
                  -----      -----         ------
                  N-2 Notes  929306AB4     B+

                WM Asset Holdings Corp. CI 2006-11
                          Series 2006-11

                  Class      CUSIP         Rating
                  -----      -----         ------
                  N-2 Notes  92933KAB0     B+

                WM Asset Holdings Corp. CI 2007-WM1
                         Series 2007-WM1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  N-2 Notes  92933UAB8     B+

                WM Asset Holdings Corp. CI 2007-WM2
                          Series 2007-WM2

                  Class      CUSIP         Rating
                  -----      -----         ------
                  N-1 Notes  92933VAA8     B+
                  N-3 Notes  92933VAC4     B+


* S&P Cuts Ratings on 17 Classes From Eight RMBS Transactions
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 17
classes from eight residential mortgage-backed securities
transactions backed by U.S. subprime, closed-end second-lien, and
home equity line of credit mortgage loan collateral issued between
1997 and 2007.  S&P removed all of the lowered ratings from
CreditWatch with negative implications.  In addition, S&P affirmed
its ratings on 84 classes from four of the downgraded
transactions, as well as 44 other transactions, and removed 44 of
the affirmed ratings from CreditWatch negative.

Standard & Poor's has established loss projections for all closed-
end second-lien and HELOC transactions rated in 2005, 2006, and
2007.  S&P changed its lifetime projected losses for these
transactions:

                                   Orig. bal.      Lifetime
    Transaction                    (mil. $)        exp. loss (%)
    -----------                    ----------      -------------
    Macquarie Mortgage              480             5.19
    Funding Trust 2007-1
    Lehman ABS Corp.                269             5.54
    Home Equity Loan Trust 2005-1

The downgrades reflect S&P's opinion that projected credit support
for the affected classes is insufficient to maintain the previous
ratings, given its current projected losses.  Classes that are
backed by a bond insurance policy reflect ratings that are the
higher of (i) the rating on the bond insurer, and (ii) Standard &
Poor's underlying rating on the security.

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

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

A combination of subordination, excess spread,
overcollateralization, and bond insurance provide credit support
for the affected transactions.  The underlying collateral for the
HELOC and closed-end second-lien transactions consists of HELOC
and second-lien fixed- and adjustable-rate negative amortization
mortgage loans secured by one- to four-family residential
properties.  The underlying collateral for the subprime
transaction consists of fixed- and adjustable-rate mortgage
assets, including mortgage loans, building and installment sale
contracts, promissory notes, and related mortgages on
standardized, partially-finished, detached, single-family
residential homes.

                          Rating Actions

                  Citigroup HELOC Trust 2006-NCB1
                       Series      2006-NCB1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1A-1       172978AA6     BB+                  BBB+/Watch Neg
    2A-1       172978AB4     BBB+                 BBB+/Watch Neg
    2A-2       172978AC2     BBB+                 BBB+/Watch Neg
    2A-3       172978AD0     B                    BBB+/Watch Neg

                        CWABS Master Trust
                        Series      2003-E

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    Notes      126671B21     BBB-                 BBB-/Watch Neg

                        CWABS Master Trust
                        Series      2004-A

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    Notes      1266712S4     B                    B/Watch Neg

       CWABS Revolving Home Equity Loan Trust Series 2004-E
                        Series      2004-E

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    2-A        126673BV3     BBB-                 BBB-/Watch Neg

       CWABS Revolving Home Equity Loan Trust Series 2004-J
                        Series      2004-J

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        126673HB1     BB                   BB/Watch Neg
    2-A        126673HC9     BB                   BB/Watch Neg

      CWABS Revolving Home Equity Loan Trust Series 2004-K
                        Series      2004-K

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    2-A        126673KG6     B                    B/Watch Neg

      CWABS Revolving Home Equity Loan Trust Series 2004-L
                        Series      2004-L

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        126673KP6     BBB                  BBB/Watch Neg
    2-A        126673KQ4     B                    B/Watch Neg

      CWABS Revolving Home Equity Loan Trust Series 2004-M
                        Series      2004-M

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        126673KK7     BBB                  BBB/Watch Neg

      CWABS Revolving Home Equity Loan Trust Series 2004-O
                        Series      2004-O

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        126673KR2     BBB                  BBB/Watch Neg
    2-A        126673KS0     BB                   BB/Watch Neg

      CWABS Revolving Home Equity Loan Trust Series 2004-Q
                        Series      2004-Q

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        126673MX7     BBB                  BBB/Watch Neg
    2-A        126673MY5     BBB                  BBB/Watch Neg

      CWABS Revolving Home Equity Loan Trust, Series 2004-D
                        Series      2004-D

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        126673BW1     B                    B/Watch Neg
    2-A        126673BX9     B                    B/Watch Neg

      CWABS Revolving Home Equity Loan Trust, Series 2004-G
                        Series      2004-G

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        126673AS1     BB                   BB/Watch Neg
    2-A        126673AT9     B-                   B/Watch Neg

      CWABS Revolving Home Equity Loan Trust, Series 2004-T
                        Series      2004-T

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    2-A        126673TP7     A-                   A-/Watch Neg

      CWHEQ Revolving Home Equity Loan Trust Series 2005-G
                        Series      2005-G

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        126685AL0     BBB                  BBB/Watch Neg

      CWHEQ Revolving Home Equity Loan Trust, Series 2005-H
                        Series      2005-H

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    1-A        126685AN6     BBB+                 BBB+/Watch Neg

                 First Horizon ABS Trust 2004-HE1
                       Series      2004-HE1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    Notes      320515AA7     BBB+                 BBB+/Watch Neg

                 First Horizon ABS Trust 2004-HE2
                       Series      2004-HE2

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    Notes      320514AA0     A                    A/Watch Neg

                 First Horizon ABS Trust 2004-HE3
                       Series      2004-HE3

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    Notes      320514AB8     BB                   BB/Watch Neg

                 First Horizon ABS Trust 2006-HE1
                       Series      2006-HE1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    Notes      32051GZ73     BBB                  BBB/Watch Neg

              GMACM Home Equity Loan Trust 2001-HE2
                       Series      2001-HE2

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    I-A-1      361856BH9     BBB                  BBB/Watch Neg
    I-A-2      361856BJ5     BBB                  BBB/Watch Neg
    II-A-7     361856BG1     BBB                  BBB/Watch Neg

              GMACM Home Equity Loan Trust 2002-HE1
                       Series      2002-HE1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-1        361856BT3     BBB                  BBB/Watch Neg
    A-2        361856BU0     BBB                  BBB/Watch Neg

              GMACM Home Equity Loan Trust 2003-HE1
                       Series      2003-HE1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-3        361856CK1     BBB                  BBB/Watch Neg

              GMACM Home Equity Loan Trust 2004-HE5
                       Series      2004-HE5

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-5        361856DX2     BBB                  BBB/Watch Neg
    A-6        361856DY0     BBB                  BBB/Watch Neg

             GreenPoint Home Equity Loan Trust 2004-1
                        Series      2004-1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A          395385AQ0     BBB+                 BBB+/Watch Neg

             Greenpoint Home Equity Loan Trust 2004-4
                        Series      2004-4

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A          395385AZ0     B                    BBB/Watch Neg

                  Home Equity Loan Trust 2003-HS4
                       Series      2003-HS4

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A-I-A      76110VPK8     BBB+                 BBB+/Watch Neg
    A-I-B      76110VPL6     BBB+                 BBB+/Watch Neg

                  Home Equity Loan Trust 2004-HS3
                       Series      2004-HS3

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A          76110VQY7     BBB                  BBB/Watch Neg

                Irwin Home Equity Loan Trust 2004-1
                        Series      2004-1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    IA-1       464126CG4     A-                   A-/Watch Neg

                Irwin Home Equity Loan Trust 2006-2
                        Series      2006-2

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    IA-1       46412QAA5     A-                   A/Watch Neg
    IIA-1      46412QAB3     BBB+                 BBB+/Watch Neg
    IIA-2      46412QAC1     BBB+                 BBB+/Watch Neg
    IIA-3      46412QAD9     B-                   BBB+/Watch Neg
    IIA-4      46412QAE7     B+                   BBB+/Watch Neg
    VFN        46412Q9A7     A-                   A/Watch Neg

               Irwin Home Equity Loan Trust 2006-3
                        Series      2006-3

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    I-A        464125AA1     BBB+                 BBB+/Watch Neg
    II-A-1     464125AB9     BBB+                 BBB+/Watch Neg
    II-A-2     464125AC7     BBB-                 BBB+/Watch Neg
    II-A-3     464125AD5     CCC                  BBB+/Watch Neg
    II-A-4     464125AE3     CCC                  BBB+/Watch Neg
    VFN        4641259A3     BBB+                 BBB+/Watch Neg

               Irwin Home Equity Loan Trust 2006-P1
                        Series      2006-P1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    I-A        46412AAA0     CC                   B/Watch Neg
    II-A-2     46412AAC6     CC                   BB/Watch Neg
    II-A-3     46412AAD4     CC                   BB/Watch Neg
    II-A-4     46412AAE2     CC                   BB/Watch Neg

                          Lehman ABS Corp.
                         Series      2004-2

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A          525170BZ8     A                    A/Watch Neg

      Lehman ABS Corporation Home Equity Loan Trust 2005-1
                        Series      2005-1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A          525170CG9     CCC                  B/Watch Neg

    Wachovia Asset Securitization Issuance LLC 2004-HE1 Trust
                       Series      2004-HE1

                                     Rating
                                     ------
    Class      CUSIP         To                   From
    -----      -----         --                   ----
    A          92975NAA5     BB+                  BBB/Watch Neg

                         Ratings Affirmed

                        CWABS Master Trust
                        Series      2004-C

                  Class      CUSIP         Rating
                  -----      -----         ------
                  Notes      1266715Y8     CCC

                        CWABS Master Trust
                        Series      2004-B

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        1266715W2     CCC

       CWABS Revolving Home Equity Loan Trust Series 2004-E
                        Series      2004-E

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        126673BU5     CCC

       CWABS Revolving Home Equity Loan Trust Series 2004-K
                        Series      2004-K

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        126673KF8     CCC

       CWABS Revolving Home Equity Loan Trust Series 2004-M
                        Series      2004-M

                  Class      CUSIP         Rating
                  -----      -----         ------
                  2-A        126673KL5     CCC

       CWABS Revolving Home Equity Loan Trust Series 2004-N
                        Series      2004-N

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        126673KM3     CCC
                  2-A        126673KN1     CCC

      CWABS Revolving Home Equity Loan Trust, Series 2004-F
                        Series      2004-F

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        126673BS0     CCC
                  2-A        126673BT8     CCC

       CWABS Revolving Home Equity Loan Trust, Series 2004-I
                        Series      2004-I

                  Class      CUSIP         Rating
                  -----      -----         ------
                  Notes      126673FH0     BB+

       CWABS Revolving Home Equity Loan Trust, Series 2004-P
                        Series      2004-P

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        126673LL4     BB+
                  2-A        126673LM2     BB+

      CWABS Revolving Home Equity Loan Trust, Series 2004-S
                        Series      2004-S

                  Class      CUSIP         Rating
                  -----      -----         ------
                  Notes      126673QR6     CCC

       CWABS Revolving Home Equity Loan Trust, Series 2004-T
                        Series      2004-T

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        126673TN2     CCC

       CWHEQ Revolving Home Equity Loan Trust Series 2005-A
                        Series      2005-A

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        761545AC6     BB+
                  2-A        761545AD4     BB+

       CWHEQ Revolving Home Equity Loan Trust Series 2005-G
                        Series      2005-G

                  Class      CUSIP         Rating
                  -----      -----         ------
                  2-A        126685AM8     CCC

      CWHEQ Revolving Home Equity Loan Trust, Series 2005-C
                        Series      2005-C

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        126685AC0     AAA
                  2-A        126685AD8     AAA

       CWHEQ Revolving Home Equity Loan Trust, Series 2005-F
                              Series

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        126685AJ5     CCC

       CWHEQ Revolving Home Equity Loan Trust, Series 2005-H
                        Series      2005-H

                  Class      CUSIP         Rating
                  -----      -----         ------
                  2-A        126685AP1     CCC

       CWHEQ Revolving Home Equity Loan Trust, Series 2005-L
                        Series      2005-L

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A          126685BA3     CCC

       CWHEQ Revolving Home Equity Loan Trust, Series 2006-F
                        Series      2006-F

                  Class      CUSIP         Rating
                  -----      -----         ------
                  1-A        23242LAA1     AAA
                  2-A-1A     23242LAB9     AAA
                  2-A-1B     23242LAC7     AAA
                  3-A        23242LAD5     AAA

                  First Horizon ABS Trust 2006-HE2
                        Series      2006-HE2

                  Class      CUSIP         Rating
                  -----      -----         ------
                  Notes      32052XAA5     AAA

                  First Horizon ABS Trust 2007-HE1
                        Series      2007-HE1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  Notes      32053JAA5     AAA

                Flagstar Home Equity Loan Trust 2005-1
                        Series      2005-1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  Notes      33848DAA6     AAA

                 Home Equity Loan Trust 2006-HSA3
                        Series      2006-HSA3

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A          76113JAA0     AAA
                  VFN        76113J9A2     AAA

               Irwin Home Equity Loan Trust 2004-1
                        Series      2004-1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  IIA-1      464126CH2     AAA
                  IIM-1      464126CJ8     AA
                  IIM-2      464126CK5     A
                  IIB-1      464126CL3     BBB

             Macquarie Mortgage Funding Trust 2007-1
                        Series      2007-1

                  Class      CUSIP         Rating
                  -----      -----         ------
                  Notes      556083AA1     AAA

                        Mid-State Trust VI
                              Series

                  Class      CUSIP         Rating
                  -----      -----         ------
                  A-1        59549NAA1     AAA
                  A-2        59549NAB9     AA+
                  A-3        59549NAC7     AA
                  A-4        59549NAD5     BBB


* S&P Downgrades Ratings on 49 Classes From 16 RMBS Transactions
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 49
classes from 16 U.S. residential mortgage-backed securities
transactions backed primarily by scratch-and-dent mortgage loan
collateral issued in 2003-2007.  Additionally, S&P affirmed its
ratings on 69 classes from 12 of the downgraded transactions, as
well as 15 additional transactions.

The "scratch-and-dent" collateral backing these transactions
originally consisted predominantly of outside-the-guidelines and
document-deficient first-lien, fixed- and adjustable-rate,
residential mortgage loans secured by one- to four-family
properties.

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

S&P derived its loss assumptions using its criteria listed in the
"Related Criteria And Research" section below.  As part of S&P's
analysis, S&P considered the characteristics of the underlying
mortgage collateral, as well as macroeconomic influences.  For
example, the risk profile of the underlying mortgage pools
influences S&P's default projections, while its outlook for
housing-price declines and the health of the housing market
influence its loss severity assumptions.  Furthermore, S&P
adjusted its loss expectations for each deal based on upward
trends in delinquencies.

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

The lowered ratings reflect S&P's belief that the amount of credit
enhancement available for the downgraded classes is not sufficient
to cover losses at the previous rating levels, given S&P's current
projected losses, due to increased delinquencies.  The
affirmations reflect S&P's belief that there is sufficient credit
enhancement to support the ratings at their current levels.
Certain senior classes also benefit from senior-support classes
that would provide support to a certain extent before any
applicable losses could affect the super-senior certificates.  The
subordination of classes within each structure provides credit
support for the affected transactions.

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

                          Rating Actions

        Bear Stearns Asset Backed Securities Trust 2003-1
                        Series      2003-1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        07384YHA7     BB                   AA
        M-2        07384YHB5     CCC                  A
        B          07384YHC3     CC                   CCC

        Bear Stearns Asset Backed Securities Trust 2005-1
                        Series      2005-1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-2        073877AW2     B-                   A
        M-3        073877AX0     CCC                  BB
        M-4        073877AY8     CC                   B
        M-5        073877AZ5     CC                   CCC
        M-6        073877BA9     CC                   CCC

        Bear Stearns Asset Backed Securities Trust 2007-SD3
                       Series      2007-SD3

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A          07387LAA9     CCC                  B
        M-1        07387LAB7     CC                   CCC
        M-2        07387LAC5     CC                   CCC

                GMACM Mortgage Loan Trust 2003-GH1
                       Series      2003-GH1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        B          36185NXU9     B-                   BBB

                GMACM Mortgage Loan Trust 2004-GH1
                       Series      2004-GH1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        B          36185HEE9     CC                   CCC

                      GSAMP Trust 2005-SEA2
                      Series      2005-SEA2

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-2        362341TQ2     BBB-                 AA-
        B-1        362341TR0     B-                   BBB
        B-2        362341TS8     B-                   B

                      Quest Trust 2004-X1
                      Series      2004-X1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-1        03072SPT6     CC                   CCC

                      Quest Trust 2004-X2
                      Series      2004-X2

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-3        03072SSY2     B-                   BB
        M-4        03072SSZ9     CC                   CCC

                      Quest Trust 2006-X1
                      Series      2006-X1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-2        748351AR4     CCC                  B
        A-3        748351AS2     CCC                  B
        M-1        748351AT0     CC                   CCC
        M-2        748351AU7     CC                   CCC

                      RAMP Series 2003-RS11 Trust
                      Series      2003-RS11

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-I-2      760985K59     BB-                  A
        M-I-3      760985K67     CC                   B
        M-II-2     760985L25     CCC                  A
        M-II-3     760985L33     CC                   CCC

                    RAMP Series 2003-RS4 Trust
                       Series      2003-RS4

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-I-5      760985UR0     B-                   B
        A-I-6      760985US8     B-                   B
        A-II-A     760985UT6     B-                   B
        A-II-B     760985UU3     B-                   B

                    RAMP Series 2003-RS5 Trust
                       Series      2003-RS5

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-I-6      760985WZ0     CC                   CCC

                    RAMP Series 2003-RS6 Trust
                       Series      2003-RS6

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-I-5      760985XK2     B-                   BBB
        A-I-6      760985XL0     B-                   BBB
        A-II-A     760985XM8     B-                   BB
        A-II-B     760985XN6     B-                   BB

                    RAMP Series 2003-RS9 Trust
                       Series      2003-RS9

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-I-3      760985B26     CC                   CCC
        M-II-1     760985B34     B+                   AA
        M-II-3     760985B59     CC                   CCC

                    RAMP Series 2004-RS1 Trust
                       Series      2004-RS1

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        M-I-1      760985N49     A+                   AA
        M-I-2      760985N56     CCC                  A
        M-I-3      760985N64     CC                   CCC
        M-II-1     760985N80     BBB-                 A
        M-II-2     760985N98     CC                   BB
        M-II-3     760985P21     CC                   B

                    RAMP Series 2004-RS7 Trust
                       Series      2004-RS7

                                         Rating
                                         ------
        Class      CUSIP         To                   From
        -----      -----         --                   ----
        A-I-4      7609857D7     CC                   CCC
        A-I-5      7609857E5     CC                   CCC
        A-I-6      7609857F2     CC                   CCC
        A-III      7609857K1     CC                   B

                         Ratings Affirmed

        Bear Stearns Asset Backed Securities Trust 2003-1
                        Series      2003-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        07384YGX8     AAA
                 A-2        07384YGY6     AAA

        Bear Stearns Asset Backed Securities Trust 2005-1
                        Series      2005-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        073877AV4     AA

                GMACM Mortgage Loan Trust 2003-GH1
                       Series      2003-GH1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-5        36185NXR6     AAA
                 M-1        36185NXS4     AA
                 M-2        36185NXT2     A

                GMACM Mortgage Loan Trust 2003-GH2
                       Series      2003-GH2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-4        36185NQ60     AAA
                 M-1        36185NQ78     AA
                 M-2        36185NQ86     A
                 B          36185NQ94     CCC

                GMACM Mortgage Loan Trust 2004-GH1
                       Series      2004-GH1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-3        36185HDY6     AAA
                 A-4        36185HDZ3     AAA
                 A-5        36185HEA7     AAA
                 A-6        36185HEB5     AAA
                 M-1        36185HEC3     BBB
                 M-2        36185HED1     CCC

                       GSAMP Trust 2005-SEA2
                       Series      2005-SEA2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-1        362341TM1     AAA
                 A-2        362341TN9     AAA
                 M-1        362341TP4     AA+

             Option One Woodbridge Loan Trust 2003-2
                        Series      2003-2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A          68401NAA9     AAA
                 M          68401NAC5     BB-

             Option One Woodbridge Loan Trust 2004-1
                        Series      2004-1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A          68401NAD3     AAA
                 M          68401NAE1     BB-

                       Quest Trust 2003-X2
                       Series      2003-X2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-2        03072SHP3     AA

                       Quest Trust 2003-X3
                       Series      2003-X3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-2        03072SKE4     AA
                 M-3        03072SKF1     BBB

                       Quest Trust 2004-X1
                       Series      2004-X1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A          03072SPS8     AA

                       Quest Trust 2004-X2
                       Series      2004-X2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 M-1        03072SSW6     AA
                 M-2        03072SSX4     A

                       Quest Trust 2005-X2
                       Series      2005-X2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-2        748351AF0     CCC

                    RAMP Series 2001-RS1 Trust
                       Series      2001-RS1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-II       760985CP4     CCC

                    RAMP Series 2001-RS2 Trust
                       Series      2001-RS2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-II       760985DV0     AAA
                 M-II-1     760985DZ1     BBB
                 M-II-2     760985EA5     BB-
                 M-II-3     760985EB3     CCC

                    RAMP Series 2001-RS3 Trust
                       Series      2001-RS3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-II       760985FC0     CCC

                    RAMP Series 2002-RS1 Trust
                       Series      2002-RS1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-I-5      760985GQ8     AAA
                 M-II-2     760985GX3     B

                    RAMP Series 2002-RS4 Trust
                       Series      2002-RS4

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-I-5      760985NK3     CCC
                 A-I-6      760985NL1     CCC
                 A-II       760985NN7     BB+

                    RAMP Series 2002-RS5 Trust
                       Series      2002-RS5

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-I-5      760985NW7     BB
                 A-I-6      760985NX5     BB
                 A-II       760985NZ0     CCC

                    RAMP Series 2002-RS6 Trust
                       Series      2002-RS6

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-I-5      760985PN5     CCC
                 A-I-6      760985PP0     CCC
                 A-I-7      760985PQ8     CCC
                 A-II       760985PS4     A-

                    RAMP Series 2003-RS11 Trust
                       Series      2003-RS11

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-I-6B     760985L66     AAA
                 A-I-7      760985K34     AAA
                 M-I-1      760985K42     AA
                 M-II-1     760985K91     AA
                 A-I-6A     760985K26     AAA

                    RAMP Series 2003-RS2 Trust
                       Series      2003-RS2

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-I-5      760985SS1     CCC
                 A-I-6      760985ST9     CCC
                 A-II       760985SU6     CCC

                    RAMP Series 2003-RS3 Trust
                       Series      2003-RS3

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-II       760985UC3     CCC

                    RAMP Series 2003-RS5 Trust
                       Series      2003-RS5

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-I-5      760985WY3     A
                 A-II-A     760985XA4     AA-
                 A-II-B     760985XB2     AA-

                    RAMP Series 2003-RS9 Trust
                       Series      2003-RS9

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-I-6A     760985A43     AAA
                 A-I-6B     760985B83     AAA
                 A-I-7      760985A50     AAA
                 M-I-1      760985A84     AA
                 M-I-2      760985A92     BB-
                 M-II-2     760985B42     CCC

                    RAMP Series 2004-RS1 Trust
                       Series      2004-RS1

                 Class      CUSIP         Rating
                 -----      -----         ------
                 A-I-6A     760985M73     AAA
                 A-I-6B     760985M81     AAA
                 A-I-7      760985M99     AAA


* S&P Downgrades Ratings on Five Tranches From Four CDO Deals
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
tranches from four U.S. collateralized debt obligation
transactions and removed four of them from CreditWatch with
negative implications.  The tranches with lowered ratings have a
total issuance amount of $396.05 million.  At the same time, S&P
affirmed its ratings on 23 tranches from 15 transactions and
removed 17 of them from CreditWatch negative.

The downgrades reflect two primary factors:

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

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

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

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

                          Rating Actions

                                              Rating
                                              ------
  Transaction                         Class  To   From
  -----------                         -----  --   ----
  Balboa CDO I Ltd.                   A      AAA  AAA/Watch Neg
  Centurion CDO III Ltd.              I      AAA  AAA/Watch Neg
  Centurion CDO III Ltd.              II     AA   AA/Watch Neg
  FC CBO III Ltd.                     B      D    CCC-
  GIA Investment Grade CDO 2001 Ltd.  A-2    B+   BB/Watch Neg
  GIA Investment Grade CDO 2001 Ltd.  B      CCC- B/Watch Neg
  Hampden CBO Ltd.                    A-1    AAA  AAA/Watch Neg
  Inner Harbor CBO 1999-1 Ltd.        A-4A   BB-  BB-/Watch Neg
  Inner Harbor CBO 1999-1 Ltd.        A-4B   BB-  BB-/Watch Neg
  JWS CBO 2000-1 Ltd.                 B      AAA  AAA/Watch Neg
  JWS CBO 2000-1 Ltd.                 C-1    BBB- BBB-/Watch Neg
  JWS CBO 2000-1 Ltd.                 C-2    BBB- BBB-/Watch Neg
  Liberty Square CDO II Ltd.          A-1    AAA  AAA/Watch Neg
  Liberty Square CDO II Ltd.          A-2    AAA  AAA/Watch Neg
  Phoenix Funding Ltd.                Senior AA   AA/Watch Neg
  Signature 5 L.P.                    A      AAA  AAA/Watch Neg
  Signature 6 Ltd.                    A      AAA  AAA/Watch Neg
  Solar Investment Grade CBO I        I-A    AAA  AAA/Watch Neg
  Solar Investment Grade CBO I        I-B    AAA  AAA/Watch Neg
  Solar Investment Grade CBO II       I      AA+  AAA/Watch Neg
  Structured Investments Corp.        Notes  CCC- BBB-/Watch Neg
  Valeo Investment Grade CDO II Ltd.  A-2    BB+  BB+/Watch Neg

                         Ratings Affirmed

         Transaction                         Class  Rating
         -----------                         -----  ------
         GIA Investment Grade CDO 2001 Ltd.  A-1    AAA
         Inner Harbor CBO 1999-1 Ltd.        B-2    CC
         Magma CDO Ltd.                      A      AAA
         Muzinich Cashflow CBO II Ltd.       A      AAA
         Valeo Investment Grade CDO II Ltd.  A-1    AAA
         Valeo Investment Grade CDO Ltd.     A-1    AAA


* S&P Puts Ratings on Tobacco Manufacturers' Notes on Neg. Watch
----------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on 122
classes from 31 asset-backed securities transactions backed by
payments from participating tobacco manufacturers under the Master
Settlement Agreement on CreditWatch with negative implications.
S&P maintain a negative outlook on all other outstanding classes
of tobacco securitizations.

The CreditWatch placements follow Standard & Poor's revised base-
case ('B' rating case) and stress case volume (higher than a 'B'
rating) decline assumptions for U.S. cigarette sales and S&P's
stress case assumptions for domestic cigarette manufacturer market
share.

Tobacco securitizations are backed by payments made by the
participating tobacco manufacturers under the MSA, which was
signed in 1998.  The PMs are designated either as original
participating manufacturers or subsequent participating
manufacturers.  Under the MSA, the PMs are required to make
payments to each state annually, in perpetuity.  After the
agreement was signed, many state and local governments sold all or
a portion of their rights to receive future settlement proceeds to
investors in exchange for a payment at the time of the sale.

S&P's revised assumptions include:

S&P revised its recovery assumptions to between 80% and 90% of the
original disputed amounts in its nonparticipating manufacturer
adjustment liquidity stress.  S&P has also updated its assumptions
regarding the duration of the disputes.  S&P retain its assumption
of the magnitude of the amounts disputed by the PMs of about 10%
of the total MSA payment.

While S&P retains its base-case cigarette consumption decline
projections of 3.5% for 2010, between 3.25% and 3.75% for 2011 and
then between 2.75% and 3.25% annually in perpetuity, S&P estimates
that cigarette sales volume will decline by another 1.5% in 2010
primarily as a continued effect of the federal excise tax increase
that was introduced last year.

S&P revised its base-case market share assumptions: 83% for OPMs,
10% for SPMs, and 7% for NPMs.  S&P expects this market share
allocation for the domestic cigarette manufacturers will remain
relatively stable for the next three to four years.

S&P specifies its reinvestment assumptions for the reserve account
funds.  S&P typically gives full credit in its cash flow
projections to reinvestment income of the reserve account funds to
the specified rate in the guaranteed investment contract or
forward purchase agreement with an eligible counterparty, if there
is a GIC or an FPA.  Otherwise, if the reserve account funds are
invested in eligible investments, which are typically lower-risk
instruments, S&P assumes a 0.03% reinvestment rate in cash flows
for the first year.  S&P's minimum rate assumption increases to
0.25% in the second year, 0.4% in the third year, 0.5% in the
fourth year, 0.65% in the fifth year, and 0.75% in the sixth year
and thereafter.

The ratings S&P placed on CreditWatch negative affect classes that
exhibit an inability to pay timely interest or full principal
under at least one of a number of cash flow scenarios when S&P
account for S&P's revised assumptions for each class at its
current rating level.

S&P expects to resolve all of the CreditWatch placements within
the next 90 days.

S&P maintains its negative outlook on the transactions not
affected by the CreditWatch placement because S&P believes
significant industry and litigation event risks will be present
for five years or more, which could lead to downgrades in the
future.

              Ratings Placed on Creditwatch Negative

          Buckeye Tobacco Settlement Financing Authority
US$5.532 billion tobacco settlement asset-backed bonds series 2007

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2007A-2 06/01/2024 200.000             BBB/Watch Neg  BBB/Negative
2007A-2 06/01/2024 949.530             BBB/Watch Neg  BBB/Negative
2007A-2 06/01/2030 687.600             BBB/Watch Neg  BBB/Negative
2007A-2 06/01/2034 505.200             BBB/Watch Neg  BBB/Negative
2007A-2 06/01/2042 250.000             BBB/Watch Neg  BBB/Negative
2007A-2 06/01/2047 750.000             BBB/Watch Neg  BBB/Negative
2007A-2 06/01/2047 1383.715            BBB/Watch Neg  BBB/Negative
2007A-3 06/01/2037 274.751             BBB/Watch Neg  BBB/Negative

         California County Tobacco Securitization Agency
              (Fresno County Tobacco Funding Corp.)
US$93 million tobacco settlement asset-backed bonds series 2002

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2023    06/01/2023 17.035              BBB/Watch Neg  BBB/Negative
2027    06/01/2027 12.23               BBB/Watch Neg  BBB/Negative
2035    06/01/2035 35.265              BBB/Watch Neg  BBB/Negative
2038    06/01/2038 18.500              BBB/Watch Neg  BBB/Negative

         California County Tobacco Securitization Agency
              (Gold County Settlement Funding Corp.)
US$59 million tobacco settlement asset-backed bonds series 2006

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2006A   06/01/2046 45.000              B+/Watch Neg  B+/Negative
2006B   06/01/2033 14.372              B+/Watch Neg  B+/Negative

         California County Tobacco Securitization Agency
               (Kern County Tobacco Funding Corp.)
  US$105 million tobacco settlement asset-backed bonds series 2002

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2002A   06/01/2043 40.960              BBB/Watch Neg  BBB/Negative
2002B   06/01/2029 27.875              BBB/Watch Neg  BBB/Negative
2002B   06/01/2037 29.010              BBB/Watch Neg  BBB/Negative

         California County Tobacco Securitization Agency
         (Sonoma County Settlement Securitization Corp.)
US$83 million tobacco settlement asset-backed bonds series 2005-1

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2005    06/01/2021 14.835              BBB/Watch Neg  BBB/Negative
2005    06/01/2026 9.920               BBB/Watch Neg  BBB/Negative
2005    06/01/2038 31.045              BBB/Watch Neg  BBB/Negative
2005    06/01/2045 27.260              BBB/Watch Neg  BBB/Negative

                         Children's Trust
US$1.171 billion tobacco settlement asset-backed bonds series 2002

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2033    05/15/2033 471.105             BBB/Watch Neg  BBB/Negative
2039    05/15/2039 310.380             BBB/Watch Neg  BBB/Negative
2043    05/15/2043 296.255             BBB/Watch Neg  BBB/Negative

      District of Columbia Tobacco Settlement Financing Corp.
     US$521.105 million tobacco settlement asset-backed bonds
                            series 2001

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2024    05/15/2024 114.855             BBB/Watch Neg  BBB/Negative
2033    05/15/2033 169.110             BBB/Watch Neg  BBB/Negative
2040    05/15/2040 187.540             BBB/Watch Neg  BBB/Negative

               Educational Enhancement Funding Corp.
     US$278.045 million tobacco settlement asset-backed bonds
                          series 2002A&B

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2002A   06/01/2025 148.505             BBB/Watch Neg  BBB/Negative
2002B   06/01/2032 129.540             BBB/Watch Neg  BBB/Negative

              Erie Tobacco Asset Securitization Corp.
     US$318.835 million tobacco settlement asset-backed bonds
                           series 2005

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2005A   06/01/2031 30.330              BBB/Watch Neg  BBB/Negative
2005A   06/01/2038 74.685              BBB/Watch Neg  BBB/Negative
2005A   06/01/2045 111.480             BBB/Watch Neg  BBB/Negative
2005E   06/01/2028 69.470              BBB/Watch Neg  BBB/Negative

             Golden State Tobacco Securitization Corp.
$4,446 million tobacco settlement asset-backed bonds series 2007

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2007A-1 06/01/2027 863.100             BBB/Watch Neg  BBB/Negative
2007A-1 06/01/2033 610.525             BBB/Watch Neg  BBB/Negative
2007A-1 06/01/2047 1250.000            BBB/Watch Neg  BBB/Negative
2007A-1 06/01/2047 693.575             BBB/Watch Neg  BBB/Negative
2007A-2 06/01/2037 389.193             BBB/Watch Neg  BBB/Negative
2007-B  06/01/2047 271.957             BB/Watch Neg   BB/Negative
2007-C  06/01/2047 78.547              BB-/Watch Neg  BB-/Negative

          Michigan Tobacco Settlement Finance Authority
       US$490 million tobacco settlement asset-backed bonds
                         series 2006 A B C

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2006A   06/01/2034 363.115             BBB/Watch Neg  BBB/Negative

          Michigan Tobacco Settlement Finance Authority
       US$523 million tobacco settlement asset-backed bonds
                        series 2007 A B C

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2007A   06/01/2022 20.000              BBB/Watch Neg  BBB/Negative
2007A   06/01/2022 57.185              BBB/Watch Neg  BBB/Negative
2007A   06/01/2034 112.855             BBB/Watch Neg  BBB/Negative
2007A   06/01/2048 290.085             BBB/Watch Neg  BBB/Negative
2007B   06/01/2052 35.65               BB/Watch Neg   BB/Negative
2007C   06/01/2052 7.217               BB-/Watch Neg  BB-/Negative

              Nassau County Tobacco Settlement Corp.
     US$431.043 million tobacco settlement asset-backed bonds
                            series 2006

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2006A-1 06/01/2019 42.645              BBB/Watch Neg  BBB/Negative
2006A-2 06/01/2025 37.906              BBB/Watch Neg  BBB/Negative
2006A-3 06/01/2035 97.005              BBB/Watch Neg  BBB/Negative
2006A-3 06/01/2046 194.535             BBB/Watch Neg  BBB/Negative

                New York Counties Tobacco Trust I
     US$303.37 million tobacco settlement pass-through bonds
                            series 2000

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2019    06/01/2019 14.890              BBB/Watch Neg  BBB/Negative
2028    06/01/2028 39.710              BBB/Watch Neg  BBB/Negative
2035    06/01/2035 60.450              BBB/Watch Neg  BBB/Negative
2042    06/01/2042 71.840              BBB/Watch Neg  BBB/Negative

                New York Counties Tobacco Trust II
     US$215.22 million tobacco settlement pass-through bonds
                           series 2001

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2025    06/01/2025 48.370              BBB/Watch Neg  BBB/Negative
2035    06/01/2035 68.005              BBB/Watch Neg  BBB/Negative
2043    06/01/2043 82.795              BBB/Watch Neg  BBB/Negative

               New York Counties Tobacco Trust III
US$79.68 million tobacco settlement pass-through bonds series 2003

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2033    06/01/2033 15.175              BBB/Watch Neg  BBB/Negative
2043    06/01/2043 40.39               BBB/Watch Neg  BBB/Negative

                New York Counties Tobacco Trust IV
       US$539 million tobacco settlement pass-through bonds
                         series 2005 ABC

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2005A   06/01/2021 6.965               BBB/Watch Neg  BBB/Negative
2005A   06/01/2026 4.520               BBB/Watch Neg  BBB/Negative
2005A   06/01/2038 16.585              BBB/Watch Neg  BBB/Negative
2005A   06/01/2042 84.995              BBB/Watch Neg  BBB/Negative
2005A   06/01/2045 83.875              BBB/Watch Neg  BBB/Negative
2005B   06/01/2027 54.61               BBB/Watch Neg  BBB/Negative
2010A   06/01/2041 124.400             BBB/Watch Neg  BBB/Negative

          Rensselaer Tobacco Asset Securitization Corp.
US$34.555 million tobacco settlement asset-backed bonds series A

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
(2025)A 06/01/2025 7.710               BBB/Watch Neg  BBB/Negative
(2035)A 06/01/2035 10.890              BBB/Watch Neg  BBB/Negative
(2043)A 06/01/2043 13.355              BBB/Watch Neg  BBB/Negative

            Rockland Tobacco Asset Securitization Corp.
US$47.75 million tobacco settlement asset-backed bonds series 2001

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2025    08/15/2025 12.005              BBB/Watch Neg  BBB/Negative
2035    08/15/2035 15.225              BBB/Watch Neg  BBB/Negative
2043    08/15/2043 18.620              BBB/Watch Neg  BBB/Negative

        San Diego County Tobacco Asset Securitization Corp.
     US$583.631 million tobacco asset-backed bonds series 2006

                                             Rating
                                             ------
Class  Maturity   Orig bal. (mil. $)  To             From
-----  --------   ------------------  --             ----
2006A  06/01/2025 111.860             BBB/Watch Neg  BBB/Negative
2006A  06/01/2037 186.440             BBB/Watch Neg  BBB/Negative
2006A  06/01/2046 236.310             BBB/Watch Neg  BBB/Negative
2006B  06/01/2046 19.770              BBB-/Watch Neg BBB-/Negative
2006C  06/01/2046 8.686               BB+/Watch Neg  BB+/Negative
2006D  06/01/2046 20.565              BB-/Watch Neg  BB=/Negative

        Tobacco Securitization Corp. of Northern California
       US$255 million tobacco asset-backed bonds series 2005

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2005A-1 06/01/2023 45.825              BBB/Watch Neg  BBB/Negative
2005A-1 06/01/2038 87.290              BBB/Watch Neg  BBB/Negative
2005A-1 06/01/2045 86.570              BBB/Watch Neg  BBB/Negative
2005A-2 06/01/2027 12.469              BBB/Watch Neg  BBB/Negative
2005B   06/01/2045 11.674              BB+/Watch Neg  BB+/Negative
2005C   06/01/2045 11.659              BB-/Watch Neg  BB-/Negative

                Iowa Tobacco Settlement Authority
  US$839 million tobacco settlement authority series 2005 A B C D

                                             Rating
                                             ------
Class  Maturity   Orig bal. (mil. $)  To             From
-----  --------   ------------------  --             ----
2005A  06/01/2046 229.910             BBB/Watch Neg  BBB/Negative
2005B  06/01/2034 159.369             BBB/Watch Neg  BBB/Negative
2005C  06/01/2038 103.475             BBB/Watch Neg  BBB/Negative
2005C  06/01/2042 135.120             BBB/Watch Neg  BBB/Negative
2005C  06/01/2046 174.130             BBB/Watch Neg  BBB/Negative
2005D  06/01/2046 15.775              BBB-/Watch Neg BBB-/Negative

             Tobacco Settlement Authority (Washington)
     US$517.905 million tobacco settlement asset-backed bonds
                            series 2002

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2026    06/01/2026 279.775             BBB/Watch Neg  BBB/Negative
2032    06/01/2032 179.505             BBB/Watch Neg  BBB/Negative

          Tobacco Settlement Financing Corp. (New Jersey)
      US$3,622 million tobacco settlement asset-backed bonds
                          series 2007-1

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2007-1A 06/01/2023 623.710             BBB/Watch Neg  BBB/Negative
2007-1A 06/01/2026 287.620             BBB/Watch Neg  BBB/Negative
2007-1A 06/01/2029 332.270             BBB/Watch Neg  BBB/Negative
2007-1A 06/01/2034 672.945             BBB/Watch Neg  BBB/Negative
2007-1A 06/01/2041 1263.590            BBB/Watch Neg  BBB/Negative
2007-1B 06/01/2041 126.198             BB/Watch Neg   BB/Negative
2007-1C 06/01/2034 59.785              BB-/Watch Neg  BB-/Negative

         Tobacco Settlement Financing Corp. (Rhode Island)
       US$685 million tobacco settlement asset-backed bonds
                      series 2002A and 2002B

                                             Rating
                                             ------
Class  Maturity   Orig bal. (mil. $)  To             From
-----  --------   ------------------  --             ----
2002-A 06/01/2023 109.770             BBB/Watch Neg   BBB/Negative
2002-A 06/01/2032 168.260             BBB/Watch Neg   BBB/Negative
2002-A 06/01/2042 371.700             BBB/Watch Neg   BBB/Negative

          Tobacco Settlement Financing Corp. (Louisiana)
      US$1.203 billion tobacco settlement asset-backed bonds
                          series 2001A&B

                                                Rating
                                                ------
   Class      Maturity   Orig bal. (mil. $)  To             From
   -----      --------   ------------------  --             ----
   2001B-2031 05/15/2030 230.390             BBB/Watch Neg BBB/Negative
   2001B-2038 05/15/2039 689.405             BBB/Watch Neg BBB/Negative

                            TSASC Inc.
      US$1.354 billion tobacco settlement asset-backed bonds
                           series 2006-1

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2006    06/01/2022 284.070              BBB/Watch Neg  BBB/Negative
2006    06/01/2026 137.765              BBB/Watch Neg  BBB/Negative
2006    06/01/2034 372.650              BBB/Watch Neg  BBB/Negative
2006    06/01/2042 559.025              BBB/Watch Neg  BBB/Negative

              Tobacco Settlement Financing Corp. (VA)
  $1,149 million tobacco settlement asset-backed bonds series 2007

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2007A-1 06/01/2046 682.650              BBB/Watch Neg  BBB/Negative
2007B-1 06/01/2047 335.625              BBB/Watch Neg  BBB/Negative
2007B-2 06/01/2047 26.808               BBB/Watch Neg  BBB/Negative
2007C   06/01/2047 77.104               BB/Watch Neg   BB/Negative
2007D   06/01/2047 27.086               BB-/Watch Neg  BB-/Negative

          Westchester Tobacco Asset Securitization Corp.
  $216 million tobacco settlement asset-backed bonds series 2005

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2005    06/01/2021 29.600               BBB/Watch Neg  BBB/Negative
2005    06/01/2026 24.100               BBB/Watch Neg  BBB/Negative
2005    06/01/2038 81.200               BBB/Watch Neg  BBB/Negative
2005    06/01/2045 81.700               BBB/Watch Neg  BBB/Negative

       Tobacco Settlement Finance Authority (West Virginia)
   US$911 million taxable tobacco settlement asset-backed bonds
                           series 2007

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2007A   06/01/2047 845.810              BBB/Watch Neg  BBB/Negative
2007B   06/01/2047 65.332               BB+/Watch Neg  BB+/Negative

         Tobacco Settlement Financing Corp. (Rhode Island)
US$194 million tobacco settlement asset-backed bonds series 2007

                                             Rating
                                             ------
Class   Maturity   Orig bal. (mil. $)  To             From
-----   --------   ------------------  --             ----
2007A   06/01/2052 176.974              BB/Watch Neg   BB/Negative
2007B   06/01/2052 17.336               BB-/Watch Neg  BB-/Negative


* S&P Withdraws Ratings on 57 Classes From 31 North American CMBS
-----------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 57
classes from 31 North American commercial mortgage-backed
securities and commercial real estate collateralized debt
obligation transactions.

S&P withdrew its ratings on 49 classes from 29 CMBS and CRE CDO
transactions following the repayment in full of the remaining
principal balance of each class, as noted in the July 2010
remittance report for each transaction.  S&P withdrew its ratings
on three interest-only classes from three CMBS transactions
following the full reductions of the classes' notional balances,
as noted in each transaction's respective July 2010 remittance
reports.  The IO withdrawals included two IO classes from two
additional CMBS transactions not affected by the previously noted
principal balance repayments.

S&P also withdrew its ratings on five additional IO classes from
five affected CMBS transactions.  S&P withdrew these IO ratings
following the repayment of all principal and interest paying
classes rated 'AA-' or higher from the respective CMBS
transactions.

Ratings Withdrawn Following Full Repayment or Balance Reduction

                     AERO 1 HQ Finance Trust
Commercial mortgage-backed pass-through certificates series 2003A

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA
        A-2                      NR                  BBB+
        A-3                      NR                  BB

                    Asset Securitization Corp.
      Commercial mortgage pass-through certs series 1995-D1

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-3                      NR                  AA+

             Banc of America Commercial Mortgage Inc.
    Commercial mortgage pass-through certificates series 2000-2

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-2                      NR                  AAA

             Banc of America Commercial Mortgage Inc.
    Commercial mortgage pass-through certificates series 2004-1

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-2                      NR                  AAA

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

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        C                        NR                  AA
        D                        NR                  AA-

         Bear Stearns Commercial Mortgage Securities Inc.
   Commercial mortgage pass-through certificates series 2000-WF1

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        D                        NR                  AA+

         Bear Stearns Commercial Mortgage Securities Trust
  Commercial mortgage pass-through certificates series 2005-PWR10

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA

            Chase Commercial Mortgage Securities Corp.
       Commercial mortgage pass-through certs series 1998-2

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        C                        NR                  AAA
        D                        NR                  AA+
        E                        NR                  AA-

          Chase Manhattan Bank-First Union National Bank
                    Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 1999-1

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        C                        NR                  AAA

                Citigroup Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2006-FL2

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-2                      NR                  AAA
        B                        NR                  AAA
        C                        NR                  AAA
        D                        NR                  AA+
        CNP-1                    NR                  B+
        CNP-3                    NR                  CCC+

                Citigroup Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2008-C7

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA

                   COMM 2000-C1 Mortgage Trust
   Commercial mortgage pass-through certificates series 2000-C1

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        B                        NR                  AAA

                               COMM
  Commercial mortgage pass-through certificates series 2003-LNB1

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        X-2                      NR                  AAA

       Credit Suisse First Boston Mortgage Securities Corp.
  Commercial mortgage pass through certificates series 2005-TFL3

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        J                        NR                  A
        K                        NR                  BB+
        L                        NR                  B+

                   DLJ Commercial Mortgage Trust
     Commercial mortgage pass-through certificates 2000-CF1

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-4                      NR                  AAA

                    GE Commercial Mortgage Corp.
   Commercial mortgage pass-through certificates series 2005-C3

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-2                      NR                  AAA

            Greenwich Capital Commercial Funding Corp.
   Commercial mortgage pass-through certificates series 2003-C2

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-2                      NR                  AAA

       JPMorgan Chase Commercial Mortgage Securities Trust
Commercial mortgage pass-through certificates, series 2006-CIBC14

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA

       JPMorgan Chase Commercial Mortgage Securities Trust
  Commercial mortgage pass-through certificates series 2006-LDP6

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA

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

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA

            JPMorgan Commercial Mortgage Finance Corp.
      Commercial mortgage pass-through certs series 1997-C5

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        Class                    To                  From
        E                        NR                  AA+

                 LB-UBS Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2003-C5

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        X-CP                     NR                  AAA

                 LB-UBS Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2007-C2

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA

     Lehman Brothers Floating Rate Commercial Mortgage Trust
     Multiclass pass-through certificates series 2004 LLFC5

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        B                        NR                  AAA
        C                        NR                  AAA
        D                        NR                  AAA
        E                        NR                  AAA
        F                        NR                  AA-

                  Morgan Stanley Capital I Trust
  Commercial mortgage pass-through certificates series 2005-HQ6

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA

                  Morgan Stanley Capital I Trust
Commercial mortgage pass-through certificates series 2006-TOP21

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA

                   N-45 First CMBS Issuer Corp.
          Commercial mortgage-backed bonds series 2000-1

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA
        A-2                      NR                  AAA
        B                        NR                  AAA
        C                        NR                  AA+
        D                        NR                  A+
        IO                       NR                  AAA

                   PNC Mortgage Acceptance Corp.
   Commercial mortgage pass-through certificates series 2000-C2

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-2                      NR                  AAA

                         STRIPs CDO Ltd.
                      STRIPs CDO LTD 2002-1

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        L                        NR                  A

             Wachovia Bank Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2004-C10

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-2                      NR                  AAA

             Wachovia Bank Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2006-C23

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        A-1                      NR                  AAA


       Ratings Withdrawn Following Application Of Criteria
                         For IO Securities

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

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        X-C                      NR                  AAA

         Bear Stearns Commercial Mortgage Securities Inc.
  Commercial mortgage pass-through certificates series 2000-WF1

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        X                        NR                  AAA
            Chase Commercial Mortgage Securities Corp.
       Commercial mortgage pass-through certs series 1998-2

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        X                        NR                  AAA

               Citigroup Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2006-FL2

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        X-3                      NR                  AAA

     Lehman Brothers Floating Rate Commercial Mortgage Trust
     Multiclass pass-through certificates series 2004 LLFC5

                                         Rating
                                         ------
        Class                    To                  From
        -----                    --                  ----
        X-2                      NR                  AAA

                          NR - Not rated.



                           *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers"
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Wednesday's edition of the TCR.  Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com/

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

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

For copies of court documents filed in the District of Delaware,
please contact Vito at Parcels, Inc., at 302-658-9911.  For
bankruptcy documents filed in cases pending outside the District
of Delaware, contact Ken Troubh at Nationwide Research &
Consulting at 207/791-2852.

                           *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors" Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Frederick, Maryland,
USA.  Marites Claro, Joy Agravante, Rousel Elaine Tumanda, Howard
C. Tolentino, Joseph Medel C. Martirez, Denise Marie Varquez,
Philline Reluya, Ronald C. Sy, Joel Anthony G. Lopez, Cecil R.
Villacampa, Sheryl Joy P. Olano, Carlo Fernandez, Christopher G.
Patalinghug, and Peter A. Chapman, Editors.

Copyright 2010.  All rights reserved.  ISSN: 1520-9474.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.  Information contained
herein is obtained from sources believed to be reliable, but is
not guaranteed.

The TCR subscription rate is $775 for 6 months delivered via e-
mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Christopher
Beard at 240/629-3300.


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