TCR_Public/101107.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

            Sunday, November 7, 2010, Vol. 14, No. 309

                            Headlines

505 CLO: S&P Raises Ratings on Various Classes of Notes
ABACUS 2006-13: Fitch Downgrades Ratings on 11 Classes of Notes
ABACUS 2006-17: Fitch Downgrades Ratings on Five Classes
ABACUS 2007-18: Fitch Downgrades Ratings on Four Classes of Notes
ACCESS TO: Fitch Downgrades Ratings on Subordinate Notes to 'BB'

ACE SECURITIES: Moody's Assigns 'Ba3' Rating to 2006-FM1 Swap
AERCO LIMITED: Fitch Affirms Ratings on Various Classes of Notes
ARBOR REALTY: Fitch Downgrades Ratings on Two Classes of Notes
ARTUS LOAN: S&P Raises Ratings on Various Classes of Notes
BANC OF AMERICA: Fitch Downgrades Ratings on 14 Classes

BANC OF AMERICA: Fitch Takes Rating Actions on Various Classes
BANC OF AMERICA: Moody's Downgrades Ratings on 14 2005-5 Certs.
BEAR STEARNS: Fitch Downgrades Ratings on 11 2005-PWR7 Certs.
BEAR STEARNS: Moody's Downgrades Ratings on Four 2003-TOP12 Certs.
BEAR STEARNS: Moody's Reviews Ratings on 14 2005-PWR7 Certs.

BEAR STEARNS: Moody's Reviews Ratings on 15 2005-TOP20 Certs.
BEAR STEARNS: Moody's Reviews Ratings on 2006-TOP22 Certs.
BEAR STEARNS: Moody's Reviews Ratings on 2007-BBA8 Certificates
BEAR STEARNS: S&P Downgrades Ratings on Eight 2007-BBA8 Certs.
C-BASS MORTGAGE: Moody's Downgrades Ratings on Four Tranches

CAPITALSOURCE COMMERCIAL: S&P Raises Ratings on Various Classes
CD 2007-CD5: Moody's Reviews Ratings on 13 Classes of Certs.
CHASE COMMERCIAL: S&P Downgrades Ratings on Four Certificates
CITIGROUP COMMERCIAL: Moody's Cuts Ratings on Five 2004-C1 Certs.
CLYDESDALE CLO: S&P Raises Ratings on Three Classes of Notes

COMM 2004: S&P Downgrades Ratings on 11 Classes of Notes
COMM 2007-FL14: Moody's Reviews Ratings on 10 Classes of Notes
COMMERCIAL MORTGAGE: Moody's Cuts Ratings on Six 1999-C1 Certs.
COMMERCIAL MORTGAGE: Moody's Takes Rating Actions on Certificates
COUNTRYWIDE COMMERCIAL: Moody's Cuts Ratings on 16 2007-MF1 Certs.

CREDIT AND REPACKAGED: Moody's Upgrades Rating on 2006-11 Notes
CREDIT AND REPACKAGED: Moody's Upgrades Ratings on 2 Notes to Ba3
CREST 2003-2: Moody's Downgrades Ratings on 11 Classes of Notes
CREST G-STAR: Moody's Takes Rating Actions on Four Classes
CREDIT SUISSE: Moody's Reviews Ratings on 12 2002- CKN2 Certs.

CREDIT SUISSE: Moody's Downgrades Ratings on Six 2002-CP3 Certs.
CREDIT SUISSE: Moody's Takes Rating Actions on Various Classes
CSMC SERIES: Moody's Assigns Ratings on Various Certificates
DEUTSCHE MORTGAGE: Moody's Downgrades Rating on Class 3-A-1 Certs.
EDUCATION LOANS: Fitch Affirms CCCsf Rating on Class K Sr. Loan

FAIRFAX COUNTY: S&P Corrects Rating to Revenue Bonds to 'BB+'
GS MORTGAGE: S&P Downgrades Ratings on Nine 2007-GKK1 Securities
FRANKLIN CLO: Moody's Upgrades Ratings on Various Classes
FREMONT HOME: Moody's Assigns 'Ba2' Rating to Certificate Swap
GE COMMERCIAL: Fitch Downgrades Ratings on Three 2005-C3 Certs.

GMAC COMMERCIAL: Moody's Raises Rating on 2000-C1 Certificates
GMAC COMMERCIAL: Moody's Takes Rating Actions on Various Classes
GRAND HORN: S&P Raises Ratings on Various Classes of Notes
GREENFIELD REDEVELOPMENT: S&P Cuts Rating on Tax Bonds to 'BB+'

GREENWICH CAPITAL: S&P Downgrades Ratings on Six 2007-RR2 Certs.
GS MORTGAGE: Moody's Downgrades Ratings on Three 2004-C1 Certs.
GS MORTGAGE: Moody's Downgrades Ratings on 11 2005-GG4 Certs.
GS MORTGAGE: S&P Downgrades Ratings on 11 2006-RR2 Certificates
GUAM WATERWORKS: Fitch Assigns 'BB' Rating to $118.8 Mil. Bonds

GUAM WATERWORKS: Moody's Assigns 'Ba2' Rating to $118.8 Mil. Bonds
GULF STREAM-COMPASS: S&P Affirms Junk CLO 2004-1 Rating
GULF STREAM-COMPASS: S&P Ups Rating on Class D Notes to BB
HAMPTON ROADS: Fitch Maintains Negative Watch on Three Bonds
HELLER FINANCIAL: Moody's Cuts Ratings on Five 2000 PH-1 Notes

HOLIDAY SYNTHETIC: Moody's Takes Rating Actions on CDO Deals
JP MORGAN: Fitch Downgrades Ratings on Nine 2005-CIBC12 Certs.
JP MORGAN: Fitch Downgrades Ratings on 16 2005-LDP2 Certs.
JP MORGAN: Fitch Downgrades Ratings on Six 2005-LDP5 Certs.
JP MORGAN: Moody's Downgrades Ratings on Seven 2002-CIBC4 Certs.

JP MORGAN: Moody's Reviews Ratings on 15 2006-CIBC14 Certificates
JP MORGAN: Moody's Reviews Ratings on 19 2007-C1 Certificates
JP MORGAN: Moody's Takes Rating Actions on Three Classes of Notes
KEYCORP STUDENT: Moody's Reviews Ratings on Eight Student Loans

KODIAK CDO: Moody's Assigns 'Ba2' Rating to Interest Rate Swap
LB COMMERCIAL: Moody's Upgrades Ratings on Two 1999-C1 Certs.
LB-UBS COMMERCIAL: Moody's Cuts Ratings on Five 2000-C4 Certs.
LB-UBS COMMERCIAL: Moody's Cuts Ratings on Nine 2007-C6 Certs.
LCM I: S&P Raises Ratings on Various Classes of Notes

LEGG MASON: Moody's Takes Rating Actions on Various Classes
LEHMAN BROS: S&P Downgrades Ratings on Nine 2006-LLF C5 Certs.
LOCAL INSIGHT: Moody's Downgrades Ratings on Two Classes of Notes
MAGNOLIA FINANCE: S&P Downgrades Ratings on Two Classes of Notes
MARICOPA COUNTY: Moody's Cuts Rating to $10.4 Mil. Notes to 'B3'

MERRILL LYNCH: DBRS Upgrades Class F Rating From 'BB' to 'BBB'
MERRILL LYNCH: DBRS Upgrades Class H Rating From 'BB' to 'BBB'
MERRILL LYNCH: Moody's Reviews Ratings on 2006-C2 Certs.
MERRILL LYNCH: Moody's Reviews Ratings on Three Classes of Certs.
MICHIGAN FINANCE: S&P Assigns 'BB+' Rating on 2010 Revenue Bonds

MICHIGAN STRATEGIC: S&P Downgrades Rating on Revenue Bonds to 'BB'
MORGAN STANLEY: Moody's Takes Rating Action on Class A Notes
MORGAN STANLEY: S&P Withdraws Ratings on Class II 2006-14 Notes
MSC 2006-SRR2: Fitch Downgrades Ratings on 10 Classes of Notes
MUNIMAE TE: Moody's Downgrades Ratings on Various Shares

PALOMAR POMERADO: Fitch Assigns 'BB+' Rating to $160 Mil. Notes
PETRA CRE: Moody's Takes Rating Actions on Various Classes
PNC MORTGAGE: S&P Downgrades Ratings on Three 1999-CM1 Securities
POPULAR ABS: Moody's Assigns 'Ba1' Rating to Interest Rate Swap
RACE POINT: Moody's Upgrades Ratings on Various Classes of Notes

RED RIVER: Moody's Upgrades Ratings on Three Classes of Notes
SATURN VENTURE: Moody's Takes Rating Actions on Four Classes
SCHOONER TRUST: DBRS Confirms Class G Rating at 'BB'
SCHOONER TRUST: DBRS Upgrades Class F Rating to 'BBB' From 'BB'
SIENA MORTGAGES: Moody's Assigns Ratings on Four Classes of Notes

SILVERADO CLO: Moody's Upgrades Ratings on Two Classes of Notes
SOLAR TRUST: DBRS Confirms Class F Rating at 'BB'
SOLOSO CDO: Fitch Downgrades Ratings on Two Classes of Notes
SOUNDVIEW HOME: Moody's Downgrades Ratings on Three Tranches
ST JOSEPH: Moody's Downgrades Rating on $18.6 Mil. Bonds to 'B2'

STEDMAN LOAN: Moody's Upgrades Ratings on Various Classes
SWISS CHEETAH: Moody's Adjusts Ratings on Bonds to 'B1'
TCW SELECT: S&P Raises Ratings on Various Classes of Notes
TIERS SYNTHETIC: Moody's Downgrades Rating on Certs. to 'C'
TRINITY HIGHER: Fitch Affirms Ratings on Senior Student Loans

UNITED COMMERCIAL: S&P Downgrades Rating on Class A Certificates
US CAPITAL: Moody's Downgrades Ratings on Five Classes of Notes
VERICREST FINANCIAL: Moody's Reviews Ratings on Four Tranches
WACHOVIA AUTO: Fitch Corrects Press Release; Upgrades Ratings
WACHOVIA AUTO: Fitch Upgrades Ratings on Three Classes of Notes

WACHOVIA AUTO: S&P Raises Ratings on Various Classes of Notes
WACHOVIA BANK: Fitch Downgrades Ratings on 10 2005-C20 Certs.
WACHOVIA BANK: Fitch Downgrades Ratings on 13 2005-C22 Certs.
WACHOVIA BANK: Moody's Reviews Ratings on 10 2005-C18 Certs.
WACHOVIA BANK: Moody's Confirms Ratings on Three 2005-C21 Certs.

WACHOVIA BANK: Moody's Reviews Ratings on 17 2007-C33 Certs.
WACHOVIA BANK: S&P Downgrades Ratings on Eight 2004-C10 Certs.

* Fitch Affirms Ratings on Two US RMBS Housing Resecuritizations
* Fitch Assigns 'BB' Rating to New York and New Jersey's Bonds
* Fitch Upgrades Ratings on New Jersey Health's Bonds to 'B'
* Fitch Withdraws Ratings on Harvey, Illinois' Bonds
* Moody's Downgrades Ratings on 95 Notes by 56 CDO Transactions

* Moody's Reviews Ratings on 149 Prime Jumbo RMBS Transactions
* S&P Downgrades Ratings on 40 Certs. From Five CMBS Deals
* S&P Downgrades Ratings on 79 Classes From 10 RMBS Deals
* S&P Downgrades Rating on Boynton Beach, Florida's Bonds to 'BB'
* S&P Raises Rating on Orange County Housing Bonds From 'B+'

* S&P Raises Rating on Orange County Housing Bonds From 'CCC'
* S&P Reviews Ratings on 96 Classes From Four RMBS Transactions
* S&P Withdraws Ratings on 55 Classes From 33 North American CMBS
* S&P Withdraws Ratings on Four Classes From Two CDO Transactions

                            *********

505 CLO: S&P Raises Ratings on Various Classes of Notes
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B, C, and D notes from 505 CLO I Ltd., a collateralized loan
obligation transaction managed by CIT Asset Management LLC.  At
the same time, S&P removed the class A notes from CreditWatch with
positive implications.  The upgrades reflect the improved
performance S&P has observed in the transaction since S&P's last
rating action in February 2010.

According to the Oct. 4, 2010, trustee report, the transaction
held $12.5 million in defaulted assets, down from $55 million
noted in the Jan. 5, 2010 trustee report.  In addition, assets
from obligors rated in the 'CCC' category were 8.6% of the
collateral pool in October 2010, compared with 20% in January
2010.  The class A overcollateralization test improved to 162.28%
in October 2010 from 136.55% as of January 2010.  The class A
notes were paid down by $163 million since S&P's last rating
action.

Standard & Poor's will continue to review whether, in S&P's view,
the ratings currently assigned to the notes remain consistent with
the credit enhancement available to support them and take rating
actions as S&P deem necessary.

                  Rating And Creditwatch Actions

                          505 CLO I Ltd.

             Class       To         From
             -----       --         ----
             A           AAA (sf)   A+ (sf)/Watch Pos
             B           A (sf)     BB+ (sf)
             C           BBB (sf)   B+ (sf)
             D           BB (sf)    CCC- (sf)


ABACUS 2006-13: Fitch Downgrades Ratings on 11 Classes of Notes
---------------------------------------------------------------
Fitch Ratings has downgraded 11 classes issued by Abacus 2006-13,
Ltd., as a result of significant negative credit migration within
the reference portfolio.

Since Fitch's last rating action in November 2009, approximately
44.8% of the reference portfolio has been downgraded, and 18.9% is
currently on Rating Watch Negative.  Approximately 87.1% of the
portfolio has a Fitch-derived rating below investment grade and
44.6% has a rating in the 'CCC' rating category or lower, compared
to 78.2% and 5.4%, respectively, at last review.  The reference
portfolio is composed of 79 commercial mortgage backed securities,
of which 96.9% are from the 2004 through 2006 vintages, with the
balance from the 2003 vintage and prior (3.1%).

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  Based on this analysis, all PCM
rating loss rates exceed the credit enhancement available to all
classes.  For all classes, Fitch compared the respective credit
enhancement levels to the amount of distressed assets ('CC' and
below).  Given the high probability of default of these assets and
the expected low recoveries upon default, the class A and B notes
have been downgraded to 'CC' and classes C through M to 'C'.

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

As of the Oct. 21, 2010 trustee report, 11.6% of the eligible
investments are rated below investment grade and 8.6% have a
rating in the 'CCC' category.  According to the transaction
documents, a collateral default constitutes an Optional Early
Termination/Event of Default resulting in a Mandatory Redemption.
Given the credit ratings of the eligible investments, a collateral
default is a real possibility.

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

Fitch has downgraded these classes:

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


ABACUS 2006-17: Fitch Downgrades Ratings on Five Classes
--------------------------------------------------------
Fitch Ratings has downgraded five and affirmed one class of notes
issued by Abacus 2006-17, Ltd., as a result of significant
negative credit migration within the reference portfolio.

Since Fitch's last rating action in November 2009, approximately
47.5% of the reference portfolio has been downgraded, and 13.3% is
currently on Rating Watch Negative.  The entire portfolio is rated
below investment grade and 69.2% has a Fitch-derived rating in the
'CCC' rating category or lower, compared to 97.5% and 25.0%,
respectively, at last review.  The reference portfolio is composed
of 50 commercial mortgage backed securities and five structured
finance collateralized debt obligations, of which 90.8% are CMBS
assets from the 2005 and 2006 vintages, 8.3% are SF CDOs from the
2005 and 2006 vintages, and the balance are CMBS assets from the
2004 vintage (0.8%).

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  Based on this analysis, all PCM
rating loss rates exceed the credit enhancement available to all
classes.  For all classes, Fitch compared the respective credit
enhancement levels to the amount of distressed assets ('CC' and
below).  Given the high probability of default of these assets and
the expected low recoveries upon default, the class A-1 notes have
been affirmed at 'CC' and classes A-2 through M have been
downgraded to 'C'.

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

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

As of the Oct. 21, 2010 trustee report, 33.1% of the eligible
investments is rated 'CC'.  According to the transaction
documents, a collateral default constitutes an Optional Early
Termination/Event of Default resulting in a Mandatory Redemption.
Given the credit ratings of the eligible investments, a collateral
default is a probable.

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

Fitch has taken these rating actions:

  -- $66,000,000 Class A-1 Notes affirmed at 'CCsf';
  -- $72,000,000 Class A-2 Notes downgrade to 'Csf' from 'CCsf';
  -- $16,500,000 Class C Notes downgraded to 'Csf' from 'CCsf';
  -- $13,500,000 Class E Notes downgraded to 'Csf' from 'CCsf';
  -- $5,731,500 Class L Notes downgraded to 'Csf' from 'CCsf';
  -- $3,110,600 Class M Notes downgraded to 'Csf' from 'CCsf'.

In addition, the class B notes have been redeemed at a price of
par.


ABACUS 2007-18: Fitch Downgrades Ratings on Four Classes of Notes
-----------------------------------------------------------------
Fitch Ratings has downgraded four classes of notes issued by
Abacus 2007-18, Ltd., as a result of significant negative credit
migration within the reference portfolio.

Since Fitch's last rating action in November 2009, approximately
45.5% of the portfolio has been downgraded, and 21.8% is currently
on Rating Watch Negative.  Approximately 98.7% of the portfolio
has a Fitch derived rating below investment grade and 77.5% has a
rating in the 'CCC' rating category or lower, compared to 96.8%
and 35.3% 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.  Based on this analysis, all PCM
rating loss rates exceeds the credit enhancement available to all
classes.  For all classes, Fitch compared the respective credit
enhancement levels to the amount of distressed assets ('CC' and
below).  Given the high probability of default of these assets and
the expected low recoveries upon default, all classes have been
assigned a 'C' rating, indicating default is inevitable.

Abacus 2007-18 is a static synthetic collateralized debt
obligation transaction issued in May 2007 that references a
US$1 billion portfolio of CMBS and CRE CDO securities.  The
reference portfolio is composed of 91% CMBS assets from the 2005-
2007 vintage, and 9% are SF CDOs from the 2006 and 2007 vintages.
The transaction is designed to provide credit protection for
realized losses on the reference portfolio through a Credit
Default Swap between the issuer and the swap counterparty, Goldman
Sachs Capital Markets, L.P.

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

Fitch has downgraded these classes:

  -- $80,000,000 Class A-1 Notes to 'Csf' from 'CCCsf';
  -- $11,500,000 Class A-3 Notes to 'Csf' from 'CCCsf';
  -- $5,000,000 Class B Notes to 'Csf' from 'CCsf';
  -- $17,500,000 Class B Series 2 Notes to 'Csf' from 'CCsf'.

In addition, the class A-2 notes have been redeemed at a price of
par.

Fitch does not rate classes C through R.


ACCESS TO: Fitch Downgrades Ratings on Subordinate Notes to 'BB'
----------------------------------------------------------------
Fitch Ratings has affirmed the senior student loan notes at 'AAA'
and downgraded the subordinate notes to 'BB' issued by Access to
Loans for Learning Student Loan Corp. - 1998 Master Trust IV (CA).
Stable Outlooks are assigned to all bonds.  Fitch's Global
Structured Finance Rating Criteria and FFELP student loan ABS
rating criteria, as well as the refined basis risk criteria
outlined in the press release 'Fitch to Gauge Basis Risk in
Auction-Rate U.S. FFELP SLABS Review' dated Sept. 22, 2010 were
used to review the ratings.  A full ratings list is shown below.

The ratings on the senior notes are affirmed based on the
sufficient level of credit enhancement (consisting of
subordination and the projected minimum excess spread) to cover
the applicable risk factor stresses and a qualitative adjustment
accounting for the expected increase in the senior parity as the
transaction pay down.

The ratings on the subordinate notes are downgraded to 'BB'
because the level of hard credit enhancement is only capable of
absorbing the applicable risk factor stress level after accounting
for the trust's ability to generate excess spread, which is very
limited due to the high cost structure of the trust.

Fitch has taken these rating actions:

Access to Loans for Learning Student Loan Corp.-1998 Master Trust
IV (CA)

Series 1998

  -- Class C-1 downgraded to'BB/LS3' from 'BBB/LS3'; Outlook
     Stable.

Series 2000

  -- Class A-3 affirmed at 'AAA/LS1'; Outlook Stable.

Series 2002

  -- Class A-4 affirmed at 'AAA/LS1'; Outlook Stable;
  -- Class A-5 affirmed at 'AAA/LS1'; Outlook Stable.

Series 2003-1

  -- Class A-6 affirmed at 'AAA/LS1'; Outlook Stable;

  -- Class A-7 affirmed at 'AAA/LS1'; Outlook Stable;

  -- Class A-8 affirmed at 'AAA/LS1'; Outlook Stable;

  -- Class A-9 affirmed at 'AAA/LS1'; Outlook Stable;

  -- Class A-10 affirmed at 'AAA/LS1'; Outlook Stable;

  -- Class C-2 downgraded to'BB/LS3' from 'BBB/LS3'; Outlook
     Stable.

Series 2003-2

  -- Class A-11 affirmed at 'AAA/LS1'; Outlook Stable;
  -- Class A-12 affirmed at 'AAA/LS1'; Outlook Stable.

Series 2004

  -- Class A-13 affirmed at 'AAA/LS1'; Outlook Stable.
     Series 2007

  -- Class IV-A-14 affirmed at 'AAA/LS1'; Outlook Stable;

  -- Class IV-A-15 affirmed at 'AAA/LS1'; Outlook Stable;

  -- Class IV-A-16 affirmed at 'AAA/LS1'; Outlook Stable;

  -- Class IV-A-17 affirmed at 'AAA/LS1'; Outlook Stable;

  -- Class IV-A-18 affirmed at 'AAA/LS1'; Outlook Stable.


ACE SECURITIES: Moody's Assigns 'Ba3' Rating to 2006-FM1 Swap
-------------------------------------------------------------
Moody's Investors Service has assigned a Ba3 (sf) rating on the
Certificate Swap to the ACE Securities Corp. Home Equity Loan
Trust, Series 2006-FM1 transaction.  Moody's rating addresses the
credit risk posed to the swap counterparty.  This rating only
addresses the risk attributable to the ability of the trust to
continue to honor its obligations under the swap.  The rating does
not address market risk that may be experienced by the party
facing the trust under the swap contract.

Issuer:

  -- ACE Securities Corp. Home Equity Loan Trust, Series 2006-FM1
     (Reference Number N503602N) Interest Rate Swap, Assigned Ba3
     (sf)

                        Ratings Rationale

The rating takes into account the rating of the swap counterparty,
the transaction's legal structure and the characteristics of the
collateral mortgage pool of the respective trust.  Because there
is relatively limited historical performance data for the types of
instruments, this credit rating may have a greater potential
rating volatility than would ratings for transactions supported by
more historical performance data.

Moody's rating approach for this counterparty instrument rating
rests on three propositions:

* The CIRs are based on an analysis of the payment promise made by
  the trust, the position of the instrument in the payment
  waterfall, the credit quality of the rated payment flows, the
  security arrangements governing the trust's relationship with
  the counterparty, the support mechanisms available to the
  counterparty, the termination date of the swap and other
  structural features of the transaction in question.  In this
  regard, the rating process is similar to that for all other
  ratings assigned by Moody's.

* The credit quality and ratings assigned to counterparty
  instrument obligations of the trust may differ from those of its
  payment obligations to bondholders.  As a result, ratings
  assigned to bonds issued by the trust may diverge from the CIR
  and therefore the bond ratings may offer only a limited guidance
  on the CIR.

* Although counterparty instrument ratings address payments to
  rather than from the counterparty, in certain circumstances the
  credit strength of the counterparty itself may have a bearing on
  the CIR.  For example, where a counterparty's non-performance
  under a swap agreement leads to the trust having to make a
  termination payment to that counterparty, Moody's will take into
  account the likelihood of the counterparty's non-performance
  occurring and the position of termination payments in the cash
  flow waterfall .  Specifically, in the event that the swap
  counterparty causes a termination event, any termination payment
  owed to the swap counterparty may be paid at the bottom of the
  cash flow waterfall.  As a result, a default by the swap
  counterparty, which is currently rated Aa3, makes payment in
  full to the counterparty unlikely.

By way of background, the swap counterparty, Deutsche Bank AG, New
York Branch in this case, receives a fixed rate from, and pays
LIBOR to, the trust on a notional amount that is the lesser of the
aggregate class certificate balance and the amount set forth on
the schedule to the swap agreement.  Per the terms of the deal
documents, the swap counterparty for the swap receives payments,
prior to bondholders, and is thus in a senior position to all
bonds issued by the trust.  The termination date for the
Certificate Swap is 13th May, 2013.  To pay the swap counterparty,
the trust also has access to principal payments, liquidation
proceeds and interest collections.  This provision strengthens the
nature of senior payment right of the swap counterparty.

The primary risks driving the rating on the swap is the risk that
the collateral pool amortizes at a rate that exceeds the
amortization rate of the swap notional and the risk of a
termination event triggered by a default of the swap counterparty.
As the losses are not allocated to the senior certificates, it is
likely, especially in high default scenarios, that the collateral
balance would amortize faster than the swap notional.  The
counterparty in the swap, Deutsche Bank AG, New York Branch, has a
Aa3 long term rating and a P-1 short term rating by Moody's.

Moody's methodology for rating swaps on US RMBS transactions
includes running collateral cashflows and considers the rating of
the swap counterparty.  Moody's stress the cashflows by increasing
defaults and prepayments to determine what level of collateral
stress would cause a shortfall in proceeds owed to the swap
counterparty.  The cashflows are modeled to reflect the waterfall
of the underlying transaction, which results in all swap payments
other than termination payments caused by a counterparty default
coming at the top of the waterfall.  Termination payments owed to
the swap counterparty resulting from a default of the swap
counterparty are paid at the bottom of the waterfall.  The swap in
this transaction passed scenarios consistent with the Ba3
collateral cashflow stresses Additional qualitative considerations
that were not modeled, such as the impact of a decline in the
weighted average interest rate of the collateral pool, interest
rate reduction modifications or more conservative servicer
advancing approaches, were also analyzed.

Moody's projected remaining loss on the mortgage pool as a
percentage of the current balance is 63%.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments in this transaction.


AERCO LIMITED: Fitch Affirms Ratings on Various Classes of Notes
----------------------------------------------------------------
Fitch Ratings has affirmed, upgraded, revised Recovery Ratings and
assigned Rating Outlooks to AerCo Limited:

  -- Class A-3 notes at 'BBsf'; Outlook Negative;
  -- Class A-4 notes to 'Asf' from 'BBBsf'; Outlook Stable;
  -- Class B-1 and B-2 revised to 'Csf/RR5' from 'Csf/DR4';
  -- Class C-1, C-2, and D-2 revised to 'Dsf/RR6' from 'Dsf/DR6'.

Consistent with Fitch's criteria titled 'Global Rating Criteria
for Aircraft Operating Lease ABS,' dated March 31, 2010, Fitch's
analysis incorporated the expected net cash flow to be available
to service debt over the remaining life of the transaction.
Fitch's expected cash flow takes several factors into account,
including aircraft age, portfolio value, Fitch's expectations for
the commercial aviation industry, remarketing expenses and
downtime, potential lease rates on the aircraft, and perceived
liquidity of the aircraft in the portfolio.

The upgrade to the class A-4 notes reflects the class' ability to
receive full payments of principal and interest under Fitch's
'Asf' stress scenarios.  Due to the scheduled amortization as
defined in transaction documents, Fitch expects the class will pay
in full in the next seven months.

The affirmation and assignment of a Negative Outlook to the class
A-3 notes is representative of the decrease in monthly rental
collections and the deteriorating collateral position, as measured
by the loan to value ratio, since last review.  As such there is
potential for future negative rating actions if these trends
continue.

The revision to the Recovery Rating for the Class B-1 and B-2
notes reflects the decreased recovery expectations as interest
shortfalls continue to accumulate and the classes remain locked
out from either principal or interest distributions.

The 'Dsf/RR6' rating on the class C-1, C-2, and D-2 notes
indicates that Fitch does not expect the accumulating interest
shortfalls will be recouped as the notes are not expected to
receive any further distributions.


ARBOR REALTY: Fitch Downgrades Ratings on Two Classes of Notes
--------------------------------------------------------------
Fitch Ratings has downgraded two and affirmed seven classes of
Arbor Realty Mortgage Securities series 2005-1 Ltd/LLC reflecting
Fitch's increased base case loss expectation of 41.2%.  Fitch's
performance expectation incorporates prospective views regarding
commercial real estate market value and cash flow declines.

The downgrades to the bottom two rated classes are a result of the
slightly increased base case expected loss of 41.2% from 40% at
last review; and decreased credit enhancement due to realized
losses.  Total net realized losses since last review are estimated
at $32.5 million.  As of the Sept. 30, 2010 trustee report, total
collateral was $457.3 million compared to total liabilities of
$466.3 million, leaving the transaction under-collateralized.

Since last review, nine assets have been removed (including two
loan payoffs) from the collateralized debt obligation (CDO), with
seven assets newly contributed.  The new assets have a higher
average expected loss than the assets previously in the pool.
Further, while defaulted assets are currently 5.4% compared to
8.4% at last review; Fitch loans of concern are significantly
higher at 37.6% from 11% at last review.

ARMSS 2005-1 is a commercial real estate CDO managed by Arbor
Realty Trust, Inc.  The transaction has a five-year reinvestment
period that ends in April 2011.  As of the Sept. 30, 2010 trustee
report, all overcollateralization and interest coverage ratios
were in compliance.

Under Fitch's methodology, approximately 66.3% of the portfolio is
modeled to default in the base case stress scenario, defined as
the 'B' stress.  In this scenario, the modeled average cash flow
decline is 7.3% from, generally, either year end 2009 or trailing
12-month first or second quarter 2010.  Fitch estimates that
average recoveries will be 37.8% as many of the assets are highly
leveraged and subordinate in nature.

The largest component of Fitch's base case loss expectation is a
B-note secured by a large office building located in downtown St.
Louis, MO.  The second largest tenant (14% of the NRA) recently
vacated the property.  While the property currently supports debt
service; it is not expected to once amortization begins in early
2012.  Fitch modeled a term default and a full loss on this
overleveraged position in its base case scenario.

The next largest component of Fitch's base case loss expectation
is a defaulted B-note secured by a portfolio of eight multifamily
properties located in the southeastern United States.  The
borrower filed Chapter 11 in January 2010.  Fitch modeled a full
loss in its base case scenario.

The third largest component of Fitch's base case loss expectation
is a junior mezzanine position on a 1.6 million square foot office
building located in midtown Manhattan.  Fitch modeled a term
default and a substantial loss on this highly leveraged position
in its base case scenario.

This transaction was analyzed according to the 'U.S. CREL CDO
Surveillance Criteria', which applies stresses to property cash
flows and debt service coverage ratio tests to project future
default levels for the underlying portfolio.  Cash flow stresses
have been updated to reflect more recently available data on
commercial real estate performance.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under the various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.
Based on this analysis, the class A notes' credit characteristics
are generally consistent with the 'BBB' rating category; the class
B through E notes' credit characteristics are generally consistent
with the 'BB' rating category; and the class F notes' credit
characteristics are generally consistent with the 'B' rating
category.

The ratings for classes G and H are based on a deterministic
analysis, which considers Fitch's base case loss expectation for
the pool, and the current percentage of defaulted assets and Fitch
Loans of Concern factoring in anticipated recoveries relative to
each class' credit enhancement.  Based on this analysis, classes G
and H are consistent with the 'CCC' rating category, meaning
default is a real possibility.  Fitch's base case loss expectation
of 41.2% exceeds these classes' respective current credit
enhancement levels.

Class A-1's Rating Outlook is revised to Stable from Negative
reflecting the class's senior position in the capital stack, and
positive cushion in the cash flow modeling.  Class A-2 through F
maintain a Negative Rating Outlook reflecting Fitch's expectation
of further negative credit migration of the underlying collateral.
These classes also maintain Loss Severity ratings ranging from
'LS4' to 'LS5'.  The LS ratings indicate each tranche's potential
loss severity given default, as evidenced by the ratio of tranche
size to the expected loss for the collateral under the 'B' stress.
LS ratings should always be considered in conjunction with
probability of default indicated by a class' long-term credit
rating.

Classes G and H are assigned Recovery Ratings to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.  Recovery Ratings are
calculated using Fitch's cash flow model, and incorporate Fitch's
current 'B' stress expectation for default and recovery rates, the
'B' stress US$ LIBOR up-stress, and a 24-month recovery lag.  All
modeled distributions are discounted at 10% to arrive at a present
value and compared to the class' tranche size to determine a
Recovery Rating.  The assumptions for the 'B' stress US$ LIBOR up-
stress scenario are found in Fitch's report, 'Criteria for
Interest Rate Stresses in Structured Finance Transactions'
(April 26, 2010), available on Fitch's web site at
'www.fitchratings.com'.

The assignment of 'RR5' to class G reflects modeled recoveries of
18% of its outstanding balance.  The expected recovery proceeds
are broken down:

  -- Present value of expected principal recoveries ($0 million);
  -- Present value of expected interest payments ($1.8 million);
  -- Total present value of recoveries ($1.8 million);
  -- Sum of undiscounted recoveries ($3.4 million).

Class H is assigned a Recovery Rating of 'RR6' as the present
value of the recoveries is less than 10% of the class's principal
balance.

Fitch has affirmed and revised Outlooks for these classes, as
indicated:

  -- $161,500,000 class A-1 affirmed at 'BBBsf/LS4'; Outlook
     revised to Stable from Negative;

  -- $40,375,000 class A-2 affirmed at 'BBBsf/LS5'; Outlook
     Negative;

  -- $57,000,000 class B affirmed at 'BBsf/LS5'; Outlook Negative;

  -- $23,211,890 class C affirmed at 'BBsf/LS5'; Outlook Negative;

  -- $7,964,890 class D affirmed at 'BBsf/LS5'; Outlook Negative;

  -- $7,056,415 class E affirmed at 'BBsf/LS5'; Outlook Negative;

  -- $13,741,439 class F affirmed at 'Bsf/LS5'; Outlook Negative.

Fitch has downgraded and assigned recovery ratings (RR) to these
classes, as indicated:

  -- $10,213,232 class G downgraded to 'CCCsf/RR5' from
     'Bsf/LS5';;

  -- $13,927,134 class H downgraded to 'CCCsf/'RR6' from
     'Bsf/LS5'.


ARTUS LOAN: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1L, A-2L, A-3L, B-1L, and B-2L notes from Artus Loan Fund 2007-I
Ltd., a collateralized loan obligation transaction managed by
Babson Capital Management LLC.  At the same time, S&P removed its
ratings on the class A-1L and A-2L notes from CreditWatch
positive.

The upgrades reflect factors that have positively affected the
credit enhancement available to support the notes since S&P
downgraded the notes in December 2009 - specifically the
transaction's delevering.

Since December 2009, the transaction has paid down approximately
$158 million to the class A-1L notes, including a payment of
$58 million on the Aug. 4, 2010, distribution date.  At the time
of S&P's last rating action, based on the Nov. 3, 2009 trustee
report, the transaction held approximately $66 million in
defaulted obligations.  Since that time, a number of defaulted
obligors held in the deal emerged from bankruptcy, and some
received proceeds that were higher than their carrying value in
the overcollateralization ratio test calculations.  As of the
Sept. 2, 2010 trustee report, the transaction held approximately
$33 million as defaulted obligors.  The reduced number of
defaulted assets held, combined with a $158 million paydown on the
class A-1L notes, have benefited the O/C ratio tests, thereby
increasing the O/C available to support the rated notes.

                    Coverage Ratio Comparison

     Test name                   Sept. 2, 2010    Nov. 3, 2009
     ---------                   -------------    ------------
     Senior class A O/C (%)      129.85           119.15
     Class A O/C (%)             119.20           111.75
     Class B-1L O/C (%)          112.96           107.27
     Class B-2L O/C (%)          105.97           100.15
     Interest coverage ratio (%) 2.76             2.17

                   O/C - Overcollateralization.

Standard & Poor's will continue to review whether, in S&P's view,
the ratings currently assigned to the notes remain consistent with
the credit enhancement available to support them and take rating
actions as S&P deem necessary.

                         Rating Actions

                   Artus Loan Fund 2007-I Ltd.

                               Rating
                               ------
        Class             To           From
        -----             --           ----
        A-1L              AA+ (sf)     AA- (sf)/Watch Pos
        A-2L              AA (sf)      A- (sf)/Watch Pos
        A-3L              A- (sf)      BBB- (sf)
        B-1L              BBB- (sf)    BB (sf)
        B-2L              B+ (sf)      CCC+ (sf)

  Transaction Information
  -----------------------
Issuer:             Artus Loan Fund 2007-I Ltd.
Coissuer:           Artus Loan Fund 2007-I LLC
Collateral manager: Babson Capital Management LLC
Underwriter:        Bear Stearns Cos. LLC (The)
Indenture trustee:  State Street Bank and Trust Co.
                    (Boston, Mass.)
Transaction type:   Cash flow CLO


BANC OF AMERICA: Fitch Downgrades Ratings on 14 Classes
-------------------------------------------------------
Fitch Ratings has downgraded 14 classes of Banc of America
Commercial Mortgage Inc. commercial mortgage pass-through
certificates series 2005-4.

As a result of the expected losses on loans currently in special
servicing, Fitch expects classes H through P to be fully depleted.
As of the October 2010 distribution date, the pool's aggregate
principal balance has been paid down by 12.6% to $1.39 billion
from $1.59 billion at issuance.  As of October 2010, cumulative
interest shortfalls affect classes F through P.

Fitch has designated 44 loans (36.7%) as Fitch Loans of Concern,
which includes 18 specially serviced loans (19%).  The largest
specially serviced loan, Pacific Arts Plaza (7.9%), is an 825,061
square foot (sf) office property located in Costa Mesa, CA.  This
loan transferred to special servicing in August 2009 for imminent
default after the borrower requested debt relief.  The property
was approximately 75% occupied as of the year-end 2009 rent roll,
compared to approximately 88% at issuance.  As of year-end 2009
the reported debt service coverage ratio was 0.84 times, compared
to 1.32x at issuance.  The loan is pari passu with the $132
million A-1 note in the BACM 2005-3 transaction.  The loan was
structured as full interest only and the sponsor is Maguire
Properties, L.P.  The borrower and the lender have agreed on the
appointment of a receiver with the right to market and sell the
property.

The next largest specially serviced loan, Colonade Apartments
(2.7%), is a 535 unit multifamily and a 78,463 sf office mixed-use
property located in Jenkintown, PA, approximately nine miles north
of the Philadelphia central business district.  As of year-end
2009 the servicer-reported DSCR and occupancy were 0.82x and 55%.
The sponsor is Jeffrey J.  Cohen.  The loan is now amortizing on a
30-year schedule, following three years interest only.

The third largest specially serviced loan (1.2%) is a real estate
owned 240-unit multifamily complex located in Las Vegas, NV.  The
loan transferred Oct. 1, 2008, after the borrower obtained a
subordinate loan not approved by the lender.  The most recent
reported DSCR was 0.90x as of the third quarter of 2009.  At that
time, the property was 83% occupied.

Fitch stressed the value of the non-defeased loans by applying a
5% haircut to 2009 fiscal year-end net operating income (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 that
could refinance to a DSCR of 1.25x or higher were considered to
pay off at maturity.  Of the non-defeased or non-specially
serviced loans, 79 loans (72.6% of the overall pool) were assumed
not to be able to refinance, of which Fitch modeled losses for 33
loans (31.2%) in instances where Fitch's derived value was less
than the outstanding balance.  The pool has above average leverage
with a weighted average Fitch stressed loan-to-value ratio for
non-defeased and non-specially serviced loans of 94.3%.

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

  -- $97.1 million class A-J to 'BBB-sf/LS4' from 'A/LS4'; Outlook
     to Stable;

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

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

  -- $17.8 million class E to 'CCCsf/RR1' from 'B/LS5';

  -- $19.8 million class F to 'CCCsf/RR4' from 'B-/LS5';

  -- $17.8 million class G to 'CCCsf/RR6' from 'B-/LS5';

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

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

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

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

  -- $4 million class M to 'CCsf/RR6' from 'CCC/RR6';

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

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

Fitch has affirmed these classes:

  -- $177.9 million class A-1A at 'AAAsf/LS2'; Outlook Stable;
  -- $215.5 million class A-2 at 'AAAsf/LS2'; Outlook Stable;
  -- $87.9 million class A-3 at 'AAAsf/LS2'; Outlook Stable;
  -- $70 million class A-4 at 'AAAsf/LS2'; Outlook Stable;
  -- $61.2 million class A-SB at 'AAAsf/LS2'; Outlook Stable;
  -- $485.9 million class A-5A at 'AAAsf/LS2'; Outlook Stable;
  -- $69.4 million class A-5B at 'AAAsf/LS2'; Outlook Stable;
  -- $15.9 million class C at 'BBsf/LS5'; Outlook Negative.

The $22 million class P is not rated by Fitch.  Class A-1 has paid
in full.  Fitch has withdrawn the ratings on the interest-only
classes X-P and X-C.


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

  -- $23.1 million class E to 'AAsf/LS5' from 'AAA/LS5'; Outlook
     Negative;

  -- $21 million class F to 'Asf/LS5' from 'AA/LS5'; Outlook
     Negative;

  -- $23.1 million class G to 'BBsf/LS5' from 'A/LS5'; Outlook
     Negative;

  -- $21 million class H to 'Bsf/LS5' from 'BBBLS5'; Outlook
     Negative.

Fitch downgrades and assigns Recovery Ratings to these classes:

  -- $18.9 million class J to 'CCCsf/RR1' from 'BB/LS5';
  -- $10.5 million class K to 'CCsf/ RR6' from 'B/LS5';
  -- $10.5 million class L to 'Csf/ RR6' from 'B-/LS5';
  -- $8.4 million class M to 'Csf/RR6' from 'B-LS5';
  -- $8.4 million class N to 'Csf/RR6' from 'CC/RR6'.

Additionally, Fitch affirms, revises LS ratings, and assigns
Outlooks to these classes:

  -- $340.3 million class A-1A at 'AAAsf/LS2'; Outlook Stable;
  -- $15.7 million class A-2 at 'AAAsf/LS2'; Outlook Stable;
  -- $168.1 million class A-3 at 'AAAsf/LS2'; Outlook Stable;
  -- $482.3 million class A-4 at 'AAAsf/LS2'; Outlook Stable;
  -- $56.7 million class B at 'AAAsf/LS5'; Outlook Stable;
  -- $44.1 million class D at 'AAAsf/LS5; Outlook Negative.

In addition, Fitch has affirmed and assigned Outlooks and LS
ratings to these classes as indicated:

  -- $21 million class C at 'AAAsf/LS5'; Outlook Stable;
  -- $2.5 million class BW-A at 'AAAsf/LS1'; Outlook Stable;
  -- $1.1 million class BW-B at 'AAAsf/LS1'; Outlook Stable;
  -- $8.2 million class BW-C at 'AAAsf/LS1'; Outlook Stable;
  -- $2.5 million class BW-D at 'AAAsf/LS1'; Outlook Stable;
  -- $3.4 million class BW-E at 'AAAsf/LS1'; Outlook Stable;
  -- $3 million class BW-F at 'AAAsf/LS1'; Outlook Stable;
  -- $2.9 million class BE-G at 'AAAsf/LS1'; Outlook Stable;
  -- $2.5 million class BW-H at 'AAAsf/LS1'; Outlook Stable;
  -- $2.5 million class BW-J at 'AAAsf/LS1'; Outlook Stable;
  -- $2 million class BW-K at 'AAAsf/LS1'; Outlook Stable;
  -- $3.3 million class BW-L at 'AAAsf/LS1'; Outlook Stable;
  -- $4.2 million class O at 'C/RR6'.

Fitch does not rate the $14.3 million class P or classes HS-A
through HS-E.

Fitch withdraws the ratings of the interest only classes X-C and
X-P .

The downgrades are the result of projected losses on the specially
serviced assets (7.5%) and future expected losses following
Fitch's prospective review of potential stresses to the
transaction.  Fitch expects losses of 4.9% of the remaining
transaction balance, or $67.5 million, from loans in special
servicing and loans that cannot refinance at maturity based on
Fitch's refinance test.  Rating Outlooks reflect the likely
direction of any changes to the ratings over the next one to two
years.

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

There are 117 of the original 152 loans remaining in the
transaction, 23 of which have defeased (28.3% of the current
transaction balance).

As of the October 2010 distribution date, the pool's aggregate
principal balance has been paid down by 22.1% to $1.38 billion
from $1.8 billion at issuance.  Currently 23 loans (28.3%) are
defeased.  As of October 2010, cumulative interest shortfalls
affect classes J through P.

The largest specially serviced asset (2.61%) is a manufactured
housing community in Justice, IL.  The loan transferred to special
servicing Oct. 19, 2009, due to a mechanics lien being filed.  The
loan matured on May 1, 2009, and the borrower requested a two-year
extension which was denied by the special servicer.  Subsequently,
the borrower filed Chapter 11 bankruptcy on May 17, 2010.  A
hearing is set for a motion of relief of stay which will be heard
in bankruptcy court on Nov. 22 and 23, 2010.

The second largest specially serviced asset (1.59%) is a real
estate owned multifamily property in Irving, TX.  The loan
transferred to special servicing on Aug. 29, 2008, and foreclosed
on Jan. 6, 2009.  The special servicer intends to reposition the
property for sale.  Occupancy has steadily risen to 71% from 59%
at the time of foreclosure; however, losses are still expected.

The Hines Sumitomo portfolio, the largest loan in the pool, is
secured by three office properties, two of which are located in
New York, NY and the third in Washington, DC.  The 425 Lexington
Avenue building in New York is fully occupied.  The 499 Park
Avenue building in New York is occupied at 81.3% and the 1200
Nineteenth Avenue building in Washington, DC is occupied at 55.7%.
Total combined occupancy is at 84.6%.

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 7.5% and
10% to determine value.

Similar to Fitch's prospective analysis of recent vintage CMBS,
each loan also underwent a refinance test by applying an 8%
interest rate and a 30-year amortization schedule based on the
stressed cash flow.  Loans that could refinance to a debt service
coverage ratio of 1.25 times or higher were considered to payoff
at maturity.  Anticipated losses due to the refinance test were
$20.8 million.


BANC OF AMERICA: Moody's Downgrades Ratings on 14 2005-5 Certs.
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of 14 classes,
confirmed one class and affirmed seven classes of Banc of America
Commercial Mortgage, Inc., Commercial Mortgage Pass-Through
Certificates, Series 2005-5:

  -- Cl. A-2, Affirmed at Aaa (sf); previously on Oct. 17, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3A, Affirmed at Aaa (sf); previously on Oct. 17, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3B, Affirmed at Aaa (sf); previously on Oct. 17, 2005
     Assigned Aaa (sf)

  -- Cl. A-SB, Affirmed at Aaa (sf); previously on Oct. 17, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed at Aaa (sf); previously on Oct. 17, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. XP, Affirmed at Aaa (sf); previously on Oct. 17, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. XC, Affirmed at Aaa (sf); previously on Oct. 17, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-M, Confirmed at Aaa (sf); previously on Sept. 22, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-J, Downgraded to Aa3 (sf); previously on Sept. 22, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Downgraded to A3 (sf); previously on Sept. 22, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Downgraded to Baa1 (sf); previously on Sept. 22, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to Baa3 (sf); previously on Sept. 22, 2010
     A2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to Ba2 (sf); previously on Sept. 22, 2010
     A3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to B2 (sf); previously on Sept. 22, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to Caa1 (sf); previously on Sept. 22, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. H, Downgraded to Ca (sf); previously on Sept. 22, 2010
     Ba2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. J, Downgraded to C (sf); previously on Sept. 22, 2010 B1
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. K, Downgraded to C (sf); previously on Sept. 22, 2010 B2
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. L, Downgraded to C (sf); previously on Sept. 22, 2010 B3
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. M, Downgraded to C (sf); previously on Sept. 22, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. N, Downgraded to C (sf); previously on Sept. 22, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. O, Downgraded to C (sf); previously on Sept. 22, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans.

The confirmation and affirmations are due to key parameters,
including Moody's loan to value ratio, Moody's stressed debt
service coverage ratio and the Herfindahl Index (Herf), remaining
within acceptable ranges.  Based on Moody's current base expected
loss, the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings.

On September 22, 2010 Moody's placed 15 classes on review for
possible downgrade.  This action concludes Moody's review.

Moody's rating action reflects a cumulative base expected loss of
7.0% of the current balance.  At last review, Moody's cumulative
base expected loss was 4.4%.  Moody's stressed scenario loss is
19.5% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl score
(Herf), a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the underlying rating of the
loan which corresponds to a range of credit enhancement levels.
Actual fusion credit enhancement levels are selected based on loan
level diversity, pool leverage and other concentrations and
correlations within the pool.  Negative pooling, or adding credit
enhancement at the underlying rating level, is incorporated for
loans with similar credit estimates in the same transaction.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated March 25, 2009.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.

                         Deal Performance

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 15% to $1.7 billion
from $1.9 billion at securitization.  The Certificates are
collateralized by 93 mortgage loans ranging in size from less than
1% to 6% of the pool, with the top ten loans representing 47% of
the pool.  The pool contains one loan with an investment grade
credit estimate that represents 3% of the pool.  Two loans,
representing 1% of the pool, have defeased and are collateralized
with U.S. Government securities.

Twenty-one 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 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 realized loss of $14.5 million (32% loss severity
overall).  Seven loans, representing 7% of the pool, are currently
in special servicing.  Moody's has estimated an aggregate
$52.5 million loss (46% expected loss on average) for the
specially serviced loans.

Moody's has assumed a high default probability for six poorly
performing loans representing 3% of the pool and has estimated a
$10.1 million aggregate loss (20% expected loss based on a 40%
probability default) from these troubled loans.

Moody's was provided with full year 2009 operating results for
100% of the pool.  Excluding specially serviced and troubled
loans, Moody's weighted average LTV is 104% compared to 114% at
Moody's prior review.  Moody's net cash flow reflects a weighted
average haircut of 13% to the most recently available net
operating income.  Moody's value reflects a weighted average
capitalization rate of 9.2%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.52X and 1.06X, respectively, compared to
1.33X and 0.91X at last review.  Moody's actual DSCR is based on
Moody's net cash flow (NCF) 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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 32, essentially the same as at Moody's prior
review.

The loan with a credit estimate is the Torre Mayor Loan
($52.7 million -- 3.2%), which is secured by a 829,000 square foot
Class A office building located in Mexico City, Mexico.  The loan
represents a 50% pari-passu interest in a $124.6 million senior
note.  There is also a subordinate $19.2 million note held outside
the trust.  The property was 98% leased as of December 2009.
Property performance has remained stable.  Moody's current credit
estimate and stressed DSCR are A1 and 1.64X, respectively,
compared to A1 and 2.08X at last review.

The top three performing conduit loans represent 18% of the pool
balance.  The largest loan is the One Renaissance Square Loan
($103.6 million -- 6.2%), which is secured by a 492,000 square
foot Class A office building located in downtown Phoenix, Arizona.
The property was 79% leased as of June 2010, similar to last
review.  Performance has been stable since last review.  The loan
matures in April 2012.  Moody's LTV and stressed DSCR are 146% and
0.66X, respectively, compared to 152% and 0.65X at last review.

The second largest loan is the Sotheby's Building Loan
($99.7 million -- 6.0%), which is secured by a 406,000 square foot
office building located in New York City.  The loan represents a
48% pari-passu interest in a $209.4 million loan.  The property is
100% leased to Sotheby's (Moody's senior unsecured rating Ba3,
stable outlook) through December 2022.  Moody's LTV and stressed
DSCR are 109% and 0.85X, respectively, essentially the same as at
last review.

The third largest loan is the Fireman's Fund Loan ($91.9 million -
- 5.5%), which is secured by a 710,000 square foot office property
located in Novato, California.  The property is 100% leased to
Fireman's Fund Insurance Company (Moody's insurance financial
strength rating A2, stable outlook) through November 2018.
Moody's LTV and stressed DSCR are 105% and 1X, respectively,
essentially the same as at last review.


BEAR STEARNS: Fitch Downgrades Ratings on 11 2005-PWR7 Certs.
-------------------------------------------------------------
Fitch Ratings has downgraded 11 classes of Bear Stearns Commercial
Mortgage Securities Trust, 2005-PWR7 commercial mortgage pass-
through certificates, due to further deterioration of performance.

While projected losses on loans in special servicing remained
fairly consistent relative to the previous review, Fitch-modeled
losses across the pool increased due to asset-specific performance
issues evidenced by a 13.4% year-over-year decline in Fitch-
adjusted net operating income for all non-defeased, non-specially
serviced loans in the pool.  The year-over-year servicer-reported
NOI decline was lower at 5.6%.

As of the October 2010 distribution date, the pool's aggregate
principal balance has been reduced by 10.4% to $1.01 billion from
$1.12 billion at issuance, including paydown of 10.3% and realized
losses of 0.1%.  Three loans (3.2%) are currently defeased.  As of
October 2010, cumulative interest shortfalls only affect classes J
through Q.

Fitch identified 23 Loans of Concern (30.4%) within the pool, of
which four (8.9%) are specially serviced.  Six of the Fitch Loans
of Concern (19.9%) are within the transaction's top 15 loans,
including two loans (8.1%) that are specially serviced.

The largest specially serviced loan, Shops at Boca Park (5.4%) is
secured by 140,415 square feet (sf) of a 279,768-sf lifestyle
center located in Summerlin, NV, northwest of Las Vegas.  The
property's largest noncollateral tenant, The Great Indoors
(139,353 sf, ground leased through March 2022), vacated in 2009,
though the tenant continues to pay ground rent.  The borrower has
signed six leases in 2010, including the second-largest collateral
space at the property (19%), which had previously been leased to
Linens 'n Things.  As of the most recent rent roll provided by the
special servicer, the collateral was 90.4% occupied.  The total
center was 45.4% physically occupied and 95.2% economically
occupied, compared with 97.9% at issuance.  Fitch was unable to
obtain updated financials for the property.  The borrower
initially discussed modification and forbearance options with the
special servicer, but filed for Chapter 11 bankruptcy protection
on June 17, 2010.  According to the special servicer, a cash
collateral order that provides for the borrower to make monthly
payments of $225,000 was agreed to and executed in August 2010.

The second largest specially serviced loan, Garden State Pavilion
(2.6%), is secured by 257,353 sf of a 389,384-sf anchored retail
center in Cherry Hill, NJ.  Major tenants at the subject include
ShopRite (28.7% of the NRA), Ross Dress for Less (11.7%), and
Staples (9.2%).  The loan transferred to the special servicer
Jan. 5, 2009, and has since become real estate owned.  Occupancy
was most recently reported at 76%, compared with 83% at issuance.
The decline in occupancy was manly driven by the loss of Old Navy
and Rack Room Shoes.  As of third-quarter 2010, the servicer-
reported debt service coverage ratio was 0.54 times, unchanged
from one year prior.

Fitch stressed the value of the non-defeased loans by applying a
5% haircut to 2009 fiscal year-end NOI and applying an adjusted
market cap rate between 7.25% and 10% to determine value.  In
certain cases, Fitch adjusted the NOI based on recent performance
developments such as lease signings, tenant vacancies, or rent
reductions.

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 DSCR of 1.25x or higher were considered to
pay off at maturity.  Of the non-defeased or non-specially
serviced loans, 48 loans (48.2% of the overall pool) were assumed
not to be able to refinance, of which Fitch modeled losses for 19
loans (21.8%) in instances where Fitch's derived value was less
than the outstanding balance.

Fitch has downgraded these classes and revised or assigned Loss
Severity ratings and Recovery Ratings (RR) as indicated:

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

  -- $33.7 million class B to 'BBsf/LS5' from 'A/LS4'; Outlook
     Stable;

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

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

  -- $11.2 million class E to 'B-sf/LS5' from 'BB/LS5'; Outlook
     Negative;

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

  -- $9.8 million class G to 'CCCsf/RR1' from 'B/LS5';

  -- $12.7 million class H to 'CCCsf/RR1' from 'B-/LS5';

  -- $4.2 million class J to 'CCsf/RR6' from 'B-/LS5';

  -- $4.2 million class K to 'Csf/RR6' from 'CCC/RR6';

  -- $5.6 million class L to 'Csf/RR6' from 'CCC'/RR6;

In addition, Fitch has affirmed these classes as indicated:

  -- $165.8 million class A-2 at 'AAAsf/LS1'; Outlook Stable;
  -- $90.8 million class A-AB at 'AAAsf/LS1'; Outlook Stable;
  -- $527.7 million class A-3 at 'AAAsf/LS1'; Outlook Stable;
  -- $4.2 million class M at 'Csf/RR6';
  -- $1.4 million class N at 'Csf/RR6';
  -- $2.8 million class P at 'Csf/RR6'.

Fitch does not rate the $12.5 million class Q.  Class A-1 has paid
in full.  Fitch has withdrawn the ratings on the interest-only
classes X-1 and X-2.


BEAR STEARNS: Moody's Downgrades Ratings on Four 2003-TOP12 Certs.
------------------------------------------------------------------
Moody's Investors Service downgraded the ratings of four classes
and affirmed 12 classes of Bear Stearns Commercial Mortgage
Securities Trust 2003-TOP12, Commercial Mortgage Pass-Through
Certificates, Series 2003-TOP12:

  -- Cl. A-3, Affirmed at Aaa (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed at Aaa (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-1, Affirmed at Aaa (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-2, Affirmed at Aaa (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned Aaa (sf)

  -- Cl. B, Affirmed at Aaa (sf); previously on Jan. 11, 2007
     Upgraded to Aaa (sf)

  -- Cl. C, Affirmed at Aa2 (sf); previously on Aug. 7, 2008
     Upgraded to Aa2 (sf)

  -- Cl. D, Affirmed at A1 (sf); previously on Aug. 7, 2008
     Upgraded to A1 (sf)

  -- Cl. E, Affirmed at A3 (sf); previously on Aug. 7, 2008
     Upgraded to A3 (sf)

  -- Cl. F, Affirmed at Baa2 (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned Baa2 (sf)

  -- Cl. G, Affirmed at Baa3 (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned Baa3 (sf)

  -- Cl. H, Affirmed at Ba1 (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned Ba1 (sf)

  -- Cl. J, Affirmed at Ba2 (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned Ba2 (sf)

  -- Cl. K, Downgraded to B1 (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned Ba3 (sf)

  -- Cl. L, Downgraded to B3 (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned B1 (sf)

  -- Cl. M, Downgraded to Caa3 (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned B2 (sf)

  -- Cl. N, Downgraded to C (sf); previously on Oct. 17, 2003
     Definitive Rating Assigned B3 (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from anticipated losses from specially serviced and
troubled loans.  The affirmations are due to key parameters,
including Moody's loan to value ratio, Moody's stressed debt
service coverage ratio and the Herfindahl Index, remaining within
acceptable ranges.  Based on Moody's current base expected loss,
the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings.

Moody's rating action reflects a cumulative base expected loss of
2.3% of the current balance.  At last review, Moody's cumulative
base expected loss was 1.4%.  Moody's stressed scenario loss is
4.4% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the underlying rating of the
loan which corresponds to a range of credit enhancement levels.
Actual fusion credit enhancement levels are selected based on loan
level diversity, pool leverage and other concentrations and
correlations within the pool.  Negative pooling, or adding credit
enhancement at the underlying rating level, is incorporated for
loans with similar credit estimates in the same transaction.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated August 7, 2008.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

As of the October 13, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 37% to
$733.5 million from $1.16 billion at securitization.  The
Certificates are collateralized by 123 mortgage loans ranging
in size from less than 1% to 8% of the pool, with the top ten
loans representing 38% of the pool.  Thirteen loans, representing
8% of the pool, have defeased and are collateralized with U.S.
Government securities.  The pool contains nine loans, representing
27% of the pool with investment grade credit estimates.

Nineteen loans, representing 10% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council 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 since
securitization, resulting in an aggregate $25,466 loss (0.03% loss
severity on average).  Currently four loans, representing 2% of
the pool, are in special servicing.  The master servicer has
recognized an aggregate $2.4 million appraisal reduction for two
of the specially serviced loans.  Moody's has estimated an
aggregate $6.3 million loss (35% expected loss on average) for the
specially serviced loans.

Moody's has assumed a high default probability for four poorly
performing loans representing 1.7% of the pool and has estimated a
$3.1 million loss (25% expected loss based on a 50% probability
default) from these troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 98% and 60% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 64% compared to 69% at last review.  Moody's net
cash flow reflects a weighted average haircut of 12% to the most
recently available net operating income.  Moody's value reflects a
weighted average capitalization rate of 9.5%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 2.06X and 1.79X, respectively, compared to
1.66X and 1.59X 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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 41 compared to 50 at Moody's prior review.

The largest loan with a credit estimate is the WestShore Plaza
Loan ($58.4 million -- 8.0%), which represents a 66% pari passu
interest in a $88.5 million first mortgage loan.  The loan is
secured by the borrower's interest in 1.06 million square foot
(collateral represents 356,024 square feet) regional mall located
in Tampa, Florida.  The center is anchored by Macy's, Sears and
Saks Fifth Avenue.  The in-line space was 93% occupied as of June
2010 compared to 97% at last review.  Financial performance is
stable and the loan is benefitting from amortization.  The loan
has amortized 4% since last review and matures in September 2012.
Moody's current credit estimate and stressed DSCR are A2 and
1.56X, respectively, same as at last review.

The second largest loan with a credit estimate is the West Valley
Mall Loan ($53.3 million -- 7.3%), which is secured by the
borrower's interest in 717,573 square foot (collateral represents
621,697 square feet) regional mall located in Tracy, California.
The center is anchored by Target, J.C. Penney and Sears, and most
recently Macy's.  The inline space was 76% occupied as of March
2010 compared to 84% at last review.  Financial performance has
deteriorated since last review due to lower rental income from
increased vacancy.  Gottschalks, the former largest collateral
tenant, vacated the center following its bankruptcy; however,
Macy's has filled this space with a store opening in October 2010.
The loan's sponsor, General Growth Properties Inc., included the
loan in its bankruptcy.  The loan was modified in January 2010
with a maturity extension and matures in January 2014.  The loan
has amortized by approximately 8% since last review.  Moody's
current credit estimate and stressed DSCR are A2 and 1.43X,
respectively, compared to Aa3 and 1.64X at last review.

The remaining seven loans with credit estimates comprise 12.1% of
the pool.  The Cedar Knolls Shopping Center Loan ($16.6 million --
2.3% of the pool) is secured by a 270,000 square retail center
located in Cedar Knolls, New Jersey.  Its underlying rating is
Baa3, the same as at last review.  The Sun Valley Apartments Loan
($17.3 million -- 2.4%), is secured by a 305-unit multifamily
property located in Florham Park, New Jersey, and has a credit
estimate of Aaa, same as at last review.  The 284 Mott Street Loan
($16.5 million -- 2.2%) is secured by a 163-unit multifamily
property located in New York City.  Its credit estimate is A3, the
same as at last review.  The Eagle Plaza Shopping Center Loan
($14.8 million -- 2.0%) is secured by a 227,000 square foot retail
center located in Voorhees, New Jersey.  Its credit estimate is
A3, the same as at last review.  The three smallest loans with
credit estimates -- Carriage Way MHP Loan ($10.0 million -- 1.4%),
Deerfield Estates MHP ($8.6 million -- 1.2%) and Wayne Towne
Center Loan ($5.0 million -- 0.7%) have credit estimates of Aaa,
the same as at last review.

The top three performing conduit loans represent 12% of the
pool balance.  The largest loan is the 360 Lexington Loan
($38.6 million -- 5.3%), which is secured by a 251,382 square
foot Class B office building located in the Grand Central office
submarket in New York City.  Property performance has improved
since the previous review because of increases in rental revenues.
The property was 89% leased as of June 2010.  The loan is interest
only for its entire 10-year term and matures in July 2013.
Moody's LTV and stressed DSCR are 75% and 1.22X, respectively,
compared to 84% and 1.16X at last review.

The second largest loan is the GGP Portfolio Loan ($31.5 million -
- 4.3%), which is secured by nine retail properties totaling
735,000 square feet.  The properties are located primarily in
tertiary markets in Utah (5), Oregon (2), Arizona and Colorado.
Portfolio performance has improved since securitization due to
increased revenues and loan amortization.  The portfolio was
included in GGP's bankruptcy and was modified in March 2010 with a
maturity extension.  The loan matures in January 2014.  The loan
has amortized by approximately 7% since last review.  Moody's LTV
and stressed DSCR are 55% and 1.86X, respectively, compared to 58%
and 1.42X at last review.

The third largest loan is the Annapolis Commerce Park Loan
($15.2 million -- 2.1% of the pool), which is secured by a 229,160
square foot industrial park located in Annapolis, Maryland.  The
park's largest tenants are the District Court of Maryland (23% of
the net rentable area (NRA); lease expiration August 2014), FTI
Consulting, Inc. (23% of the NRA; lease expiration August 2017)
and Premier Health & Fitness (10% of the NRA; lease expiration
October 2012).  Performance remains stable.  The loan amortizes on
a 30-year schedule and has amortized by approximately 4% since
last review.  Moody's LTV and stressed DSCR are 56% and 1.80X,
respectively, compared to 60% and 1.77X at last review.


BEAR STEARNS: Moody's Reviews Ratings on 14 2005-PWR7 Certs.
------------------------------------------------------------
Moody's Investors Service placed 14 classes of Bear Stearns
Commercial Mortgage Corporation, Commercial Mortgage Pass-Through
Certificates, Series 2005-PWR7 on review for possible downgrade:

  -- Cl. A-J, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to Aa2 (sf)

  -- Cl. B, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to A1 (sf)

  -- Cl. C, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to A2 (sf)

  -- Cl. D, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to Baa1 (sf)

  -- Cl. E, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to Baa2 (sf)

  -- Cl. F, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to Baa3 (sf)

  -- Cl. G, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to Ba2 (sf)

  -- Cl. H, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to B1 (sf)

  -- Cl. J, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to B2 (sf)

  -- Cl. K, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to B3 (sf)

  -- Cl. L, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to Caa2 (sf)

  -- Cl. M, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to Caa3 (sf)

  -- Cl. N, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to Caa3 (sf)

  -- Cl. P, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on May 28, 2009 Downgraded to Ca (sf)

The classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from realized and
anticipated losses from specially serviced and troubled loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated May 28, 2009.

                   Deal And Performance Summary

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 10% to $1.0 billion
from $1.1 billion at securitization.  The Certificates are
collateralized by 121 mortgage loans ranging in size from less
than 1% to 10% of the pool, with the top ten loans representing
41% of the pool.  Three loans, representing 3% of the pool, have
defeased and are collateralized with U.S. Government securities.

Twenty-eight loans, representing 24% 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 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 since
securitization, resulting in an aggregate $1.5 million loss (41%
loss severity on average).  Currently four loans, representing 9%
of the pool, are in special servicing.  The master servicer has
recognized an aggregate $28.7 million appraisal reduction for
three of the specially serviced loans.

Based on the most recent remittance statement, Classes J through
Q have experienced cumulative interest shortfalls totaling
$1.5 million.  Moody's anticipates that the pool will continue
to experience future 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 review will focus on potential losses from specially
serviced and troubled loans and the performance of the overall
pool.


BEAR STEARNS: Moody's Reviews Ratings on 15 2005-TOP20 Certs.
-------------------------------------------------------------
Moody's Investors Service placed 15 classes of Bear Stearns
Commercial Mortgage Securities Trust 2005-TOP20, Commercial
Mortgage Pass-Through Certificates, Series 2005-TOP20 on review
for possible downgrade:

  -- Cl. A-J, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 17, 2005 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. B, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 17, 2005 Definitive Rating Assigned Aa1
      (sf)

  -- Cl. C, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 17, 2005 Definitive Rating Assigned Aa2
      (sf)

  -- Cl. D, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 17, 2005 Definitive Rating Assigned Aa3
      (sf)

  -- Cl. E, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 17, 2005 Definitive Rating Assigned A2
     (sf)

  -- Cl. F, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 17, 2005 Definitive Rating Assigned A3
     (sf)

  -- Cl. G, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 23, 2009 Downgraded to Baa2 (sf)

  -- Cl. H, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 23, 2009 Downgraded to Baa3 (sf)

  -- Cl. J, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 23, 2009 Downgraded to Ba2 (sf)

  -- Cl. K, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 23, 2009 Downgraded to Ba3 (sf)

  -- Cl. L, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 23, 2009 Downgraded to B2 (sf)

  -- Cl. M, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 23, 2009 Downgraded to B3 (sf)

  -- Cl. N, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 23, 2009 Downgraded to Caa1 (sf)

  -- Cl. O, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 23, 2009 Downgraded to Caa2 (sf)

  -- Cl. P, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 23, 2009 Downgraded to Caa3 (sf)

The classes were placed on review due to higher expected losses
for the pool resulting from anticipated losses from specially
serviced and troubled loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated September 23, 2009.

                  Deal And Performance Summary

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 7.5% to
$1.92 billion from $2.07 billion at securitization.  The
Certificates are collateralized by 213 mortgage loans ranging
in size from less than 1% to 6% of the pool, with the top ten
loans representing 38% of the pool.

Forty loans, representing 15% 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 the 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
realized loss of $663,439 (60% loss severity).  Nine loans,
representing 10% of the pool, are currently in special servicing.
The specially serviced loans are secured by a mix of multifamily,
office, retail and manufactured housing property types.

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


BEAR STEARNS: Moody's Reviews Ratings on 2006-TOP22 Certs.
----------------------------------------------------------
Moody's Investors Service placed 13 classes of Bear Stearns
Commercial Mortgage Corporation, Commercial Mortgage Pass-Through
Certificates, Series 2006-TOP22 on review for possible downgrade:

  -- Cl. B, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to A2 (sf)

  -- Cl. C, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to A3 (sf)

  -- Cl. D, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to Baa2 (sf)

  -- Cl. E, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to Baa3 (sf)

  -- Cl. F, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to Ba1 (sf)

  -- Cl. G, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to Ba2 (sf)

  -- Cl. H, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to Ba3 (sf)

  -- Cl. J, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to B1 (sf)

  -- Cl. K, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to B2 (sf)

  -- Cl. L, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to B3 (sf)

  -- Cl. M, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to Caa2 (sf)

  -- Cl. N, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to Caa2 (sf)

  -- Cl. O, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 9, 2009 Downgraded to Caa3 (sf)

The classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from realized and
anticipated losses from specially serviced and troubled loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated February 9, 2009.

                   Deal And Performance Summary

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 10% to $1.5 billion
from $1.7 billion at securitization.  The Certificates are
collateralized by 220 mortgage loans ranging in size from less
than 1% to 10% of the pool, with the top ten loans representing
24% of the pool.  Two loans, representing 0.3% of the pool, have
defeased and are collateralized with U.S. Government securities.

Forty-seven 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 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 Mervyn's - Roll-
up (II) loan ($59.2 million -- 3.9% of the pool), which is the
second largest loan in the pool.  The loan is secured by 25 single
tenant retail buildings which were formerly occupied by Meryn's.
Mervyn's vacated all the buildings following its bankruptcy filing
in July 2008.  As of June 30, 2010 only nine of the properties
have been leased to new tenants.

No loans have been liquidated from the pool since securitization.
Currently three loans, representing 1% of the pool, are in special
servicing.  The master servicer has recognized an aggregate
$1.5 million appraisal reduction for one of the specially serviced
loans.

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


BEAR STEARNS: Moody's Reviews Ratings on 2007-BBA8 Certificates
---------------------------------------------------------------
Moody's Investors Service placed three non-pooled, or rake,
classes of Bear Stearns Commercial Mortgage Securities, Inc.
Commercial Pass-Through Certificates, Series 2007-BBA8 on review
for possible downgrade.

  -- Cl. CA-1, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to B1 (sf)

  -- Cl. CA-2, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to B3 (sf)

  -- Cl. CA-3, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to B3 (sf)

The three non-pooled classes have been placed on review for
possible downgrade due to the continued deterioration in
performance of the CarrAmerica Portfolio Loan.  The loan is
secured by two office buildings known as the Fairchild Research
Center with 131,561 square feet located in Mountain View,
California, and an office/R&D complex known as Sunnyvale Tech
Center with 166,250 square feet located in Sunnyvale, California.


BEAR STEARNS: S&P Downgrades Ratings on Eight 2007-BBA8 Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of commercial mortgage pass-through certificates from Bear
Stearns Commercial Mortgage Securities Trust 2007-BBA8, a U.S.
commercial mortgage-backed securities transaction.  Concurrently,
S&P affirmed 19 ratings from the same transaction.

S&P based its downgrades on its revised valuations for the
remaining 12 floating-rate assets in the transaction, which
experienced a weighted averaged decline of 9% since its last
review, and 30% since issuance.  S&P based its revaluation
analysis, in part, on a review of servicer-operating statement
analysis reports, the most recent borrower-provided rent rolls,
and site inspection reports provided by the master servicer, Bank
of America.  S&P's analysis also considered the upcoming final
maturities, 84% of which matures in 2011.  Based on S&P's analysis
of the hotel collateral, the revenue per available room overall
had declined substantially in 2008 but has been fairly stable
since 2009.  Many of the office properties are experiencing higher
vacancies and lower rents than at issuance.

S&P affirmed its 'AAA (sf)' ratings on the class X-1B, X-2, X-4,
and X-2M interest-only (IO) certificates based on its current
criteria.

Standard & Poor's lowered the ratings on five "MS" certificates
and affirmed the ratings on three "MS" rake certificates.  These
certificates derive 100% of their cash flow from a subordinate
nonpooled component of the Meristar Portfolio loan.  S&P also
affirmed all three of the "PH" raked certificates.  These
certificates derive 100% of their cash flow from a subordinate
nonpooled component of the Prime Hospitality Portfolio loan.  The
lowered and affirmed ratings follow S&P's analysis of the
respective loans.

                       Transaction Summary

According to the Oct. 15, 2010, remittance report, pool statistics
are:

There are 12 loans in the pool, including the pari passu piece of
one A/B loan, the pari passu piece of one whole loan, the senior
interest of 10 participated whole loans, and the subordinate
unpooled interests of four of these loans.

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

The loans in the pool are secured by 71.5% lodging properties,
26.3% office properties, and 2.2% multifamily properties.

                   Summary of Hotel Properties

Hotel properties secure six loans totaling $668.7 million (71.5%
of the trust balance).  S&P based its hotel analysis on a review
of the borrowers' operating statements for the six months ended
June 30, 2010, and the year ended Dec. 31, 2009, as well as their
2010 budgets.  The lodging collateral performance has been
significantly affected by the reduction in business and leisure
travel.  Details on the significant hotel properties are:

The Meristar Portfolio loan has a whole-loan balance of
$284.5 million that consists of a $47.9 million senior pooled
component and a $236.6 million subordinate nonpooled component
that is raked to the "MS" certificates.  In addition, the
borrower's equity interests in the property secure a mezzanine
loan totaling $249.3 million.  The whole-loan balance reflects
$550.5 million (66% of the whole-loan balance) in paydowns since
issuance due to collateral releases.  The remaining collateral
includes a portfolio of 11 full-service hotels with a total of
4,069 rooms in six states and the District of Columbia.  Overall
occupancy for the remaining collateral was 67.4% as of the
trailing-12-months through June 2010.  Based on Standard & Poor's
review of the borrower's operating statements for year-end 2009,
TTM ended June 30, 2010, and its 2010 budget, S&P's stressed
pooled and in-trust loan-to-value ratios are 18.1% and 107.2%,
respectively.  S&P's adjusted valuation for this loan has declined
by 36% since issuance.  The loan was transferred to the special
servicer, also Bank of America, on Feb. 2, 2010, based on the
borrower's statement, which due to current market conditions, it
did not anticipate that it would be able to pay off the loan at
maturity.  The borrower provided a proposal to modify and extend
the loan, which is currently under review by the special servicer,
GSREA LLC, as of May 2010.  The loan matures in May 2011 and has
no remaining extension options available.

The Prime Hospitality Portfolio loan has a whole-loan balance of
$141.6 million that consists of a $99.3 million senior pooled
component, a $16.4 million subordinate nonpooled component that is
raked to the "PH" certificates, and a $25.9 million junior
participation that is held outside of the trust.  In addition, the
borrower's equity interests in the property secure a mezzanine
loan totaling $36.0 million.  The whole-loan balance reflects
$33.8 million (19% of the whole-loan balance) in paydowns since
issuance due to collateral releases.  The remaining collateral
includes a portfolio of 14 full-service, limited-service, and
extended-stay hotels with a total of 1,954 rooms in three states.
Overall occupancy for the remaining collateral was 68.2% as of the
TTM ended June 2010.  Based on Standard & Poor's review of the
borrower's operating statements for the year-end 2009, TTM ended
June 30, 2010, and its 2010 budget, S&P's stressed pooled and in-
trust LTV ratios are 108.4% and 126.3%, respectively.  S&P's
adjusted valuation for this loan has declined by 37% since
issuance.  The loan matures in May 2011 and has no remaining
extension options available.

The Felcor Lodging Trust loan, the second-largest hotel loan in
the pool, has a trust balance of $96.2 million (10% of the trust
balance) and a whole-loan balance of $250.0 million.  The loan is
secured by 12 full-service hotels with a total of 2,929 rooms in
eight states.  Overall occupancy for the portfolio was 69.2% as of
the TTM ended June 2010.  The loan matures in November 2010 and
has one 12-month extension option available.  Based on Standard &
Poor's review of the borrower's operating statements for the year-
end 2009, TTM ended June 30, 2010, and its 2010 budget, S&P's
stressed in-trust and whole-loan LTV ratios are 98.2% and 132.8%,
respectively.  S&P's adjusted valuation for this loan has declined
by 27% since issuance.  The Ashford MIP Portfolio loan, the third-
largest hotel loan in the pool, has a trust balance of $92.2
million (10% of the trust balance) and a whole-loan balance of
$203.4 million.  The whole-loan balance reflects $15.6 million (7%
of the whole-loan balance) in paydowns since issuance due to the
release of one property.  The remaining collateral includes a
portfolio of five full-service hotels with a total of 1,447 rooms
in four states.  Overall occupancy for the portfolio was 71.8% as
of the TTM through June 2010.  The loan matures in December 2010
and has one 12-month extension option available.  Based on
Standard & Poor's review of the borrower's operating statements
for the year-end 2009, TTM ended June 30, 2010, and its 2010
budget, S&P's stressed in-trust and whole-loan LTV ratios are
98.0% and 216.2%, respectively.  S&P's adjusted valuation for this
loan has declined by 28% since issuance.  The Larkspur Hotel
Portfolio loan, the fourth-largest hotel loan in the pool, has a
trust and whole-loan balance of $51.5 million (5.5% of the trust
balance).  The loan is secured by five full-service hotels with a
total of 623 rooms in California and Oregon.  Overall occupancy
for the portfolio was 72.5% as of the TTM through June 2010.  The
loan matures in
February 2011 and has one 12-month extension option available.
Based on Standard & Poor's review of the borrower's operating
statements for the year-end 2009, TTM ended March 31, 2010, and
its 2010 budget, S&P's stressed in-trust LTV ratio is 123.1%.
S&P's adjusted valuation for this loan has declined by 46% since
issuance.

                   Summary of Office Properties

Office properties secure five loans (26.3% of the pool trust
balance).  S&P based its analysis on a review of the borrowers'
most recent rent rolls and operating statements.  Details of the
significant office properties are:

The Westcore Colorado Portfolio loan is the largest loan secured
by office properties and the fourth-largest loan in the pool.  The
loan has a trust balance of $80.2 million (9% of the trust
balance) and a whole-loan balance of $152.5 million.  The whole-
loan balance reflects $31.3 million (17% of the whole-loan
balance) in paydowns since issuance due to collateral releases.
The remaining collateral includes a portfolio of 14 class A/B
suburban/flex office properties and one industrial property
totaling 1.2 million sq. ft. in Colorado.  The master servicer
reported a debt service coverage of 10.07x for the year-end 2009,
and 84% occupancy as of June 2010.  The loan matures in November
2010 and has one 12-month extension option available.  Standard &
Poor's stressed in-trust and whole-loan LTV ratios are 74.8% and
142.2%, respectively.  S&P's valuation for this loan declined 27%
since issuance due to a decline in occupancy and rents.

The 980 Madison Avenue loan is the second-largest loan secured by
an office property and the fifth-largest loan in the pool.  The
$80.0 million whole loan is split into a senior pooled trust
balance of $62.5 million (8% of the trust balance) and a
$17.5 million nonpooled subordinate component that supports the
"MA" raked certificates, which Standard & Poor's does not rate.
The loan is secured by a six-story, 122,700-sq.-ft. class A office
building in Manhattan.  The master servicer reported a DSC of
5.12x for year-end 2009 and 100% occupancy as of June 2010.  The
loan was recently extended through October 2011 and has no
extension options remaining.  Standard & Poor's stressed in-trust
and whole-loan LTV ratios are 101.5% and 129.9%, respectively.
S&P's valuation for this loan has declined 46% since issuance,
primarily due to a decline in rents.

The Thanksgiving Tower loan is the third-largest loan secured by
an office property and the sixth-largest loan in the pool.  The
loan has a trust balance of $58.5 million (6% of the trust
balance) and a whole-loan balance of $84.0 million.  In addition,
the borrower's equity interests in the property secure a mezzanine
loan totaling $22.9 million.  The loan is secured by a
1.4 million-sq.-ft. office building in Dallas, Texas.  The loan
was transferred to the special servicer, Bank of America, on
Feb. 24, 2010, in anticipation of the upcoming March 2010
maturity.  The loan was recently extended through April 2012 and
has two 12-month extension options remaining.  The master servicer
reported a DSC of 8.38x for year-end 2009 and 53% occupancy as of
June 2010.  Standard & Poor's stressed in-trust and whole-loan LTV
ratios are 69.8% and 100.2%, respectively.  S&P's valuation for
this loan has declined 26% since issuance.

Specially serviced loans (not discussed above) in the pool are:

The Inverness Hotel & Conference Center loan, the ninth-largest
loan in the pool, has a trust balance of $28.7 million and whole-
loan balance of $37.1 million (3% of the trust balance).  The loan
is secured by a six-story, 302-room hotel and conference center in
Englewood, Colo.  The loan was transferred to the special
servicer, Bank of America, on Feb. 24, 2010, due to the loan's
inability to satisfy the debt yield hurdle required as a condition
of the loan extension.  The loan was recently modified and
extended to March 2012 with these conditions: a $2.5 million
principal paydown and monthly amortization payments of $150,000.
The modified loan does not provide for any extension options.  The
loan will be returned to the master servicer prior to the November
2010 payment.  Bank of America reported a 9.68x DSC for year-end
2009.  Standard & Poor's stressed in-trust and whole-loan LTV
ratios are 88.8% and 114.6%, respectively.  S&P's adjusted
valuation for this loan has fallen 27% since issuance.

Near-term maturities (within the next three months and not
discussed above) for the loans in the pool are:

The One Riverwalk Place loan, the 11th-largest loan in the pool,
has a trust balance of $14.0 million and whole-loan balance of
$27.4 million (1.5% of the trust balance).  The loan is secured by
a 261,600-sq.-ft. high-rise office building in the San Antonio
central business district.  The loan was transferred to the
special servicer, Bank of America, on March 30, 2010, in
anticipation of the upcoming April 2010 maturity.  The borrower
provided notice of its intent to exercise its current extension
option and subsequently requested a loan modification.  The loan
was granted a forbearance through October 2010.  The special
servicer is in negotiations with the borrower.  Bank of America
reported a 6.11x DSC for year-end 2009.  Standard & Poor's
stressed in-trust and whole-loan LTV ratios are 95.7% and 187.5%,
respectively.  S&P's adjusted valuation for this loan has dropped
3% since issuance.

               Ratings Lowered (Pooled Certificates)

   Bear Stearns Commercial Mortgage Securities Trust 2007-BBA8
         Commercial mortgage pass-through certificates

                 Rating
                 ------
      Class   To          From       Credit enhancement (%)
      -----   --          ----       ----------------------
      G       B (sf)      B+ (sf)                     12.87
      H       B- (sf)     B (sf)                      10.07
      J       CCC (sf)    CCC+  (sf)                   7.11

             Ratings Lowered (Nonpooled Certificates)

   Bear Stearns Commercial Mortgage Securities Trust 2007-BBA8
          Commercial mortgage pass-through certificates

                Rating
                ------
      Class   To       From          Credit enhancement (%)
      -----   --       ----          ----------------------
      MS-3    A- (sf)     A+ (sf)                       N/A
      MS-4    BB+ (sf)    BBB+  (sf)                    N/A
      MS-5    B+ (sf)     BBB-  (sf)                    N/A
      MS-6    CCC- (sf)   BB (sf)                       N/A
      MS-7    CCC- (sf)   BB- (sf)                      N/A

              Ratings Affirmed (Pooled Certificates)

   Bear Stearns Commercial Mortgage Securities Trust 2007-BBA8
          Commercial mortgage pass-through certificates

             Class   Rating     Credit enhancement (%)
             -----   ------     ----------------------
             A-1     AAA (sf)                    89.95
             A-2     AA+ (sf)                    45.32
             B       AA- (sf)                    39.17
             C       BBB+ (sf)                   33.01
             D       BB+ (sf)                    26.86
             E       BB (sf)                     20.42
             F       BB- (sf)                    16.50
             K       CCC- (sf)                    3.35
             L       CCC- (sf)                    0.00
             X-1B    AAA (sf)                      N/A
             X-2     AAA (sf)                      N/A
             X-4     AAA (sf)                      N/A
             X-2M    AAA (sf)                      N/A

            Ratings Affirmed (Nonpooled Certificates)

   Bear Stearns Commercial Mortgage Securities Trust 2007-BBA8
          Commercial mortgage pass-through certificates

            Class   Rating     Credit enhancement (%)
            -----   ------     ----------------------
            MS-1    AA+ (sf)                      N/A
            MS-2    AA (sf)                       N/A
            MS-X    AA+ (sf)                      N/A
            PH-1    CCC- (sf)                     N/A
            PH-2    CCC- (sf)                     N/A
            PH-3    CCC- (sf)                     N/A

                      N/A - Not Applicable.


C-BASS MORTGAGE: Moody's Downgrades Ratings on Four Tranches
------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of four
tranches and confirmed the ratings of one tranche from two RMBS
transactions issued by C-Bass Mortgage Loan Asset Backed Notes.
Additionally, Moody's has downgraded the underlying ratings of two
tranches from a third RMBS transactions issued by C-Bass Mortgage
Loan Asset-Backed Certificates.  The collateral backing these
deals primarily consists of closed end second lien loans.

                        Ratings Rationale

The actions are a result of the continued performance
deterioration in second lien pools in conjunction with home price
and unemployment conditions that remain under duress.  The actions
reflect Moody's updated loss expectations on second lien pools.

For securities insured by a financial guarantor, the rating on the
securities is the higher of (i) the guarantor's financial strength
rating and (ii) the current underlying rating (i.e., absent
consideration of the guaranty) on the security.  The principal
methodology used in determining the underlying rating is the same
methodology for rating securities that do not have a financial
guaranty and is as described earlier.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment remains at high
levels, and weakness persists in the housing market.  Moody's
notes an increasing potential for a double-dip recession, which
could cause a further 20% decline in home prices (versus its
baseline assumption of roughly 5% further decline).  Overall,
Moody's assumes a further 5% decline in home prices with
stabilization in early 2011, accompanied by continued stress in
national employment levels through that timeframe.

If expected losses on the each of the collateral pools were to
increase by 10%, model implied results indicate that most of the
deals' ratings would remain stable, with the exception of Class
II-B-1 from C-Bass Mortgage Loan Asset Backed Notes, Series 2001-
CB4 for which model implied results would be one notch lower (for
example, Ba2 versus Ba1, or Ca versus Caa3).  Class II-M-2 from C-
Bass Mortgage Loan Asset Backed Notes, Series 2001-CB4, model
implied results would be three notches lower.

Moody's Investors Service received and took into account one or
more third party due diligence reports on the underlying assets or
financial instruments in this transaction and the due diligence
reports had a neutral impact on the rating.

Complete rating actions are:

Issuer: C-Bass Mortgage Loan Asset Backed Notes, Series 2001-CB4

  * Expected Losses (as a % of Original Balance): 20%

  -- Cl. IIM-2, Downgraded to Baa1 (sf); previously on March 18,
     2010 A2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IIB-1, Confirmed at Ba3 (sf); previously on March 18,
     2010 Ba3 (sf) Placed Under Review for Possible Downgrade

Issuer: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2006-SL1

  * Expected Losses (as a % of Original Balance): 68%

  -- Cl. A-1, Downgraded to C (sf); previously on March 18, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-2, Downgraded to C (sf); previously on March 18, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-3, Downgraded to C (sf); previously on March 18, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

Issuer: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2007-SL1

  * Expected Losses (as a % of Original Balance): 78%

  -- Cl. A-1, Current Rating at Ca (sf); previously on March 9,
     2009 Downgraded to Ca (sf)

  -- Underlying Rating: Downgraded to C (sf); previously on
     March 18, 2010 Ca (sf) Placed Under Review for Possible
     Downgrade

  -- Financial Guarantor: Syncora Guarantee Inc. (Downgraded to
     Ca, Outlook Developing on March 9, 2009)

  -- Cl. A-2, Current Rating at Ca (sf); previously on March 9,
     2009 Downgraded to Ca (sf)

  -- Underlying Rating: Downgraded to C (sf); previously on
     March 18, 2010 Ca (sf) Placed Under Review for Possible
     Downgrade

  -- Financial Guarantor: Syncora Guarantee Inc. (Downgraded to
     Ca, Outlook Developing on March 9, 2009)


CAPITALSOURCE COMMERCIAL: S&P Raises Ratings on Various Classes
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A and B notes from CapitalSource Commercial Loan Trust 2007-1, a
collateralized loan obligation transaction that closed in April
2007.  S&P also removed the rating on class A from CreditWatch
positive.

Since February 2010, the class A notes have been paid down by more
than $134 million.  The class A notes have benefited from the deal
triggering a sequential pay event, ending the pro rata paydown of
the notes and directing the transaction to be paid down
sequentially.

The largest obligor default test drove S&P's rating actions; the
ratings on classes A and B failed to withstand the specified
combination of underlying asset defaults above the 'A (sf)' rating
level.

Standard & Poor's will continue to review whether, in its view,
the ratings currently assigned to the notes remain consistent with
the credit enhancement available to support them and take rating
actions as S&P deem necessary.

                          Rating Actions

            CapitalSource Commercial Loan Trust 2007-1

                               Rating
                               ------
        Class               To         From
        -----               --         ----
        A                   A+ (sf)    BBB+ (sf)/Watch Pos
        B                   A+ (sf)    BB+ (sf)


CD 2007-CD5: Moody's Reviews Ratings on 13 Classes of Certs.
------------------------------------------------------------
Moody's Investors Service placed 13 classes of CD 2007-CD5
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
Series 2007-CD5 on review for possible downgrade:

  -- CL. AM, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on April 3, 2008 Definitive Rating Assigned Aaa
     (sf)

  -- CL. A-MA, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on April 3, 2008 Definitive Rating
     Assigned Aaa (sf)

  -- CL. AJ, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Aa3 (sf)

  -- CL. A-JA, Aa3 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 6, 2009 Downgraded to Aa3 (sf)

  -- CL. B, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to A1 (sf)

  -- CL. C, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to A2 (sf)

  -- CL. D, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to A3 (sf)

  -- CL. E, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Baa2 (sf)

  -- CL. F, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Baa3 (sf)

  -- CL. G, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Ba1 (sf)

  -- CL. H, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Ba2 (sf)

  -- CL. K, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to B3 (sf)

  -- CL. J, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to B2 (sf)

The classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from anticipated
losses from specially serviced and troubled loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated February 6, 2009.

                   Deal And Performance Summary

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 1% to $2.07 billion
from $2.09 billion at securitization.  The Certificates are
collateralized by 160 mortgage loans ranging in size from less
than 1% to 8% of the pool, with the top ten loans representing 40%
of the pool.

Thirty-six 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 monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

One loan has been liquidated from the pool since securitization,
resulting in a $1.7 million loss (5% loss severity).  Currently 24
loans, representing 12% of the pool, are in special servicing.
The largest specially serviced loan is the Georgian Towers Loan
($58.0 million -- 2.8% of the pool), which is secured by a 890
unit multifamily property located in Silver Spring, Maryland.  The
loan was transferred to special servicing in December 2009 due to
non-monetary default and is currently 90+ days delinquent.  The
master servicer has recognized an aggregate $73.4 million
appraisal reduction for 19 of the specially serviced loans.

Based on the most recent remittance statement, Classes L through
NR have experienced interest shortfalls totaling $3.5 million.
Moody's anticipates that the pool will continue to experience
future 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 review will focus on potential losses from specially
serviced and troubled loans and the performance of the overall
pool.


CHASE COMMERCIAL: S&P Downgrades Ratings on Four Certificates
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
classes of commercial mortgage pass-through certificates from
Chase Commercial Mortgage Securities Corp.'s series 2000-3.  S&P
lowered its ratings on classes K and L to 'D (sf)'.  At the same
time, S&P affirmed its ratings on four classes and withdrew its
ratings on the class C, D, and X certificates.

The downgrades reflect S&P's analysis of the interest shortfalls
that have affected the trust, as well as the potential for future
interest shortfalls associated with several assets that are with
the special servicer.  S&P lowered its rating on the class K and L
certificates to 'D (sf)' because of recurring interest shortfalls
that S&P expects will continue for the foreseeable future.

As of the Oct. 18, 2010 remittance report, the trust experienced
monthly interest shortfalls totaling $84,380.  The interest
shortfalls were primarily due to appraisal subordinate entitlement
reduction amounts ($77,186) stemming from three ARAs on specially
serviced assets.  The monthly interest shortfalls caused classes
J, K, and L to experience interest shortfalls for seven months
each.  Several of the downgrades also reflect credit support
erosion S&P anticipate will occur following the resolution of six
of the eight specially serviced assets.

S&P withdrew its ratings on class C and D following the repayment
in full of their respective class principal balances, as noted in
the Oct. 18, 2010, remittance report.  S&P withdrew its ratings on
the class X interest-only certificates following the repayment of
all principal and interest paying classes rated 'AA- (sf)' and
higher from this transaction.

The collateral consists of nine loans and two real estate owned
(REO) assets with an aggregate trust balance of $84.9 million.
There are no defeased loans in the trust, and seven of the nine
loans in the pool ($59.1 million, 69.6%) have matured.  The
remaining two loans ($25.8 million, 30.4%) mature in 2012 and
2019, respectively.  To date, the trust has experienced losses of
$8.5 million in connection with nine loans.

Eight of the 11 remaining assets ($63.8 million, 75.1%) were
with the special servicer, LNR Partners Inc. The payment status
of these assets is: two ($25.8 million, 30.4%) are REO, five
($33.6 million, 39.6%) are matured balloons, and one
($4.4 million, 5.1%) is in foreclosure.  Four of the specially
serviced assets have ARAs in effect totaling $15.8 million.

Details regarding the three specially serviced assets that are the
primary drivers of the interest shortfalls are:

Two Bent Tree Tower is the largest asset in the pool, and has a
total exposure of $17.3 million, which consists of $16.7 million
of unpaid principal balance (19.7%) and $0.6 million of advancing
and interest thereon.  The loan was transferred to LNR on
Jan.  13, 2010, due to payment default and became REO on Aug. 3,
2010.  The subject property is a 172,513-sq.-ft. office building
in Addison, Texas.  As of Dec. 31, 2009, the reported debt service
coverage was 0.62x with 86.0% reported occupancy.  An ARA of
$7.2 million is in effect for this asset based on a February 2010
appraisal, which resulted in an ASER in the amount of $41,107.
S&P expects a significant loss to the trust upon the eventual
resolution of this asset.

The Roswell Business Center is the fifth-largest asset in the
pool, and has a total exposure of $10.4 million, which consists of
$9.2 million of unpaid principal balance (10.8%) and $1.2 million
of advancing and interest thereon.  The asset was transferred to
LNR on Aug. 7, 2008, due to the bankruptcy of the borrower's
sponsor.  It became REO on Feb. 2, 2010.  The subject property is
a 157,299-sq.-ft. office complex in Roswell, Ga.  The special
servicer is currently marketing the property for sale.  An ARA of
$4.1 million is in effect for this asset, which resulted in an
ASER in the amount of $23,650.  S&P anticipate a significant loss
to the trust upon the eventual resolution of this asset.

The Regal Court I & II loan, the seventh-largest asset in the
pool, has a total exposure of $4.9 million, which consists of
$4.4 million of unpaid principal balance (5.1%) and $0.5 million
of advancing and interest thereon.  The loan was transferred to
LNR on May 15, 2009, due to imminent default, and the special
servicer is making preparations for foreclosure.
The loan is secured by a 42,219-sq.-ft. office complex in Warren,
Mich.  Reported occupancy as of Feb. 1, 2010, was 41.7% and
reported DSC was 0.46x for the three months ended March 2009.  An
ARA of $2.2 million is in effect for this asset, which resulted in
an ASER in the amount of $12,429.  S&P anticipate a significant
loss to the trust upon the eventual resolution of this asset.

The remaining five specially serviced assets ($33.6 million,
39.6%) are all matured balloon loans.  The DSC for these loans was
0.77x.  S&P estimated losses ranging from 1.0%, to account for any
applicable workout fees, to 58.6%.

The lowered, affirmed, and withdrawn ratings are consistent with
Standard & Poor's current criteria and analysis of the
transaction.

                         Ratings Lowered

            Chase Commercial Mortgage Securities Corp.
   Commercial mortgage pass-through certificates series 2000-3

                 Rating
                 ------
    Class   To             From         Credit enhancement (%)
    -----   --             ----         ----------------------
    I       B (sf)         BB- (sf)                      28.85
    J       CCC- (sf)      B (sf)                        17.54
    K       D (sf)         B-(sf)                        13.02
    L       D (sf)         CCC+ (sf)                      8.50

                        Ratings Affirmed

            Chase Commercial Mortgage Securities Corp.
   Commercial mortgage pass-through certificates series 2000-3

            Class  Rating       Credit enhancement (%)
            -----  ------       ----------------------
            E      A- (sf)                       86.48
            F      BBB+ (sf)                     77.44
            G      BB+ (sf)                      42.41
            H      BB (sf)                       35.63

                        Ratings Withdrawn

            Chase Commercial Mortgage Securities Corp.
   Commercial mortgage pass-through certificates series 2000-3

                                       Rating
                                       ------
      Class                    To                  From
      -----                    --                  ----
      C                        NR                  AA+ (sf)
      D                        NR                  AA (sf)
      X                        NR                  AAA (sf)


CITIGROUP COMMERCIAL: Moody's Cuts Ratings on Five 2004-C1 Certs.
-----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five classes
and affirmed eleven classes of Citigroup Commercial Mortgage Trust
2004-C1, Commercial Mortgage Pass-Through Certificates, Series
2004-C1.

  -- Cl. A-3, Affirmed at Aaa (sf); previously on June 30, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed at Aaa (sf); previously on June 30, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-1, Affirmed at Aaa (sf); previously on June 30, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. B, Affirmed at Aaa (sf); previously on Feb. 1, 2007
     Upgraded to Aaa (sf)

  -- Cl. C, Affirmed at Aa1 (sf); previously on Feb. 1, 2007
     Upgraded to Aa1 (sf)

  -- Cl. D, Affirmed at A1 (sf); previously on Feb. 1, 2007
     Upgraded to A1 (sf)

  -- Cl. E, Affirmed at A3 (sf); previously on June 30, 2004
     Definitive Rating Assigned A3 (sf)

  -- Cl. F, Affirmed at Baa1 (sf); previously on June 30, 2004
     Definitive Rating Assigned Baa1 (sf)

  -- Cl. G, Affirmed at Baa3 (sf); previously on June 4, 2009
     Downgraded to Baa3 (sf)

  -- Cl. H, Affirmed at Ba2 (sf); previously on June 4, 2009
     Downgraded to Ba2 (sf)

  -- Cl. J, Affirmed at B1 (sf); previously on June 4, 2009
     Downgraded to B1 (sf)

  -- Cl. K, Downgraded to B3 (sf); previously on June 4, 2009
     Downgraded to B2 (sf)

  -- Cl. L, Downgraded to Caa3 (sf); previously on June 4, 2009
     Downgraded to Caa1 (sf)

  -- Cl. M, Downgraded to Caa3 (sf); previously on June 4, 2009
     Downgraded to Caa1 (sf)

  -- Cl. N, Downgraded to Ca (sf); previously on June 4, 2009
     Downgraded to Caa3 (sf)

  -- Cl. P, Downgraded to C (sf); previously on June 4, 2009
     Downgraded to Caa3 (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from anticipated losses from specially serviced and
troubled loans.

The affirmations are due to key parameters, including Moody's loan
to value ratio, Moody's stressed DSCR and the Herfindahl Index,
remaining within acceptable ranges.  Based on Moody's current base
expected loss, the credit enhancement levels for the affirmed
classes are sufficient to maintain their current ratings.

Moody's rating action reflects a cumulative base expected loss of
4.2% of the current balance.  At last review, Moody's cumulative
base expected loss was 3.9%.  Moody's stressed scenario loss is
10.5% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl score
, a measure of loan level diversity, is a primary determinant of
pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the credit estimate of the
loan which corresponds to a range of credit enhancement levels.
Actual fusion credit enhancement levels are selected based on loan
level diversity, pool leverage and other concentrations and
correlations within the pool.  Negative pooling, or adding credit
enhancement at the credit estimate level, is incorporated for
loans with similar credit estimates in the same transaction.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated June 4, 2009.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

                         Deal Performance

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 22% to
$919.2 million from $1.19 billion at securitization.  The
Certificates are collateralized by 84 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.  Twelve loans,
representing 18% of the pool, have defeased and are collateralized
with U.S. Government securities.

Twenty-one loans, representing 18% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council 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 realized loss of $66,641 (2% loss severity overall).
Six loans, representing 4% of the pool, are currently in special
servicing.  The master servicer has recognized an aggregate
$5.8 million appraisal reduction for three of the specially
serviced loans.  Moody's has estimated an aggregate $12.3 million
loss (38% expected loss on average) for the specially serviced
loans.

Moody's has assumed a high default probability for seven poorly
performing loans representing 7% of the pool and has estimated a
$12.1 million loss (20% expected loss based on a 50% probability
default) from these troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 93% and 64% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 93% compared to 103% at Moody's prior review.
Moody's net cash flow reflects a weighted average haircut of 12%
to the most recently available net operating income.  Moody's
value reflects a weighted average capitalization rate of 9.5%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.40X and 1.16X, respectively, compared to
1.34X and 1.09X 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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 27 compared to 29 at Moody's prior review.

The top three performing conduit loans represent 21% of the pool
balance.  The largest loan is the Yorktown Center Loan
($84.6 million -- 9.0%), which is secured by the borrower's
interest in a 1.5 million square foot super-regional mall located
approximately 22 miles west of Chicago in Lombard, Illinois.  The
collateral for this loan includes 620,000 square feet of in-line
space, several outparcel buildings and an 84,000 square foot strip
shopping center known as the Shops at Yorktown.  The property was
86% leased as of May 2010 compared to 82% at last review.
Although occupancy has been stable, performance has declined due
to lower revenues.  Net Operating Income has decreased 16% since
last review.  Moody's LTV and stressed DSCR are 93% and 1.05X,
respectively, compared to 78% and 1.24X at last review.

The second largest loan is the Pecanland Mall Loan ($55.1 million
-- 6.0%), which is secured by a 947,000 square foot enclosed
regional mall located in Monroe, Louisiana.  Non-collateral
anchors include Dillard's, J.C. Penney, Sears and Belk.  The
collateral for the loan includes 349,000 square feet of in-line
space and the junior anchor space.  The in-line space was 79%
leased as of June 2010 compared to 86% at last review.
Performance has been stable.  The loan sponsor is an affiliate of
General Growth Properties.  The loan was included in GGP's
bankruptcy filing and the loan's maturity has been extended to
2014.  Moody's LTV and stressed DSCR are 84% and 1.16X,
respectively, compared to 86% and 1.13X at last review.

The third largest loan is the Lake Shore Place Loan ($53.1 million
-- 5.8%), which is secured by the leased fee interest in a 489,066
square feet office building located in Chicago, Illinois.  The
largest tenants include Playboy Enterprises (19% of the net
rentable area; lease expiration 2022) and NW Medical Faculty
Foundation (12% of the NRA; lease expiration 2014).  The property
was 95% leased as of June 2010 compared to 89% at last review.
Performance has improved due to higher revenues.  NOI has
increased 27% since last review.  Moody's LTV and stressed DSCR
are 86% and 1.19X, respectively, compared to 109% and 0.94X at
last review.


CLYDESDALE CLO: S&P Raises Ratings on Three Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B, and C notes issued by Clydesdale CLO 2003 Ltd., a
collateralized loan obligation transaction managed by Nomura
Corporate Research and Asset Management.  At the same time, S&P
removed its rating on the class A notes from CreditWatch positive
and affirmed its rating on the class D notes.

The upgrades reflect improved performance S&P has observed in the
deal's underlying asset portfolio and significant paydown of the
class A notes since S&P's last rating action in December 2009.

According to the Sept. 3, 2010 trustee report, the transaction
currently holds $15.9 million in 'CCC' rated assets, down from
$28.5 million noted in the Oct. 9, 2009 trustee report.  In
addition, the transaction holds $13 million in defaulted
securities, down from $31.7 million in October 2009.  The deal has
paid down $77.5 million to the class A notes.  The transaction is
in its amortization period, and the class A notes have been
reduced to 50.77% of their original balance.  Accordingly, each of
the transaction's overcollateralization ratios have improved.  The
class A O/C ratio is 133.51% versus 118.97% in October 2009; the
class B O/C ratio is 116.66% versus 108.47%; the class C O/C ratio
is 107.38% versus 102.30%; and the class D O/C ratio is 101.19%
versus 97.70%.  The class D O/C ratio requires 103.20% to pass and
is currently failing.

S&P affirmed its 'CCC- (sf)' rating on the class D notes because
they failed to withstand the specified combination of underlying
asset defaults at the 'CCC' rating level in the largest obligor
default test.

Standard & Poor's will continue to review whether, in its view,
the ratings currently assigned to the notes remain consistent with
the credit enhancement available to support them and take rating
actions as S&P deem necessary.

                  Rating And Creditwatch Actions

                     Clydesdale CLO 2003 Ltd.

                            Rating
                            ------
            Class       To          From
            -----       --          ----
            A           AAA (sf)    AA- (sf)/Watch Pos
            B           A+ (sf)     BBB (sf)
            C           BB+ (sf)    CCC+ (sf)

                         Ratings Affirmed

                     Clydesdale CLO 2003 Ltd.

                      Class       Rating
                      -----       ------
                      D           CCC- (sf)


COMM 2004: S&P Downgrades Ratings on 11 Classes of Notes
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 11
classes of commercial mortgage-backed securities from COMM 2004
LNB2.  In addition, S&P affirmed its ratings on six classes from
the same transaction.

The downgrades reflect S&P's analysis of the remaining collateral
in the pool, the deal structure, and the interest shortfalls that
have affected the trust.  The downgrades also reflect the
increased susceptibility of several classes to future interest
shortfalls and a reduction of available interest to the trust.  As
of the Oct. 12, 2010, remittance report, the trust experienced
interest shortfalls of $133,996.  The shortfalls were primarily
due to interest not advanced ($116,628) on two loans due to
nonrecoverable advance declarations by the master servicer,
Berkadia Commercial Mortgage, appraisal subordinate entitlement
reduction amounts ($7,632) on two other loans, and special
servicing fees ($8,020).  S&P lowered its ratings on classes L, M,
N, and O to 'D (sf)' due to interest shortfalls for nine months
that S&P expects will continue.

The affirmations of the ratings on the principal and interest
certificates reflect subordination levels and liquidity that is
consistent with the outstanding ratings.  S&P affirmed its ratings
on the class X1 and X2 interest-only (IO) certificates based on
S&P's current criteria.

S&P's analysis of this transaction also included a review of the
credit characteristics of all of the loans in the pool using its
U.S. conduit/fusion CMBS criteria.  Using servicer-provided
financial information, S&P calculated an adjusted debt service
coverage of 2.17x and a loan-to-value ratio of 73.2%.  S&P further
stressed the loans' cash flows under its 'AAA' scenario to yield a
weighted average DSC of 1.38x and an LTV ratio of 86.61%.  The
implied defaults and loss severity under the 'AAA' scenario were
28.6% and 25.0%, respectively.  The DSC and LTV calculations S&P
noted above exclude three ($28.7 million; 4.1%) of the five
specially serviced assets and seven defeased loans ($132 million;
18.9%).  S&P separately estimated losses for these loans, which
are included in the 'AAA' scenario implied default and loss
figures.

                      Credit Considerations

As of the Oct. 12, 2010, remittance report, four loans
($38.5 million; 5.5%) in the pool were with the special servicer,
LNR Partners Inc. Three loans ($36.4 million, 5.2%) are in
foreclosure, and one loan ($2.0 million, 0.3%) is 30-days
delinquent.  In addition, the Woodway Pines Apartments loan
($4.7 million, 0.67%), which is 60 days delinquent, was
transferred to the special servicer on Oct. 5, 2010, subsequent to
the cut-off date for the October remittance report.  Four
appraisal reductions amounts totaling $14.3 million are in effect
on four of the specially serviced loans.

The 1 Northbrook Corporate Center loan ($13.9 million; 2.0%) is
the seventh-largest exposure in the pool secured by real estate.
In addition to the outstanding principal balance, advancing and
interest thereon totals $1.2 million.  The loan is secured by a
94,543-sq.-ft. office building in Trevose, Pa., built in 1989.  It
was transferred to the special servicer on June 2, 2009, due to
monetary default and is currently in foreclosure.  As of year-end
2008, the reported DSC and occupancy for this property were 0.78x
and 78.0%, respectively.  Berkadia declared future advances on the
loan nonrecoverable on Sept. 27, 2010.  Berkadia noted that the
determination was made primarily because the most recent appraisal
of the underlying property is more than 12 months old.  If LNR
Partners Inc. provides a new valuation for the property, Berkadia
noted that it will review the nonrecoverable determination.  An
ARA of $7.7 million is in effect.  Standard & Poor's expects a
moderate loss upon the resolution of this asset.

The Hawthorne Apartments loan ($12.3 million, 1.8%) is the eighth-
largest exposure in the pool secured by real estate.  The loan is
secured by a 312-unit apartment complex in Houston, Texas, built
in 1982.  It was transferred to the special servicer on Dec.  4,
2008, due to maturity default and is currently in foreclosure.
According to the special servicer, the borrower has indicated that
it would agree to a cooperative sale of the property or deed-in-
lieu of foreclosure.  An ARA of $698,707 is in effect on the loan.

The Northbrook loan ($10.2 million, 1.45%) is secured by a 66,285-
sq.-ft. office building in Bensalem, Pa., built in 2001.  In
addition to the outstanding principal balance, advancing and
interest thereon totals $0.9 million.  The asset was transferred
to the special servicer on June 2, 2009, due to monetary default
and is currently in foreclosure.  According to LNR Partners, it is
in the process of appointing a receiver for the property.  Similar
to the 1 Northbrook Corporate Center loan discussed above,
Berkadia declared future advances on the loan nonrecoverable on
Sept. 27, 2010.  Berkadia noted that the determination was made
primarily because the most recent appraisal of the underlying
property is more than 12 months old.  If the special servicer
provides a new valuation for the property, Berkadia noted it will
review the nonrecoverable determination.  While the 1 Northbrook
Corporate Center and Northbrook loans share a sponsor, the loans
are not cross-collateralized or defaulted.  An ARA of $5.4 million
is in effect.  Standard & Poor's expects a loss upon the
resolution of this asset.

The remaining two loans ($6.7 million) with the special servicer
individually represent less than 0.7% of the outstanding pool
balance.  Standard & Poor's expects a moderate loss upon the
ultimate resolution of the Woodway Pines Apartments loan
($4.7 million, 0.67%).  The borrower for the Dundee Meadows MHC
loan ($2 million, 0.29%) is remitting payments due under a
forbearance agreement.

                       Transaction Summary

As of the October 2010 remittance report, the transaction had an
aggregate trust balance of $699.8 million (71 loans), compared
with $963.8 million (90 loans) at issuance.  Seven loans
($132 million, 18.9%) are defeased.  The master servicer provided
full-year 2009 or 2008 financial information for 95% of the
nondefeased loans in the pool.  S&P calculated a weighted average
DSC of 2.34x for the nondefeased loans in the pool based on the
reported figures.  S&P's adjusted DSC and LTV were 2.17x and
73.2%, respectively, and excluded three ($28.7 million; 4.1%) of
the five specially serviced assets, and seven defeased loans
($132 million; 18.9%).  S&P separately estimated losses for the
three specially serviced assets.  Seventeen loans ($82.8 million,
11.8%) are on the master servicer's watchlist, which includes
the fifth-largest loan as discussed below.  Three loans
($12.3 million, 1.8%) have a reported DSC between 1.0x and 1.1x,
and eight loans ($31.9 million, 4.6%) have a reported DSC of
less than 1.0x.  The trust has experienced four principal losses
to date totaling $1.3 million.

                 Summary of Top 10 Loan Exposures

The top 10 loans secured by real estate have an aggregate
outstanding balance of $377.8 million (54.0%).  Using servicer-
reported information, S&P calculated a weighted average DSC of
2.82x for the top 10 loans.  The seventh- and eighth-largest
loans, which are with the special servicer as discussed above,
were excluded from the weighted average DSC as no servicer-
reported information was available for the loans.  S&P's adjusted
DSC and LTV figures for the top 10 loans were 2.47x and 68.6%,
respectively.

The Wenatchee Valley Mall loan ($23.8 million; 3.4%) is the fifth-
largest loan in the pool.  The loan is secured by a 340,406?sq.-
ft. mall in East Wenatchee, Wash., constructed in 1954 and
renovated in 2003.  The loan appears on the master servicer's
watchlist due to upcoming maturity on Nov. 1, 2010.  As of year-
end 2009, the reported occupancy and DSC were 91% and 1.21x,
respectively.  The master servicer noted that the borrower sent a
financing commitment letter and expects to pay off the loan at
maturity.

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

                         Ratings Lowered

                         COMM 2004-LNB2
          Commercial mortgage pass-through certificates

             Ratings
             -------
Class     To              From             Credit enhancement (%)
-----     --              ----             ----------------------
D         BBB (sf)        A (sf)                            10.66
E         BBB- (sf)       A- (sf)                            9.46
F         BB (sf)         BBB+ (sf)                          8.08
G         B (sf)          BBB (sf)                           6.53
H         CCC+ (sf)       BBB- (sf)                          4.98
J         CCC (sf)        BB+ (sf)                           4.29
K         CCC- (sf)       BB (sf)                            3.43
L         D (sf)          BB- (sf)                           2.92
M         D (sf)          B+ (sf)                            2.23
N         D (sf)          B (sf)                             1.88
O         D (sf)          B- (sf)                            1.71

                        Ratings Affirmed

                          COMM 2004-LNB2
          Commercial mortgage pass-through certificates

           Class    Rating       Credit enhancement (%)
           -----    ------       ----------------------
           A-3      AAA (sf)                      18.41
           A-4      AAA (sf)                      18.41
           B        AA+ (sf)                      14.80
           C        AA- (sf)                      13.42
           X1       AAA (sf)                        N/A
           X2       AAA (sf)                        N/A

                       N/A - Not applicable.


COMM 2007-FL14: Moody's Reviews Ratings on 10 Classes of Notes
--------------------------------------------------------------
Moody's Investors Service placed ten pooled classes and twelve
non-pooled, or rake, classes of COMM 2007-FL14 Commercial Pass-
Through Certificates, Series 2007-FL14 on review for possible
downgrade:

  -- Cl. A-J, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on May 24, 2007 Definitive Rating Assigned Aaa
      (sf)

  -- Cl. B, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to Aa2 (sf)

  -- Cl. C, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to A1 (sf)

  -- Cl. D, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to A2 (sf)

  -- Cl. E, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to Baa1 (sf)

  -- Cl. F, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to Baa2 (sf)

  -- Cl. G, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to Baa3 (sf)

  -- Cl. H, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to Ba1 (sf)

  -- Cl. J, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to Ba2 (sf)

  -- Cl. K, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to Ba3 (sf)

  -- Cl. GLB1, Ba1 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 24, 2009 Downgraded to Ba1 (sf)

  -- Cl. GLB2, Ba2 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 24, 2009 Downgraded to Ba2 (sf)

  -- Cl. GLB4, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to B1 (sf)

  -- Cl. AOA1, Ba3 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 24, 2009 Downgraded to Ba3 (sf)

  -- Cl. AOA2, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to B2 (sf)

  -- Cl. AOA4, Caa1 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 24, 2009 Downgraded to Caa1
     (sf)

  -- Cl. PH1, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to Ba1 (sf)

  -- Cl. PH2, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to Ba2 (sf)

  -- Cl. PH3, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 24, 2009 Downgraded to Ba3 (sf)

  -- Cl. CA1, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to B1 (sf)

  -- Cl. CA2, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to B3 (sf)

  -- Cl. CA3, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to B3 (sf)

The ten pooled classes have been placed on review for possible
downgrade due to the continued performance deterioration in the
majority of the loans in the pool.  The twelve non-pooled classes
have been placed on review for possible downgrade due to
performance issues specific to the MSREF/Glenborough Portfolio
Loan, the 1330 Avenue of the Americas Loan, the San Francisco Parc
55 Loan and the Carr California Portfolio Loan.


COMMERCIAL MORTGAGE: Moody's Cuts Ratings on Six 1999-C1 Certs.
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of six classes
and affirmed seven classes of Commercial Mortgage Asset Trust,
Commercial Mortgage Pass-Through Certificates, Series 1999-C1:

  -- Cl. A-3, Affirmed at Aaa (sf); previously on March 25, 1999
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed at Aaa (sf); previously on March 25, 1999
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X, Affirmed at Aaa (sf); previously on March 25, 1999
     Definitive Rating Assigned Aaa (sf

  -- Cl. B, Affirmed at Aaa (sf); previously on July 8, 2004
     Upgraded to Aaa (sf)

  -- Cl. C, Affirmed at Aaa (sf); previously on July 20, 2006
     Upgraded to Aaa (sf)

  -- Cl. D, Affirmed at Aaa (sf); previously on Sept. 25, 2008
     Upgraded to Aaa (sf)

  -- Cl. E, Affirmed at Aa2 (sf); previously on Sept. 25, 2008
     Upgraded to Aa2 (sf)

  -- Cl. F, Downgraded to Baa2 (sf); previously on Aug. 9, 2007
     Upgraded to Baa1 (sf)

  -- Cl. G, Downgraded to B3 (sf); previously on March 25, 1999
     Definitive Rating Assigned Ba2 (sf)

  -- Cl. H, Downgraded to Caa3 (sf); previously on March 25, 1999
     Definitive Rating Assigned Ba3 (sf)

  -- Cl. J, Downgraded to C (sf); previously on May 7, 2009
     Downgraded to Caa2 (sf)

  -- Cl. K, Downgraded to C (sf); previously on May 7, 2009
     Downgraded to Ca (sf)

  -- Cl. L, Downgraded to C (sf); previously on July 20, 2006
     Downgraded to Ca (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans and concerns about loans approaching
maturity in an adverse environment.  Forty-four loans,
representing 52% of the pool, mature within the next 36 months.
Nine of these loans, representing 27% of the pool, have a Moody's
stressed debt service coverage ratio less than 1.0X.

The affirmations are due to key parameters, including Moody's loan
to value ratio, Moody's stressed DSCR and the Herfindahl Index,
remaining within acceptable ranges.  Based on Moody's current base
expected loss, the credit enhancement levels for the affirmed
classes are sufficient to maintain their current ratings.

Moody's rating action reflects a cumulative base expected loss of
9.1% of the current balance.  At last review, Moody's cumulative
base expected loss was 6.6%.  Moody's stressed scenario loss is
12.2% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the credit estimate of the
loan which corresponds to a range of credit enhancement levels.
Actual fusion credit enhancement levels are selected based on loan
level diversity, pool leverage and other concentrations and
correlations within the pool.  Negative pooling, or adding credit
enhancement at the credit estimate level, is incorporated for
loans with similar credit estimates in the same transaction.

For deals that include a pool of credit tenant loans, Moody's
currently uses a Gaussian copula model, incorporated in its public
CDO rating model CDOROMv2.6 to generate a portfolio loss
distribution to assess the ratings.  Under Moody's CTL approach,
the rating of a transaction's certificates is primarily based on
the senior unsecured debt rating (or the corporate family rating)
of the tenant, usually an investment grade rated company, leasing
the real estate collateral supporting the bonds.  This tenant's
credit rating is the key factor in determining the probability of
default on the underlying lease.  The lease generally is
"bondable", which means it is an absolute net lease, yielding
fixed rent paid to the trust through a lock-box, sufficient under
all circumstances to pay in full all interest and principal of the
loan.  The leased property should be owned by a bankruptcy-remote,
special purpose borrower, which grants a first lien mortgage and
assignment of rents to the securitization trust.  The dark value
of the collateral, which assumes the property is vacant or "dark",
is then examined to determine a recovery rate upon a loan's
default.  Moody's also considers the overall structure and legal
integrity of the transaction.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated May 7, 2009.  Please see
the ratings tab on the issuer / entity page on moodys.com for the
last rating action and the ratings history.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.

                         Deal Performance

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 50% to
$1.17 billion from $2.37 billion at securitization.  The
Certificates are collateralized by 139 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten non-
defeased loans representing 41% of the pool.  Forty-one loans,
representing 25% of the pool, have defeased and are collateralized
with U.S. Government securities.  The pool contains 10 loans,
representing 6% of the pool, that are credit tenant lease loans.

Thirty-six 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 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.

Twenty-two loans have been liquidated from the pool, resulting in
an aggregate realized loss of $48.7 million (34% loss severity
overall).  Four loans, representing 18% of the pool, are currently
in special servicing.  The master servicer has recognized an
aggregate $5.2 million appraisal reduction for two of the
specially serviced loans.

The largest specially serviced loan is The Source Loan
($124.0 million -- 10.6%), which is secured by a 521,500 square
foot mall located in Westbury, New York.  The center is shadow
anchored by a Fortunoff Backyard store.  Two of the larger tenants
in the mall were Circuit City and Steve & Barry's, both of which
declared bankruptcy and vacated the mall several years ago.  The
loan was transferred to special servicing in January 2009 due to
tenant issues as well as pending maturity.  The loan matured on
March 11, 2009 and was unable to refinance.  The loan sponsor is
Simon Property Group.  The loan is 90+ days delinquent.  The
servicer is discussing a loan extension but is also considering
enforcement actions.

The second largest loan in special servicing is the Springfield
Mall Loan ($78.7 million -- 6.7%), which represents a 50% pari
passu interest in a $157.4 million loan.  The loan is secured by
the borrower's interest in a 1.4 million square foot regional mall
located in Springfield (Fairfax County), Virginia.  The property
is anchored by J.C. Penney, Macy's and Target.  The loan sponsor
is Vornado Realty who purchased the property in 2005 and
originally planned a major redevelopment and expansion of the
property.  The loan is in the process of foreclosure.

The remaining two specially serviced loans, representing 0.5% of
the pool, are real estate owned.  Moody's is estimating an
aggregate $74.6 million loss from the specially serviced loans.

Moody's has assumed a high default probability for four poorly
performing loans representing 6% of the pool and has estimated a
$15.1 million loss (20% expected loss based on a 50% probability
default) from these troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 89% and 54% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 67% compared to 82% at Moody's prior review.
Moody's net cash flow reflects a weighted average haircut of 12%
to the most recently available net operating income.  Moody's
value reflects a weighted average capitalization rate of 10.0%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.60X and 1.90X, respectively, compared to
1.39X and 1.60X 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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 21 compared to 29 at Moody's prior review.

The top three performing conduit loans represent 10% of the pool
balance.  The largest loan is the Laurel Mall Loan ($46.4 million
-- 4.0%), which is secured by the borrower's interest in a 505,000
square foot regional mall located in Livonia, Michigan.  The mall
is anchored by Von Maur and Parisian and is 99% leased,
essentially the same as last review.  The loan sponsor is CBL &
Associates Properties, Inc. Performance has been stable.  Moody's
LTV and stressed DSCR are 68% and 1.54X, respectively, compared to
70% and 1.51X at last review.

The second largest loan is the Baldwin Complex Loan ($42.3 million
- 3.6%), which is secured by two office buildings located in
Cincinnati, Ohio.  The two buildings total 455,000 square feet.
The property is only 50% leased compared to 58% at last review.
The loan is current but on the servicer watchlist due to low
occupancy and DSCR.  Moody's considers this loan to be a high
default risk and has identified it as a troubled loan.  Moody's
LTV and stressed DSCR are 163% and 0.73X, respectively, compared
to 188% and 0.63X at last review.

The third largest loan is the Best of the West Shopping Center
Loan ($35.1 million -- 3.0%), which is secured by a 475,000 square
feet retail property located in Las Vegas, Nevada.  The property
is 89% leased, the same as last review.  Performance has been
stable.  Moody's LTV and stressed DSCR are 64% and 1.59X,
respectively, compared to 65% and 1.58X at last review.

The CTL component includes ten loans secured by properties leased
under bondable leases.  The largest CTL exposures are Accor SA
($35.9 million -- 3.1%;) and R.R. Donnelley & Sons Co.
($18.2 million -- 1.5%; Moody's senior unsecured rating Baa3 -
stable outlook).


COMMERCIAL MORTGAGE: Moody's Takes Rating Actions on Certificates
-----------------------------------------------------------------
Moody's Investors Service upgraded the rating of one class,
downgraded the ratings of three classes and affirmed four classes
of Commercial Mortgage Acceptance Corp, Commercial Mortgage Pass-
Through Certificates 1999-C1:

  -- Cl. X, Affirmed at Aaa (sf); previously on July 27, 1999
     Assigned Aaa (sf)

  -- Cl. H, Upgraded to Aaa (sf); previously on July 30, 2009
     Upgraded to Aa2 (sf)

  -- Cl. J, Affirmed at Baa3 (sf); previously on May 24, 2007
     Upgraded to Baa3 (sf)

  -- Cl. K, Affirmed at Ba2 (sf); previously on May 24, 2007
     Upgraded to Ba2 (sf)

  -- Cl. L, Affirmed at Caa1 (sf); previously on July 30, 2009
     Downgraded to Caa1 (sf)

  -- Cl. M, Downgraded to C (sf); previously on July 30, 2009
     Downgraded to Caa2 (sf)

  -- Cl. N, Downgraded to C (sf); previously on July 30, 2009
     Downgraded to Ca (sf)

  -- Cl. O, Downgraded to C (sf); previously on July 30, 2009
     Downgraded to Ca (sf)

                        Ratings Rationale

The upgrade is due to the significant increase in subordination
due to loan payoffs and amortization and the pool's exposure to
defeased loans, which represents 12% of the current pool balance.
The pool has paid down by 36% since Moody's last review.

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans, a decline in loan diversity, as
measured by the Herfindahl index, and concerns about refinance
risk associated with loans approaching maturity in an adverse
environment.  Nine loans, representing 56% of the pool, have
either matured or mature within the next six months.  Eight of
these loans, representing 54% of the pool, have a Moody's stressed
debt service coverage less than 1.00X.

The affirmations are due to key parameters, including Moody's loan
to value ratio and Moody's stressed DSCR remaining within
acceptable ranges.  Based on Moody's current base expected loss,
the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings.

Moody's rating action reflects a cumulative base expected loss of
28.8% of the current balance.  At last review, Moody's cumulative
base expected loss was 28.9%.  Moody's stressed scenario loss is
29.6% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions as well as the excel-based CMBS Large Loan Model v.
8.0 which is used for Large Loan transactions.  Conduit model
results at the Aa2 level are driven by property type, Moody's
actual and stressed DSCR, and Moody's property quality grade
(which reflects the capitalization rate used by Moody's to
estimate Moody's value).  Conduit model results at the B2 level
are driven by a paydown analysis based on the individual loan
level Moody's LTV ratio.  Moody's Herfindahl score, a measure of
loan level diversity, is a primary determinant of pool level
diversity and has a greater impact on senior certificates.  Other
concentrations and correlations may be considered in Moody's
analysis.  Based on the model pooled credit enhancement levels at
Aa2 and B2, the remaining conduit classes are either interpolated
between these two data points or determined based on a multiple or
ratio of either of these two data points.  For fusion deals, the
credit enhancement for loans with investment-grade credit
estimates is melded with the conduit model credit enhancement into
an overall model result.  Fusion loan credit enhancement is based
on the underlying rating of the loan which corresponds to a range
of credit enhancement levels.  Actual fusion credit enhancement
levels are selected based on loan level diversity, pool leverage
and other concentrations and correlations within the pool.
Negative pooling, or adding credit enhancement at the underlying
rating level, is incorporated for loans with similar credit
estimates in the same transaction.

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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 9 compared to 21 at Moody's prior review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology.  This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation.  The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios.  Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship.  These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated July 30, 2009.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 93% to
$55.4 million from $733.8 million at securitization.  The
Certificates are collateralized by 26 mortgage loans ranging in
size from less than 1% to 14% of the pool, with the top ten loans
representing 72% of the pool.  The pool contains 13 conduit loans
representing 34% of the pool.  The remaining pool consists of five
defeased loans (12% of the pool) and eight specially serviced
loans (54% of the pool).

Three loans, representing 15% 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 monthly reporting package.  Moody's has assumed a
high default probability for all the watchlisted loans plus an
additional loan that faces near-term refinance risk.  Moody's has
estimated a $3.3 million loss (31% expected loss based on a 100%
default probability) from these troubled loans.

Fourteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $8.9 million (23% loss severity
overall).  Eight loans, representing 54% of the pool, are
currently in special servicing.  The largest specially serviced
loan is The Place Apartments Loan ($7.6 million -- 14% of the
pool), which is secured by a 230-unit multifamily property located
in Fort Myers, Florida.  The loan was transferred to special
servicing in December 2008 due to monetary default and is
currently 60 days delinquent.  The remaining seven specially
serviced loans are secured by a mix of property types.  Moody's
has estimated an aggregate $12.5 million loss (42% expected loss
on average) for the specially serviced loans.

Based on the most recent remittance statement, Classes M through
P have experienced cumulative interest shortfalls totaling
$2.5 million.  Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced loans.  Interest shortfalls are caused by
special servicing fees, including workout and liquidation fees,
appraisal subordinate entitlement reductions and extraordinary
trust expenses.

Moody's was provided with full year 2009 operating results for 89%
of the pool's nine performing conduit loans.  Excluding specially
serviced and troubled loans, Moody's weighted average LTV is 44%,
compared to 91% at Moody's prior review.  Moody's net cash flow
reflects a weighted average haircut of 11.1% to the most recently
available net operating income.  Moody's value reflects a weighted
average capitalization rate of 9.5%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.46X and 2.99X, respectively, compared to
1.15X and 1.66X 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.

Due to the high percentage of loans in special servicing, Moody's
analysis was largely based on a loss and recovery analysis for
specially serviced and troubled loans.  The performance of the
performing conduit component, which only represents 15% of the
pool, is stable and performing inline with Moody's expectations.


COUNTRYWIDE COMMERCIAL: Moody's Cuts Ratings on 16 2007-MF1 Certs.
------------------------------------------------------------------
Moody's Investors Service downgraded the ratings of 16 classes of
Countrywide Commercial Mortgage Pass -Through Certificates, Series
2007-MF1:

  -- Cl. A, Downgraded to Baa2 (sf); previously on Sept. 29, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Downgraded to Ba1 (sf); previously on Sept. 29, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Downgraded to Ba2 (sf); previously on Sept. 29, 2010
     A1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to Ba3 (sf); previously on Sept. 29, 2010
     A2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to B2 (sf); previously on Sept. 29, 2010 A3
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to Caa2 (sf); previously on Sept. 29, 2010
     Baa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to Caa3 (sf); previously on Sept. 29, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. H, Downgraded to Ca (sf); previously on Sept. 29, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. J, Downgraded to C (sf); previously on Sept. 29, 2010 Ba1
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. K, Downgraded to C (sf); previously on Sept. 29, 2010 B1
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. L, Downgraded to C (sf); previously on Sept. 29, 2010 B2
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. M, Downgraded to C (sf); previously on Sept. 29, 2010 B3
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. N, Downgraded to C (sf); previously on Sept. 29, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. P, Downgraded to C (sf); previously on Sept. 29, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. Q, Downgraded to C (sf); previously on Sept. 29, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. S, Downgraded to C (sf); previously on Sept. 29, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans.

This transaction is classified as a small balance CMBS
transaction.  Small balance transactions, which represent
approximately 1% of the Moody's rated conduit/fusion universe,
have generally experienced higher defaults and losses than
traditional conduit and fusion transaction.

On September 29, 2010 Moody's placed 16 classes on review for
possible downgrade.  This action concludes Moody's review.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.  Primary sources of assumption uncertainty are
the current stressed macroeconomic environment and continuing
weakness in the commercial real estate and lending markets.
Moody's currently views the commercial real estate market as
stressed with further performance declines expected in the
industrial, office, and retail sectors.  Hotel performance has
begun to rebound, albeit off a very weak base.  Multifamily has
also begun to rebound reflecting an improved supply / demand
relationship.  The availability of debt capital is improving with
terms returning towards market norms.  Job growth and housing
price stability will be necessary precursors to commercial real
estate recovery.  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's largest economies, returning to
trend growth rate with elevated fiscal deficits and persistent
unemployment levels.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the creditenhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the underlying rating of the
loan which corresponds to a range of credit enhancement levels.
Actual fusion credit enhancement levels are selected based on loan
level diversity, pool leverage and other concentrations and
correlations within the pool.  Negative pooling, or adding credit
enhancement at the underlying rating level, is incorporated for
loans with similar credit estimates in the same transaction.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior review is
summarized in a press release dated February 6, 2009.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 5% to $605.1
million from $639.9 million at securitization.  The Certificates
are collateralized by 240 mortgage loans ranging in size from less
than 1% to 6% of the pool, with the top ten loans representing 27%
of the pool.  The pool has a Herfindahl score of 78 compared to 89
at Moody's last review.

Fifty-one 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 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 since
securitization, resulting in an aggregate $1.1 million loss (51%
loss severity on average).  Currently 14 loans, representing 10%
of the pool, are in special servicing.  The master servicer has
recognized an aggregate $26.1 million appraisal reduction for nine
of the specially serviced loans.  Moody's has estimated an
aggregate $31.1 million loss for the specially serviced loans (51%
expected loss on average).

Moody's has assumed a high default probability for 14 poorly
performing loans representing 6% of the pool and has estimated an
$8.9 million loss (25% expected loss based on a 50% probability
default) from these troubled loans.  Moody's rating action
reflects a cumulative base expected loss of 8% of the current
balance.

The pool has experienced significant interest shortfalls.  Based
on the most recent remittance statement, Classes K through T have
experienced cumulative interest shortfalls totaling $1.12 million.
Moody's anticipates that the pool will continue to experience
interest shortfalls because of the high exposure to specially
serviced loans.  Interest shortfalls are caused by special
servicing fees, including workout and liquidation fees, appraisal
subordinate entitlement reductions and extraordinary trust
expenses.

Moody's was provided with full year 2009 and partial year 2010
operating results for 89% and 64% of the performing pool,
respectively.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 106%, compared to 118% at last
review.  Moody's net cash flow reflects a weighted average haircut
of 10% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
8.6%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.15X and 0.91X, respectively, compared to
1.10X and 0.86X 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.

Due to the high percentage of loans in special servicing, Moody's
analysis was largely based on a a loss and recovery analysis of
specially serviced and troubled loans.  The remainder of the pool
is performing in-line with Moody's expectations.


CREDIT AND REPACKAGED: Moody's Upgrades Rating on 2006-11 Notes
---------------------------------------------------------------
Moody's Investors Service announced this rating action on Credit
and Repackaged Securities Limited Series 2006-11, a leveraged
super senior collateralized debt obligation transaction
referencing a portfolio of synthetic corporate bonds.

  -- US$268,750,000 CARS 2006-11 Notes, Upgraded to Ba1 (sf);
     previously on March 20, 2009 Downgraded to B2 (sf)

                        Ratings Rationale

Moody's explained that the rating actions taken are the result of
spread tightening in the underlying portfolio, higher spread/loss
trigger points due to the passage of time, and the improving
credit quality in the underlying portfolio.  Since the last rating
review in March 2009, the 10-year weighted average rating factor
of the portfolio dropped from 1,279, equivalent to B1, to 952,
equivalent to Ba2, excluding settled credit events.  The weighted-
average spread of the portfolio tightened from 373 bps to 115 bps.
Coupled with the passage of time, the distance to spread trigger
increased from 145 bps to 581 bps.

The portfolio has experienced 6 credit events, equivalent to 4.4%
of the referenced CSO portfolio, based on the portfolio value at
closing.  In addition, the portfolio is exposed to Clear Channel
Communications, Inc. and Harrah's Operating Company, Inc., both of
which are not credit events, but nonetheless are rated Ca.  While
the credit quality of the portfolio has improved since the last
rating review, Moody's notes that the portfolio is negatively
skewed in outlook, with 20 reference entities with a negative
outlook as opposed to 8 reference entities with a positive
outlook.

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios from the base case modeling result, as
indicated below:

(1) MIRs -- Moody's rating action takes into account the result of
    a sensitivity analysis consisting of modeling MIRs in place of
    the corporate fundamental rating to derive the default
    probability of each corporate name in the reference portfolio.
    The gap between an MIR and a Moody's corporate fundamental
    rating is an indicator of the extent of the divergence of
    credit view between Moody's and the market on each referenced
    name in the CSO portfolio. The result of this run was the same
    as the base case.

(2) Defaulting all reference entities currently rated C or Ca --
    The result from this run was 1 notch lower than in the base
    case.

(3) Defaulting all reference entities currently rated C or Ca and
    apply an additional default probability stress of 30% for the
    remaining reference entities -- The result from this run was 2
    notches lower than in the base case.

(4) Shorten the time to maturity by 6-months -- The result from
    this run was the same as in the base case.

(5) Combine scenarios (3) and (4) -- The result from this run was
    the same as in the base case.

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..

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Corporate Synthetic
Obligations", key model inputs used by Moody's in its analysis may
be different from the manager/arranger's reported numbers.  In
particular, rating assumptions for all publicly rated corporate
credits in the underlying portfolio have been adjusted for "Review
for Possible Downgrade", "Review for Possible Upgrade", or
"Negative Outlook".

Moody's analysis of CSOs is subject to uncertainties, the primary
sources of which includes complexity, governance and leverage.
The methodology captures many of the dynamics of the Corporate CSO
structure, but it remains a simplification of the complex reality.
Of greatest concern are (a) variations over time in default rates
for instruments with a given rating, (b) variations in recovery
rates for instruments with particular seniority/security
characteristics and (c) uncertainty about the default and recovery
correlations characteristics of the reference pool.  Similarly on
the legal/structural side, the legal analysis although typically
based in part on opinions (and sometimes interpretations) of legal
experts at the time of issuance, is still subject to potential
changes in law, case law and the interpretations of courts and (in
some cases) regulatory authorities.  The performance of this CSO
is also dependent on on-going decisions made by one or several
parties, including the Manager and the Trustee.  Although the
impact of these decisions is mitigated by structural constraints,
anticipating the quality of these decisions necessarily introduces
some level of uncertainty in Moody's assumptions.  Given the
tranched nature of Corporate CSO liabilities, rating transitions
in the reference pool may have leveraged rating implications for
the ratings of the Corporate CSO liabilities, thus leading to a
high degree of volatility.  All else being equal, the volatility
is likely to be higher for more junior or thinner liabilities.

The base case scenario modeled fits into the central macroeconomic
scenario predicted by Moody's of a sluggish recovery scenario of
the corporate universe.  Should macroeconomics conditions evolves
towards a more severe scenario such as a double dip recession, the
CSO rating will likely be downgraded to an extent depending on the
expected severity of the worsening conditions.


CREDIT AND REPACKAGED: Moody's Upgrades Ratings on 2 Notes to Ba3
-----------------------------------------------------------------
Moody's Investors Service announced these rating actions on Credit
and Repackaged Securities Limited Series 2006-14 & 2007-11,
leveraged super senior collateralized debt obligation transactions
referencing a portfolio of synthetic corporate bonds.

Issuer: CARS 2006-14

  -- US$268,750,000.00 Single Tranche Notes due December 20,
     2016, Upgraded to Ba3 (sf); previously on March 20, 2009
     Downgraded to B3 (sf)

Issuer: Credit and Repackaged Securities, Limited 2007-11

  -- US$268,750,000.00 CARS 2007-11 Notes, Upgraded to Ba3 (sf);
     previously on March 20, 2009 Downgraded to B3 (sf)

                        Ratings Rationale

Moody's explained that the rating actions taken are the result of
spread tightening in the underlying portfolio, higher spread/loss
trigger points due to the passage of time, and the improving
credit quality in the underlying portfolio.  Since the last rating
review in March 2009, the 10-year weighted average rating factor
of the portfolio dropped from 1157, equivalent to Ba3, to 910,
equivalent to Ba1, excluding settled credit events.  The weighted-
average spread of the portfolio tightened from 345 bps to 159 bps.
Coupled with the passage of time, the distance to spread trigger
increased from 203 bps to 430 bps.

The portfolio has experienced 5 credit events, equivalent to 3.6%
of the referenced CSO portfolio, based on the portfolio value at
closing.  In addition, the portfolio is exposed to Clear Channel
Communications, Inc., Harrah's Operating Company, Inc., and
Residential Capital, LLC, all of which are not credit events, but
nonetheless are rated either Ca or C.  While the credit quality of
the portfolio has improved since the last rating review, Moody's
notes that the portfolio is negatively skewed in outlook, with 21
reference entities with a negative outlook as opposed to 9
reference entities with a positive outlook.

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios in addition to the base case modeling
results, as indicated below:

(1) MIRs -- Moody's rating action takes into account the result of
    a sensitivity analysis consisting of modeling MIRs in place of
    the corporate fundamental rating to derive the default
    probability of each corporate name in the reference portfolio.
    The gap between an MIR and a Moody's corporate fundamental
    rating is an indicator of the extent of the divergence of
    credit view between Moody's and the market on each referenced
    name in the CSO portfolio.  The result of this run was 1 notch
    higher than in the base case.

(2) Defaulting all reference entities currently rated C or Ca --
    The result from this run was 1 notch lower than in the base
    case.

(3) Defaulting all reference entities currently rated C or Ca and
    apply an additional default probability stress of 30% for the
    remaining reference entities -- The result from this run was 1
    notch lower than in the base case.

(4) Shorten the time to maturity by 6-months -- The result from
    this run was 1 notch higher than in the base case.

(5) Combine scenarios (3) and (4) -- The result from this run was
    1 notch higher than in the base case.

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.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Corporate Synthetic
Obligations", key model inputs used by Moody's in its analysis may
be different from the manager/arranger's reported numbers.  In
particular, rating assumptions for all publicly rated corporate
credits in the underlying portfolio have been adjusted for "Review
for Possible Downgrade", "Review for Possible Upgrade", or
"Negative Outlook".

Moody's analysis of CSOs is subject to uncertainties, the primary
sources of which includes complexity, governance and leverage.
The methodology captures many of the dynamics of the Corporate CSO
structure, but it remains a simplification of the complex reality.
Of greatest concern are (a) variations over time in default rates
for instruments with a given rating, (b) variations in recovery
rates for instruments with particular seniority/security
characteristics and (c) uncertainty about the default and recovery
correlations characteristics of the reference pool.  Similarly on
the legal/structural side, the legal analysis although typically
based in part on opinions (and sometimes interpretations) of legal
experts at the time of issuance, is still subject to potential
changes in law, case law and the interpretations of courts and (in
some cases) regulatory authorities.  The performance of this CSO
is also dependent on on-going decisions made by one or several
parties, including the Manager and the Trustee.  Although the
impact of these decisions is mitigated by structural constraints,
anticipating the quality of these decisions necessarily introduces
some level of uncertainty in Moody's assumptions.  Given the
tranched nature of Corporate CSO liabilities, rating transitions
in the reference pool may have leveraged rating implications for
the ratings of the Corporate CSO liabilities, thus leading to a
high degree of volatility.  All else being equal, the volatility
is likely to be higher for more junior or thinner liabilities.

The base case scenario modeled fits into the central macroeconomic
scenario predicted by Moody's of a sluggish recovery scenario of
the corporate universe.  Should macroeconomics conditions evolves
towards a more severe scenario such as a double dip recession, the
CSO rating will likely be downgraded to an extent depending on the
expected severity of the worsening conditions.


CREST 2003-2: Moody's Downgrades Ratings on 11 Classes of Notes
---------------------------------------------------------------
Moody's has downgraded eleven classes of Notes issued by Crest
2003-2, Ltd. due to the deterioration in the credit quality of the
underlying portfolio as evidenced by an increase in the weighted
average rating factor and increase in Defaulted Securities.  The
rating action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation
transactions.

  -- Cl. A-1, Downgraded to Aa2 (sf); previously on Jan. 23, 2009
     Downgraded to Aa1 (sf)

  -- Cl. A-2, Downgraded to Aa2 (sf); previously on Jan. 23, 2009
     Downgraded to Aa1 (sf)

  -- Cl. A-3, Downgraded to Aa2 (sf); previously on Jan. 23, 2009
     Downgraded to Aa1 (sf)

  -- Cl. B-1, Downgraded to Baa2 (sf); previously on Jan. 23, 2009
     Downgraded to Baa1 (sf)

  -- Cl. B-2, Downgraded to Baa2 (sf); previously on Jan. 23, 2009
     Downgraded to Baa1 (sf)

  -- Cl. C-1, Downgraded to Ba2 (sf); previously on Jan. 23, 2009
     Downgraded to Baa3 (sf)

  -- Cl. C-2, Downgraded to Ba2 (sf); previously on Jan. 23, 2009
     Downgraded to Baa3 (sf)

  -- Cl. D-1, Downgraded to B2 (sf); previously on Jan. 23, 2009
     Downgraded to Ba2 (sf)

  -- Cl. D-2, Downgraded to B2 (sf); previously on Jan. 23, 2009
     Downgraded to Ba2 (sf)

  -- Cl. E-1, Downgraded to Caa3 (sf); previously on Jan. 23, 2009
     Downgraded to Ba3 (sf)

  -- Cl. E-2, Downgraded to Caa3 (sf); previously on Jan. 23, 2009
     Downgraded to Ba3 (sf)

                        Ratings Rationale

Crest 2003-2, Ltd., is a CRE CDO transaction backed by a portfolio
of commercial mortgage backed securities (87.4% of the pool
balance), real estate investment trust debt (7.2%), ten credit
tenant leases securities (3.8%) and one CRE CDO class (1.6%).  As
of the September 30, 2010 Trustee report, the aggregate Note
balance of the transaction has decreased to $305.6 million from
$325.0 million at issuance, with the paydown directed to the Class
A-1, Class A-2 and Class A-3 Notes.

There are seven assets with a par balance of $30.6 million (10.0%
of the current pool balance) that are considered Credit Risk
Securities and eight assets with a par balance of $32.5 million
(10.6% of the current pool balance) that are considered Defaulted
Securities as of the September 30, 2010 Trustee report.  While
there have been no realized losses to date, Moody's does expect
significant losses to occur once they are realized.

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.  These parameters are typically modeled as actual
parameters for static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's have completed updated credit estimates for the non-
Moody's rated reference obligations.  The bottom-dollar WARF is a
measure of the default probability within a collateral pool.
Moody's modeled a bottom-dollar WARF of 2,661 compared to 1,030 at
last review.  The distribution of current ratings and credit
estimates is: Aaa-Aa3 (4.7% compared to 4.4% at last review), A1-
A3 (6.1% compared to 6.2% at last review), Baa1-Baa3 (13.9%
compared to 24.3% at last review), Ba1-Ba3 (50.2% compared to
60.6% at last review), B1-B3 (4.8% compared to 3.8% at last
review), and Caa1-C (20.3% compared to 0.7% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of 2.8
years compared to 4.3 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 a fixed WARR
with a mean of 19.4% compared to 18.4% at last review.  The WARR
increased slightly since last review due to the increased tranche
thickness of the underlying collateral.

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 14.0% compared to 39.3% at last review.
The low MAC is due to greater distribution in the default
probability of the collateral concentrated within a small number
of collateral names.

Moody's review incorporated CDOROM(R) v2.6, one of Moody's CDO
rating models, which was released on May 27, 2010.

The cash flow model, CDOEdge(R) v3.2, was used to analyze the cash
flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes.  However,
in many instances, a change in key parameter assumptions in
certain stress scenarios may be offset by a change in one or more
of the other key parameters.  Rated notes are particularly
sensitive to changes in recovery rate assumptions.  Holding all
other key parameters static, changing the mean recovery rate
assumption down from 19.4% to 9.4% or up to 29.4% would result in
average rating movement on the rated tranches of 0 to 2 notch
downward and 0 to 2 notch upward, respectively.

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 stressed macroeconomic environment and
continuing weakness in the commercial real estate and lending
markets.  Moody's currently views the commercial real estate
market as stressed with further performance declines expected in a
majority of property sectors.  The availability of debt capital is
improving with terms returning towards market norms.  Job growth
and housing price stability will be necessary precursors to
commercial real estate recovery.  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's largest
economies, returning to trend growth rate with elevated fiscal
deficits and persistent unemployment levels.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.


CREST G-STAR: Moody's Takes Rating Actions on Four Classes
----------------------------------------------------------
Moody's Investors Service has affirmed one and downgraded three
classes of Notes issued by Crest G-Star 2001-2, Ltd.  The
affirmation is due to paydown of the Class A Notes and the
downgrade is due to the deterioration in the credit quality of the
underlying portfolio as evidenced by an increase in the weighted
average rating factor, and an increase in Defaulted Securities.
The rating action is the result of Moody's on-going surveillance
of commercial real estate collateralized debt obligation
transactions.

Issuer: Crest G-Star 2001-2, Ltd.

  -- Class A Senior Secured Floating Rate Term Notes Due 2017,
     Affirmed at Aa3 (sf); previously on March 10, 2009 Downgraded
     to Aa3 (sf)

  -- Class B-1 Second Priority Fixed Rate Term Notes, Due 2032,
     Downgraded to Ba1 (sf); previously on March 10, 2009
     Downgraded to Baa2 (sf)

  -- Class B-2 Second Priority Floating Rate Term Notes, Due 2032,
     Downgraded to Ba1 (sf); previously on March 10, 2009
     Downgraded to Baa2 (sf)

  -- Class C Third Priority Fixed Rate Term Notes, Due 2032,
     Downgraded to Caa3 (sf); previously on March 10, 2009
     Downgraded to Ba2 (sf)

                        Ratings Rationale

Crest G-Star 2001-2, Ltd., is a CRE CDO transaction backed by a
portfolio real estate investment trust debt (51.6% of the pool
balance) and commercial mortgage backed securities (48.4%).  As of
the September 30, 2010 Trustee report, the aggregate Note balance
of the transaction has decreased to $254.3 million from
$355.3 million at issuance, with the paydown directed to the Class
A Notes.

There are three assets with a par balance of $30.2 million (13% of
the current pool balance) that are considered Credit Risk
Securities and two assets with a par balance of $15.3 million
(6.5% of the cuurent pool balance) that are considered Defaulted
Securities as of the September 30, 2010 Trustee report.  While
there have been no realized losses to date, Moody's does expect
significant losses to occur once they are realized.

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.  These parameters are typically modeled as actual
parameters for static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's have completed updated credit estimates for the non-
Moody's rated reference obligations.  The bottom-dollar WARF is a
measure of the default probability within a collateral pool.
Moody's modeled a bottom-dollar WARF of 1,663 compared to 552 at
last review.  The distribution of current ratings and credit
estimates is: Aaa-Aa3 (6.3% compared to 6.8% at last review), A1-
A3 (15.4% compared to 12.3% at last review), Baa1-Baa3 (48.8%
compared to 54.0% at last review), Ba1-Ba3 (14.1% compared to
22.4% at last review), B1-B3 (3.4% compared to 4.5% at last
review), and Caa1-C (12.0% compared to 0.0% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of 2.2
years compared to 3.1 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 a variable
WARR with a mean of 35%, the same as that at last review.  The
mean WARR did not change since last review due to the increased
tranche thickness of the underlying collateral.

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 6.2% compared to 36.3% at last review.
The low MAC is due to greater distribution in the default
probability of the collateral concentrated within a small number
of collateral names.

Moody's review incorporated CDOROM(R) v2.6, one of Moody's CDO
rating models, which was released on May 27, 2010.

The cash flow model, CDOEdge(R) v3.2, was used to analyze the cash
flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes.  However,
in many instances, a change in key parameter assumptions in
certain stress scenarios may be offset by a change in one or more
of the other key parameters.  Rated notes are particularly
sensitive to changes in recovery rate assumptions.  Holding all
other key parameters static, changing the mean recovery rate
assumption down from 35% to 20% or up to 50% would result in
average rating movement on the rated tranches of 0 to 1 notch
downward and 0 to 1 notch upward, respectively.

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 stressed macroeconomic environment and
continuing weakness in the commercial real estate and lending
markets.  Moody's currently views the commercial real estate
market as stressed with further performance declines expected in a
majority of property sectors.  The availability of debt capital is
improving with terms returning towards market norms.  Job growth
and housing price stability will be necessary precursors to
commercial real estate recovery.  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's largest
economies, returning to trend growth rate with elevated fiscal
deficits and persistent unemployment levels.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.


CREDIT SUISSE: Moody's Reviews Ratings on 12 2002- CKN2 Certs.
--------------------------------------------------------------
Moody's Investors Service placed 12 classes of Credit Suisse First
Boston Mortgage Securities Corp., Commercial Mortgage Pass-Through
Certificates, Series 2002- CKN2 on review for possible downgrade:

  -- Cl. C-1, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 25, 2008 Upgraded to Aaa (sf)

  -- Cl. C-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 25, 2008 Upgraded to Aaa (sf)

  -- Cl. D, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 25, 2008 Upgraded to Aa2 (sf)

  -- Cl. E, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 29, 2008 Upgraded to A1 (sf)

  -- Cl. F, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on March 9, 2006 Upgraded to Baa1 (sf)

  -- Cl. G, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on May 15, 2002 Definitive Rating Assigned Baa3
     (sf)

  -- Cl. H, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on May 15, 2002 Definitive Rating Assigned Ba1
      (sf)

  -- Cl. J, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on May 15, 2002 Definitive Rating Assigned Ba2
      (sf)

  -- Cl. K, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on May 15, 2002 Definitive Rating Assigned Ba3
      (sf)

  -- Cl. L, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on May 15, 2002 Definitive Rating Assigned B1 (sf)

  -- Cl. M, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 29, 2008 Downgraded to B3 (sf)

  -- Cl. N, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 29, 2008 Downgraded to Caa1 (sf)

The classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from realized and
anticipated losses from specially serviced and troubled loans and
concerns about refinance risk associated with loan facing near-
term maturity in an adverse environment.  One hundred forty-eight
loans, representing 74% of the pool, mature within the next 24
months.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated October 29, 2008.

                   Deal And Performance Summary

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 19% to $741.5
million from $918.1 million at securitization.  The Certificates
are collateralized by 181 mortgage loans ranging in size from less
than 1% to 7% of the pool, with the top ten loans representing 33%
of the pool.  Thirty loans, representing 26% of the pool, have
defeased and are collateralized with U.S. Government securities.
Defeasance at last review represented 24% of the pool.

Twenty-six 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 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.

Six loans have been liquidated from the pool since securitization,
resulting in an aggregate $16.5 million loss (54% loss severity on
average).  Twelve loans, representing 8% of the pool, are
currently in special servicing.  The master servicer has
recognized an aggregate $9.9 million appraisal reduction for seven
of the specially serviced loans.

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


CREDIT SUISSE: Moody's Downgrades Ratings on Six 2002-CP3 Certs.
----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of six classes
and affirmed nine classes of Credit Suisse First Boston Mortgage
Securities Corp, Commercial Mortgage Pass-Through Certificates,
Series 2002-CP3:

  -- Cl. A-2, Affirmed at Aaa (sf); previously on July 29, 2002
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on July 29, 2002
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-X, Affirmed at Aaa (sf); previously on July 29, 2002
     Definitive Rating Assigned Aaa (sf)

  -- Cl. B, Affirmed at Aaa (sf); previously on March 16, 2006
     Upgraded to Aaa (sf)

  -- Cl. C, Affirmed at Aaa (sf); previously on Aug. 13, 2007
     Upgraded to Aaa (sf)

  -- Cl. D, Affirmed at Aaa (sf); previously on Aug. 13, 2007
     Upgraded to Aaa (sf)

  -- Cl. E, Affirmed at Aaa (sf); previously on Aug. 13, 2007
     Upgraded to Aaa (sf)

  -- Cl. F, Affirmed at Aa2 (sf); previously on Aug. 13, 2007
     Upgraded to Aa2 (sf)

  -- Cl. G, Affirmed at A3 (sf); previously on Aug. 13, 2007
     Upgraded to A3 (sf)

  -- Cl. H, Downgraded to Baa3 (sf); previously on Aug. 13, 2007
     Upgraded to Baa2 (sf)

  -- Cl. J, Downgraded to B2 (sf); previously on July 29, 2002
     Definitive Rating Assigned Ba2 (sf)

  -- Cl. K, Downgraded to Caa3 (sf); previously on July 29, 2002
     Definitive Rating Assigned Ba3 (sf)

  -- Cl. L, Downgraded to Ca (sf); previously on July 29, 2002
     Definitive Rating Assigned B1 (sf)

  -- Cl. M, Downgraded to C (sf); previously on July 29, 2002
     Definitive Rating Assigned B2 (sf)

  -- Cl. N, Downgraded to C (sf); previously on July 29, 2002
     Definitive Rating Assigned B3 (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans and a decline in loan diversity as
measured by the Herfindahl Index.  The affirmations are due to key
parameters, including Moody's loan to value ratio and Moody's
stressed debt service coverage ratio remaining within acceptable
ranges.  Based on Moody's current base expected loss, the credit
enhancement levels for the affirmed classes are sufficient to
maintain their current ratings.

Moody's rating action reflects a cumulative base expected loss of
4.9% of the current balance.  At last review, Moody's cumulative
base expected loss was 1.6%.  Moody's stressed scenario loss is
7.1% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the credit estimate of the
loan which corresponds to a range of credit enhancement levels.
Actual fusion credit enhancement levels are selected based on loan
level diversity, pool leverage and other concentrations and
correlations within the pool.  Negative pooling, or adding credit
enhancement at the credit estimate level, is incorporated for
loans with similar credit estimates in the same transaction.

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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 17, compared to 28 at last review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology.  This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation.  The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios.  Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship.  These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated August 13, 2007.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 18% to
$732.9 million from $895.7 million at securitization.  The
Certificates are collateralized by 84 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 41% of the pool.  Twenty five loans, representing
31% of the pool, have defeased and are collateralized with U.S.
Government securities.  The pool contains one loan, representing
10% of the pool, with an investment grade credit estimate.

Twenty three 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 monthly reporting package.  As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Two loans have been liquidated from the pool, resulting in an
aggregate realized loss of $2.2 million (27% loss severity).
Three loans, representing 2.9% of the pool, are currently in
special servicing.  The largest specially serviced loan is 5440
Corporate Drive Office Building Loan ($11.7 million -- 1.6% of the
pool), which is secured by a 92,000 square foot office property
located in Troy, Michigan.  The loan was transferred to Special
Servicing in March 2010 due to payment delinquency.  The borrower
has agreed to a consensual foreclosure.

The remaining specially serviced loans are secured by a
multifamily and retail property.  The master servicer has
recognized an aggregate $12.5 million appraisal reduction for two
of the specially serviced loans.  Moody's has estimated an
aggregate $15.1 million loss (72% expected loss on average) for
the specially serviced loans.

Moody's has assumed a high default probability for ten poorly
performing loans representing 9.1% of the pool and has estimated a
$13.4 million loss (20% expected loss based on a 50% probability
default) from these troubled loans.

Based on the most recent remittance statement, Classes M through O
have experienced cumulative interest shortfalls totaling $600,000.
Moody's anticipates that the pool will continue to experience
interest shortfalls because of the exposure to specially serviced
loans.  Interest shortfalls are caused by special servicing fees,
including workout and liquidation fees, appraisal subordinate
entitlement reductions and extraordinary trust expenses.

Moody's was provided with full year 2009 operating results for 96%
of the pool.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 78% compared to 90% at Moody's
prior review.  Moody's net cash flow reflects a weighted average
haircut of 13% to the most recently available net operating
income.  Moody's value reflects a weighted average capitalization
rate of 9.5%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.27X and 1.36X, respectively, compared to
1.24X and 1.19X 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.

The loan with a credit estimate is the Westfarms Mall Loan
($69.8 million -- 9.5% of the pool), which represents a
participation interest in a $140.0 million first mortgage loan
secured by the borrower's interest in a 1.3 million square foot
super-regional mall located in Farmington, Connecticut.  The
property is anchored by Filene's, J.C. Penney, Lord & Taylor and
Nordstrom.  As of April 2010, the center was 100% leased, the same
as last review.  Performance has increased due to increased rents
and amortization.  The loan has amortized by approximately 5%
since last review.  Moody's current credit estimate and stressed
DSCR are Aaa and 2.33X, respectively, compared to Aa1 and 1.89X at
last review.

The top three performing conduit loans represent 17% of the pool
balance.  The largest loan is the Northwoods Mall Loan
($53.7 million -- 7.3% of the pool), which is secured by a 430,000
square foot regional mall located in North Charleston, South
Carolina.  The property is anchored by JC Penny, Sears, Dillard's
and Belk's.  As of June 2010, the center was 97% leased compared
to 99% at last review.  The loan matures in July 2012 and has
amortized 9% since last review.  Moody's LTV and stressed DSCR are
68% and 1.45 X, respectively, compared to 69% and 1.57X at last
review.

The second largest loan is the Gannon West Pointe Apartments Loan
($39.3 million -- 5.4% of the pool), which is secured by a 1,047-
unit multifamily property located in Maryland Heights, Missouri.
The property was 90% leased as of January 2010 compared to 88% at
last review.  The loan matures in March 2012 and has amortized 5%
since last review.  Moody's LTV and stressed DSCR are 92% and
1.05X, respectively, compared to 108% and 0.90X at last review.

The third largest loan is The Mall at Mill Creek Loan
($31.4 million -- 4.3% of the pool), which is secured by a
290,000 square foot community retail center located in Secaucus,
New Jersey.  The center is anchored by Kohl's and Bob's Discount
Furniture.  The property was 100% leased as of May 2010 compared
to 57% at last review.  Performance has increased significantly
from last review due to the increased occupancy.  The loan matures
in May 2012 and has amortized 5% since last review.  Moody's LTV
and stressed DSCR are 81% and 1.31X, respectively, compared to
141% and 0.75X at last review.


CREDIT SUISSE: Moody's Takes Rating Actions on Various Classes
--------------------------------------------------------------
Moody's Investors Service confirmed the rating of one class,
affirmed seven classes and downgraded 12 classes of Credit Suisse
First Boston Mortgage Securities Corp., Mortgage Trust Commercial
Mortgage Pass-Through Certificates, Series 2005-C6:

  -- Cl. A-1-A, Affirmed at Aaa (sf); previously on Jan. 25, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2FL, Affirmed at Aaa (sf); previously on Jan. 25, 2006
     Assigned Aaa (sf)

  -- Cl. A-2FX, Affirmed at Aaa (sf); previously on Jan. 25, 2006
     Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on Jan. 25, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed at Aaa (sf); previously on Jan. 25, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-X, Affirmed at Aaa (sf); previously on Jan. 25, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-SP, Affirmed at Aaa (sf); previously on Jan. 25, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-M, Confirmed at Aaa (sf); previously on Sept. 30, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-J, Downgraded to A2 (sf); previously on Sept. 30, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Downgraded to Baa1 (sf); previously on Sept. 30, 2010
     A1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Downgraded to Baa2 (sf); previously on Sept. 30, 2010
     A2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to Ba1 (sf); previously on Sept. 30, 2010
     A3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to Ba2 (sf); previously on Sept. 30, 2010
     Baa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to B2 (sf); previously on Sept. 30, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to Caa1 (sf); previously on Sept. 30, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. H, Downgraded to Caa2 (sf); previously on Sept. 30, 2010
     Ba3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. J, Downgraded to Caa3 (sf); previously on Sept. 30, 2010
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. K, Downgraded to C (sf); previously on Sept. 30, 2010 B3
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. L, Downgraded to C (sf); previously on Sept. 30, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. M, Downgraded to C (sf); previously on Sept. 30, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans.  The confirmation and affirmations
are due to key parameters, including Moody's loan to value ratio,
Moody's stressed debt service coverage ratio and the Herfindahl
Index, remaining within acceptable ranges.  Based on Moody's
current base expected loss, the credit enhancement levels for the
affirmed classes are sufficient to maintain their current ratings.

On September 30, 2010, Moody's placed 13 classes on review for
possible downgrade.  This action concludes Moody's review.

Moody's rating action reflects a cumulative base expected loss of
7.2% of the current balance compared to 5.0% at Moody's prior
review.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
Overall, Moody's central global scenario remains "hook-shaped" for
2010 and 2011; Moody's expects overall a sluggish recovery in most
of the world's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the credit estimate of the
loan which corresponds to a range of credit enhancement levels.
Actual fusion credit enhancement levels are selected based on loan
level diversity, pool leverage and other concentrations and
correlations within the pool.  Negative pooling, or adding credit
enhancement at the credit estimate level, is incorporated for
loans with similar credit estimates in the same transaction.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated October 22, 2009.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance had decreased by 11% to $2.22
billion from $2.5 billion at securitization.  The Certificates are
collateralized by 218 mortgage loans ranging in size from less
than 1% to 8% of the pool, with the top ten loans representing 22%
of the pool.  The pool contains one loan with an investment-grade
credit estimate, which represents 8% of the pool.  Four loans,
representing 2% of the pool, have defeased and are collateralized
by U.S. Government securities.

Fifty-six loans, representing 21% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Five loans have been liquidated from the pool since last review,
resulting in an aggregate $8.8 million loss (45% loss severity on
average).  Currently, 16 loans, representing 6% of the pool, are
in special servicing.  The largest specially serviced loan is the
Village at Meyerland Loan ($21.7 million -- 1% of the pool), which
is secured by a 714-unit, multi-family property located in
Houston, Texas.  The loan was transferred to special servicing in
November 2009 for imminent monetary default and is currently 90+
days delinquent.  The remaining 15 specially serviced loans are
secured by a mix of property types.  The master servicer has
recognized an aggregate $48.9 million appraisal reduction for the
specially serviced loans.  Moody's has estimated an aggregate loss
of $64.0 million (50% expected loss on average) for the specially
serviced loans.

Moody's has also assumed a high default probability for 25 poorly
performing loans representing 10% of the pool.  Moody's has
estimated a $48.4 million loss (22% expected loss based on a 51%
default probability) from the troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 96% and 87% of the pool, respectively.
Moody's weighted average LTV for the conduit component, excluding
specially serviced and troubled loans, is 102% compared to 109% at
Moody's prior review.  Moody's net cash flow reflects a weighted
average haircut of 12.0% to the most recently available net
operating income.  Moody's value reflects a weighted average
capitalization rate of 8.9%.

Moody's actual and stressed DSCRs for the conduit component,
excluding specially serviced and troubled loans, are 1.31X and
0.97X, respectively, compared to 1.31X and 0.94X 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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 45 compared to 53 at Moody's prior review.

The loan with the credit estimate is the One Madison Avenue Loan
($121.0 million -- 5%), which is secured by the borrower's
interest in a 1.2 million square foot office building located in
the East Midtown South submarket of Manhattan.  The property is
also encumbered by a subordinate $50.0 million B-Note.  The loan
fully amortizes on a 132-month schedule and matures in May 2016.
Credit Suisse (USA) Inc. (senior unsecured rating of Aa1, negative
outlook) is the anchor tenant, leasing approximately 95% of the
net rentable area through December 31, 2020, with three successive
five-year renewal options.  As of June 2010, the property was 98%
leased, essentially the same as at last review.  Moody's current
underlying rating and stressed DSCR are Aaa and 3.69X,
respectively, essentially the same as at last review.

The top three performing conduit loans represent 18% of the pool.
The largest conduit loan is the 450 Park Avenue Loan
($175.0 million -- 7%), which is secured by a 313,135 square foot
office building located on 57th Street and Park Avenue in midtown
Manhattan.  The loan is interest only for its entire term.  As of
June 2010, the property was 88% leased compared to 71% at last
review.  The largest tenant is Harbinger Capital (8% of the NRA;
lease expiration in August 2019).  Performance has improved since
last review due higher revenues driven by an increase in
occupancy.  However, the loan is on the master servicer's
watchlist due to low DSCR.  Moody's LTV and stressed DSCR are 119%
and 0.77X, respectively, compared to 153% and 0.60X at last
review.

The second largest conduit loan is The Fashion Place Mall Loan
($140.8 million -- 6.3% of the pool), which is secured by a
890,000 square foot super regional mall in Murray, Utah.  The loan
was transferred to special servicing in April 2009 when General
Growth Properties, the borrower, filed for bankruptcy.  The
maturity date of the loan was extended and the loan was returned
to the master servicer in March 2010.  As of March 2010, the mall
was 92% leased compared to 96% at last review.  The mall is
anchored by Nordstrom, Dillard's, Sears and Macy's.  Moody's LTV
and stressed DSCR for this loan is 92% and 1.03X, respectively,
compared to 97% and 0.94X at last review.

The third largest conduit loan is the HGA Alliance - Portfolio
Loan ($78.9 million -- 3%), which is secured by four multifamily
properties containing 1,030 units.  The properties are located in
Florida (3) and Nevada (1).  The loan is interest only for its
entire term.  Performance has declined due to softening market
conditions and increased expenses.  Moody's considers this loan to
have a high probability of default and has identified it as a
troubled loan.  Moody's LTV and stressed DSCR are 164% and 0.56X,
respectively, compared to 158% and 0.55X at last review.


CSMC SERIES: Moody's Assigns Ratings on Various Certificates
------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to
Certificates issued by CSMC Series 2010-UD1.  The Certificates are
collateralized by a pool of CMBS certificates originated by
various issuers.

Issuer: CSMC Series 2010-UD1

  -- US$197,847,000 Cl. A Certificate, Assigned Aaa (sf)
  -- US$158,262,000 Cl. A-A Certificate*, Assigned Aaa (sf)
  -- US$39,585,000 Cl. A-B Certificate*, Assigned Aa1 (sf)
  -- US$78,042,250 Cl. B Certificate, Assigned Baa3 (sf)
  -- US$39,573,000 Cl. B-A Certificate*, Assigned A2 (sf)
  -- US$38,469,250 Cl. B-B Certificate*, Assigned Ba1 (sf)

*exchangeable certificates

                        Ratings Rationale

The resecuritization transaction is comprised of 8 classes of
super-senior commercial mortgage backed securities certificates
from 7 separate transactions (100% of the pool balance).  The CMBS
collateral are from pools securitized in 2007 (85%) and 2008
(15%).  The five largest CMBS exposures are CWCI 2007-C3 (30.2%),
CSMC 2007-C3 (27.0%), CMLT 2008-LS1 (10.5%), CSMC 2007-C4 (9.9%)
and MSC 2007-IQ14 (9.9%).

Class A-A and Class A-B are exchangeable REMIC certificates that
can be exchanged for Class A exchangeable certificates and vice-
versa.  Class B-A and Class B-B are exchangeable REMIC
certificates that can be exchanged for Class B exchangeable
certificates and vice-versa.

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.  These parameters are typically modeled as actual
parameters for static deals and as covenants for managed deals.

Moody's uses a weighted average rating factor as an overall
indicator of the credit quality of a CRE CDO transaction.  Based
on Moody's analysis, the current WARF is 22 with the rating
distribution: Aaa-Aa3 (96% of the pool balance) and A1-A3 (4% of
the pool balance).  Moody's reviewed the ratings or performed
credit estimates on all the collateral supporting the
Certificates.

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled a WAL of 6.5
years.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool.  Moody's modeled a fixed WARR
of 75%.

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 71.2%.

Moody's review incorporated CDOROM(R) v2.6, one of Moody's CDO
rating models, which was released on May 27, 2010.

The cash flow model, CDOEdge(R) v3.2, was used to analyze the cash
flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of key parameters may have had
rating implications on certain classes of rated notes.  However,
in many instances, a change in assumptions of any one key
parameter may be offset by a change in one or more of the other
key parameters.  Rated notes are particularly sensitive to changes
in recovery rate assumptions.  Holding all other key parameters
static, changing the recovery rate assumption down from 75% to 60%
or up to 90% would result in average rating movement on the rated
tranches of 0 to 2 notches downward and 0 to 3 notches upward,
respectively.

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 stressed macroeconomic environment and
continuing weakness in the commercial real estate and lending
markets.  Moody's currently views the commercial real estate
market as stressed with further performance declines expected in a
majority of property sectors.  The availability of debt capital is
improving with terms returning towards market norms.  Job growth
and housing price stability will be necessary precursors to
commercial real estate recovery.  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's largest
economies, returning to trend growth rate with elevated fiscal
deficits and persistent unemployment levels.

These ratings are based upon the quality of the underlying
collateral and the legal structure.  Moody's ratings address only
the credit risks associated with the transaction.  Other non-
credit risks, such as those associated with the timing of
principal prepayments have not been addressed and may have a
significant effect on yield to investors.

The V Score for this transaction is Medium, slightly lower than
the Medium/High V Score assigned for U.S. CRE Derivatives.  The V
Score indicates a "Medium" uncertainty about critical assumptions.

Moody's V Scores provide a relative assessment of the quality of
available credit information and the potential variability around
the various inputs to a rating determination.  The V Score ranks
transactions by the potential for significant rating changes owing
to uncertainty around the assumptions due to data quality,
historical performance, the level of disclosure, transaction
complexity, the modeling and the transaction governance that
underlie the ratings.  V Scores apply to the entire transaction
(rather than individual tranches).

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments in this transaction.


DEUTSCHE MORTGAGE: Moody's Downgrades Rating on Class 3-A-1 Certs.
------------------------------------------------------------------
Moody's Investors Service has downgraded the rating of class 3-A-1
issued by Deutsche Mortgage Securities, Inc. Re-REMIC Trust
Certificates, Series 2007-RS8.

Issuer: Deutsche Mortgage Securities, Inc. Re-REMIC Trust
Certificates, Series 2007-RS8

  -- Cl. 3-A-1, Downgraded to Caa3 (sf); previously on Jan. 29,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

                        Ratings Rationale

The action is as a result of the bond not having sufficient credit
enhancement to maintain the current rating compared to the revised
loss expectation on the pool of mortgages backing the underlying
certificate.  The resecuritization is backed by Class II-2A-1 (as
the "Underlying Certificate") issued by Bear Stearns Alt-A Trust
2006-4.  The underlying certificate is backed primarily by first-
lien, Alt-A residential mortgage loans.

The Class 3-A-1 issued in the resecuritization transaction is a
senior class, supported by a subordinated bond Class 3-A-2, which
receives principal payments after Class 3-A-1 but absorbs losses
before Class 3-A-1.

Moody's ratings on certificates in a resecuritization are based
on:

   (i) The updated expected loss of the pool of loans backing the
       underlying certificate and the updated rating on the
       underlying certificate.  Moody's current loss expectation
       on the pool backing Bear Stearns Alt-A Trust 2006-4 is 46%
       expressed as a percentage of outstanding deal balance.  The
       current rating on the II-2A-1 bond is Ca.

  (ii) The credit enhancement available to the underlying
       certificate, and

(iii) The structure of the resecuritization transaction.

Moody's first updated its loss assumptions on the underlying pool
of mortgage loans (backing the underlying certificate) and then
arrived at an updated rating on the underlying certificate.  The
rating on the underlying certificate is based on expected
recoveries on the bonds under ninety-six different combinations 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.  For further
details regarding Moody's approach to estimating losses on Alt-A
pools, please refer to the methodology publication " Alt-A RMBS
Loss Projection Update: February 2010", available on Moodys.com.

In order to determine the ratings of the resecuritized bonds, the
loss on the underlying certificate was ascribed to the
resecuritized classes, 3-A-1 and 3-A-2, according to the structure
of the resecuritized transaction.  The losses on the resecuritized
certificates are allocated "bottom up" with Class 3-A-2 taking
losses ahead of Class 3-A-1.  Principal payments to the
certificates are allocated sequentially, with Class 3-A-1 being
paid ahead of Class 3-A-2.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment remains at high
levels, and weakness persists in the housing market.  Moody's
notes an increasing potential for a double-dip recession, which
could cause a further 20% decline in home prices (versus its
baseline assumption of roughly 5% further decline).  Overall,
Moody's assumes a further 5% decline in home prices with
stabilization in early 2011, accompanied by continued stress in
national employment levels through that timeframe.

As part of the sensitivity analysis, Moody's stressed the updated
expected loss of the pool of loans backing the underlying
certificate by an additional 10% and found that the implied rating
on the resecuritization bond changed from Caa3 to Ca.

Moody's Investors Service received and took into account a third
party due diligence report on the underlying assets or financial
instruments in this transaction and the due diligence report had a
neutral impact on the rating.


EDUCATION LOANS: Fitch Affirms CCCsf Rating on Class K Sr. Loan
---------------------------------------------------------------
Fitch Ratings has affirmed the senior student loan notes and
downgraded the subordinate notes issued by Education Loans
Incorporated 1998 Trust Student Loan Asset-Backed Callable Notes,
Series 1998-1, issued under the 1998 master trust indenture, dated
Feb. 1, 1998.  The Rating Outlook is Stable for the senior notes.

The transaction's most significant risk factor is the interest
rate risk tied to the fixed-rate notes.  Given the current low
interest rate environment, in addition to having a high cost
structure from the spreads on the auction-rate securities, the
transaction is under pressure, producing negative excess spread.

The rating on the subordinate note is downgraded to 'CCCsf',
reflecting the real possibility of default given the low pool
factor and less than 100% parity.

The senior notes are affirmed based on the level of credit
enhancement that is exhibiting a stable trend.  However, the
ratings may come under pressure for downgrades if the enhancement
level begins exhibiting a downward trend.  This is possible if the
payment rate declines and the effect of de-levering is outweighed
by the impact from the negative excess spread.

Fitch has taken these rating actions:

Education Loans Incorporated, Student Loan Asset-Backed Callable
Notes, Series 1998-1, issued under the 1998 master trust indenture

  -- Class D affirmed at 'AAAsf/LS1'; Outlook Stable;
  -- Class F affirmed at 'AAAsf/LS1'; Outlook Stable;
  -- Class H affirmed at 'AAAsf/LS1'; Outlook Stable;
  -- Class K downgraded to 'CCCsf' from 'Asf/LS3'.


FAIRFAX COUNTY: S&P Corrects Rating to Revenue Bonds to 'BB+'
-------------------------------------------------------------
Standard & Poor's Ratings Services corrected its rating on Fairfax
County Redevelopment and Housing Authority, Va.'s (FHA-insured
mortgage - Island Walk Project) multifamily housing revenue bonds
series 2004 to 'BB+' from 'B'.

On Oct. 8, 2010, S&P lowered the rating on the series 2004 bonds
to 'B' from 'AAA' due to an error.


GS MORTGAGE: S&P Downgrades Ratings on Nine 2007-GKK1 Securities
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on nine
classes of commercial mortgage-backed securities pass-through
certificates from GS Mortgage Securities Trust 2007-GKK1, a U.S.
resecuritized real estate mortgage investment conduit transaction.
At the same time, S&P affirmed its ratings on three classes from
the same transaction.

The downgrades and affirmations primarily reflect S&P's analysis
following interest shortfalls to the transaction.  S&P's analysis
also considered the potential for class A-1 to experience interest
shortfalls in the future.

The rating on class L was lowered to 'D (sf)' on Sept. 29, 2009,
to reflect interest shortfalls that S&P expected to continue for
the foreseeable future.

According to the Oct. 21, 2010 trustee report, remaining deferred
interest to the transaction totaled $3.6 million affecting class
A2 and the classes subordinate to it.  The interest shortfalls to
GSMST 2007-GKK1 resulted from interest shortfalls on 20 of the
underlying CMBS transactions primarily due to special servicing
fees and appraisal subordinate entitlement reductions.  S&P
lowered its ratings on classes D through K to 'D (sf)' due to
interest shortfalls since February 2010 that S&P expects will
continue for the foreseeable future.

According to the Oct. 21, 2010, trustee report, GSMST 2007-GKK1 is
collateralized by 73 CMBS classes ($629.8 million, 100%) from 46
distinct transactions issued between 1998 and 2007.  The rated
CMBS collateral has a weighted average rating of 'B (sf)' and a
rating range of 'A+ (sf)' to 'D (sf)'.  The weighted average
credit estimate of the unrated CMBS collateral is 'ccc+'.

Standard & Poor's analyzed the transaction and its underlying
collateral assets in accordance with its current criteria.  S&P's
analysis is consistent with the lowered and affirmed ratings.

                         Ratings Lowered

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

                                  Rating
                                  ------
           Class            To               From
           -----            --               ----
           A-1              B- (sf)          BB (sf)
           A-2              CCC- (sf)        CCC+ (sf)
           D                D (sf)           CCC- (sf)
           E                D (sf)           CCC- (sf)
           F                D (sf)           CCC- (sf)
           G                D (sf)           CCC- (sf)
           H                D (sf)           CCC- (sf)
           J                D (sf)           CCC- (sf)
           K                D (sf)           CCC- (sf)

                         Ratings Affirmed

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

                    Class            Rating
                    -----            ------
                    B                CCC- (sf)
                    C                CCC- (sf)
                    L                D (sf)


FRANKLIN CLO: Moody's Upgrades Ratings on Various Classes
---------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Franklin CLO VI, Ltd.:

  -- US$272,000,000 Class A Senior Secured Floating Rate Notes
     (current outstanding balance of $261,594,841) Due 2019,
     Upgraded to Aa2 (sf); previously on June 18, 2009 Downgraded
     to Aa3 (sf);

  -- US$38,000,000 Class B Senior Secured Floating Rate Notes
     Due 2019, Upgraded to Baa1 (sf); previously on June 18, 2009
     Downgraded to Baa2 (sf);

  -- US$18,000,000 Class C Senior Secured Deferrable Floating
     Rate Notes Due 2019, Upgraded to Ba2 (sf); previously on
     June 18, 2009 Downgraded to Ba3 (sf);

  -- US$15,000,000 Class D Senior Secured Deferrable Floating
     Rate Notes Due 2019, Upgraded to B3 (sf); previously on
     June 18, 2009 Downgraded to Caa3 (sf);

  -- US$11,500,000 Class E Senior Secured Deferrable Floating
     Rate Notes (current outstanding balance of $11,299,499) Due
     2019, Upgraded to Caa3 (sf); previously on June 18, 2009
     Downgraded to C (sf).

                        Ratings Rationale

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

The overcollateralization ratios of the rated notes have increased
since the rating action in June 2009 and are currently all in
compliance.  The Class A/B, Class C, Class D and Class E
overcollateralization ratios are reported at 117.75%, 111.08%,
106.07%, and 102.59%, respectively, versus May 2009 levels of
110.89%, 104.75%, 100.09%, and 96.77%, respectively.  Moody's also
notes that the Class D and Class E Notes are no longer deferring
interest and that all previously deferred interest has been paid
in full.  In addition, the Class E Notes received about $200,000
in principal repayment on the last payment date in August due to
the failure of the Interest Reinvestment Test.  Class E Notes will
continue to benefit from principal repayments as long as the
Reinvestment Test is failing and the Class E Overcollateralization
Test is in compliance.

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,
as of the latest trustee report dated September 24, 2010, the
weighted average rating factor is currently 2542 compared to 2781
in the May 2009 report, and securities rated Caa1/CCC+ or lower
make up approximately 7.9% of the underlying portfolio versus
11.3% in May 2009.  Additionally, defaulted securities total about
$9 million of the underlying portfolio compared to $20 million in
May 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 its base case, Moody's analyzed the
underlying collateral pool to have a performing par and principal
proceeds of $349.1 million, defaulted par of $8.9 million,
weighted average default probability of 30.51% (implying a WARF of
3878), a weighted average recovery rate upon default of 44.58%,
and a diversity score of 52.  These default and recovery
properties of the collateral pool are incorporated in cash flow
model analysis where they are subject to stresses as a function of
the target rating of each CLO liability being reviewed.  The
default probability is derived from the credit quality of the
collateral pool and Moody's expectation of the remaining life of
the collateral pool.  The average recovery rate to be realized on
future defaults is based primarily on the seniority of the assets
in the collateral pool.  In each case, historical and market
performance trends, and collateral manager latitude for trading
the collateral are also factors.

Franklin CLO VI, Ltd., issued in July 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis described above, Moody's
also performed a number of sensitivity analyses to test the impact
on all rated notes, including these:

1.  Various default probabilities to capture potential defaults in
    the underlying portfolio.

2.  A range of recovery rate assumptions for all assets to capture
    variability in recovery rates.

A summary of the impact of different default probabilities
(expressed in terms of WARF levels) on all rated notes (shown in
terms of the number of notches' difference versus the current
model output, where a positive difference corresponds to lower
expected losses), assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (3102)

  -- Class A: +2
  -- Class B: +2
  -- Class C: +2
  -- Class D: +2
  -- Class E: +3

Moody's Adjusted WARF + 20% (4654)

  -- Class A: -2
  -- Class B: -2
  -- Class C: -2
  -- Class D: -4
  -- Class E: -1

A summary of the impact of different recovery rate levels on all
rated notes (shown in terms of the number of notches' difference
versus the current model output, where a positive difference
corresponds to lower expected losses), assuming that all other
factors are held equal:

Moody's Adjusted WARR + 2% (46.58%)

  -- Class A: 0
  -- Class B: 0
  -- Class C: 0
  -- Class D: 0
  -- Class E: 0

Moody's Adjusted WARR - 2% (42.58%)

  -- Class A: -1
  -- Class B: -1
  -- Class C: -1
  -- Class D: -1
  -- Class E: -1

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the managers'
investment strategies and behavior, 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are described
below:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deals'
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus selling defaulted
   assets create additional uncertainties.  Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings.  Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels.  Moody's analyzed the impact of assuming lower
   of reported and covenanted values for weighted average rating
   factor, weighted average spread, weighted average coupon, and
   diversity score.  Additionally, however, in light of the large
   positive difference between the actual and covenant levels for
   the weighted average spread test, Moody's base case analysis
   incorporates the impact of assuming the midpoint of the actual
   and covenanted values for the weighted average spread test.


FREMONT HOME: Moody's Assigns 'Ba2' Rating to Certificate Swap
--------------------------------------------------------------
Moody's Investors Service has assigned a Ba2 (sf) rating on the
Certificate Swap to the Fremont Home Loan Trust Series 2006-D
transaction.  Moody's rating addresses the credit risk posed to
the swap counterparty.  This rating only addresses the risk
attributable to the ability of the trust to continue to honor its
obligations under the swap.  The rating does not address market
risk that may be experienced by the party facing the trust under
the swap contract.

Issuer:

  -- Fremont Home Loan Trust Series 2006-D (Reference Number
     N525157N) Interest Rate Swap, Assigned Ba2 (sf)

                        Ratings Rationale

The rating takes into account the rating of the swap counterparty,
the transaction's legal structure and the characteristics of the
collateral mortgage pool of the respective trust.  Because there
is relatively limited historical performance data for the types of
instruments, this credit rating may have a greater potential
rating volatility than would ratings for transactions supported by
more historical performance data.

Moody's rating approach for this counterparty instrument rating
rests on three propositions:

* The CIRs are based on an analysis of the payment promise made by
  the trust, the position of the instrument in the payment
  waterfall, the credit quality of the rated payment flows, the
  security arrangements governing the trust's relationship with
  the counterparty, the support mechanisms available to the
  counterparty, the termination date of the swap and other
  structural features of the transaction in question.  In this
  regard, the rating process is similar to that for all other
  ratings assigned by Moody's.

* The credit quality and ratings assigned to counterparty
  instrument obligations of the trust may differ from those of its
  payment obligations to bondholders.  As a result, ratings
  assigned to bonds issued by the trust may diverge from the CIR
  and therefore the bond ratings may offer only a limited guidance
  on the CIR.

* Although counterparty instrument ratings address payments to
  rather than from the counterparty, in certain circumstances the
  credit strength of the counterparty itself may have a bearing on
  the CIR.  For example, where a counterparty's non-performance
  under a swap agreement leads to the trust having to make a
  termination payment to that counterparty, Moody's will take into
  account the likelihood of the counterparty's non-performance
  occurring and the position of termination payments in the cash
  flow waterfall .  Specifically, in the event that the swap
  counterparty causes a termination event, any termination payment
  owed to the swap counterparty may be paid at the bottom of the
  cash flow waterfall.  As a result, a default by the swap
  counterparty, which is currently rated Aa3, makes payment in
  full to the counterparty unlikely.

By way of background, the swap counterparty, Deutsche Bank AG, New
York Branch in this case, receives a fixed rate from, and pays
LIBOR to, the trust on a notional amount that is the lesser of the
aggregate class certificate balance and the amount set forth on
the schedule to the swap agreement.  Per the terms of the deal
documents, the swap counterparty for the swap receives payments,
prior to bondholders, and is thus in a senior position to all
bonds issued by the trust.  The termination date for the
Certificate Swap is 25th November, 2012.  To pay the swap
counterparty, the trust also has access to principal payments,
liquidation proceeds and interest collections.  This provision
strengthens the nature of senior payment right of the swap
counterparty.

The primary risks driving the rating on the swap is the risk that
the collateral pool amortizes at a rate that exceeds the
amortization rate of the swap notional and the risk of a
termination event triggered by a default of the swap counterparty.
As the losses are not allocated to the senior certificates, it is
likely, especially in high default scenarios, that the collateral
balance would amortize faster than the swap notional.  The
counterparty in the swap, Deutsche Bank AG, New York Branch, has a
Aa3 long term rating and a P-1 short term rating by Moody's.

Moody's methodology for rating swaps on US RMBS transactions
includes running collateral cashflows and considers the rating of
the swap counterparty.  Moody's stress the cashflows by increasing
defaults and prepayments to determine what level of collateral
stress would cause a shortfall in proceeds owed to the swap
counterparty.  The cashflows are modeled to reflect the waterfall
of the underlying transaction, which results in all swap payments
other than termination payments caused by a counterparty default
coming at the top of the waterfall.  Termination payments owed to
the swap counterparty resulting from a default of the swap
counterparty are paid at the bottom of the waterfall.  The swap in
this transaction did not default until collateral stresses
exceeded Ba3 collateral loss stresses combined with high
prepayment stresses.  The swap did not default until collateral
stresses exceeded Baa2 collateral loss stresses combined with
observed prepayment stresses.  Additional qualitative
considerations that were not modeled, such as the impact of a
decline in the weighted average interest rate of the collateral
pool, interest rate reduction modifications or more conservative
servicer advancing approaches, were also analyzed.  Consideration
of collateral cash flow and additional qualitative factors brought
the rating of the swap to Ba2.

Moody's projected remaining loss on the mortgage pool as a
percentage of the current balance is 63%.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments in this transaction.


GE COMMERCIAL: Fitch Downgrades Ratings on Three 2005-C3 Certs.
---------------------------------------------------------------
Fitch Ratings downgrades three classes of GE Commercial Mortgage
Corporation, series 2005-C3 commercial mortgage pass-through
certificates due to increased expected losses on specially
serviced loans.

The downgrades of classes M, N and O are the result of loss
expectations on the four loans in special servicing.  The
remaining classes have been affirmed.  Although loss expectations
on the entire pool have increased to 5.3% from 4.2% at the last
Fitch rating action, five of the 15 largest loans, including the
largest in the pool, paid off at or near their 2010 maturity
dates.  The increased credit enhancement has provided additional
loss protection resulting in affirmations of the remaining
classes.

As of the October 2010 distribution date, the pool's aggregate
principal balance has paid down 26% to $1.56 billion from
$2.1 billion at issuance.  Two loans (1.5%) have defeased.  As of
October 2010, cumulative interest shortfalls affect classes P and
Q which are not rated by Fitch.

Fitch designated 37 Loans of Concern (33%) within the pool, four
of which (5.6%) are specially serviced.  The largest specially
serviced loan (4.3%) is One Main Place, which is secured by a
1 million square foot office building located in downtown Dallas,
TX.  The loan transferred to special servicing when the borrower
requested a loan modification after a major tenant vacated in
October 2009, bringing the occupancy to 72%.  The borrower and
special servicer continue to negotiate a loan modification.  An
appraisal reduction based on an updated valuation has been
performed.

The second largest specially serviced loan (0.8%) is the 12000
Biscayne Office Building, which is secured by a 150,924 sf office
building located in Miami, FL.  The loan transferred to special
servicing after becoming 60 days delinquent.  As of year end 2009,
the servicer reported debt service coverage ratio was 0.72 times.
Per the special servicer, occupancy is 54%.  At issuance, the DSCR
and occupancy were 1.20x and 88.2%.

The largest Fitch Loan of Concern, which is not in special
servicing, is the Garden City Plaza (5.8%) which is secured by
four adjacent, five story office buildings totaling 583,017 sf
located in Garden City, NY.  The servicer reported year end 2009
DSCR and occupancy were 1.10x and 87% compared to the DSCR and
occupancy of 1.20x and 97.4% at issuance.  The subject's
performance has declined due to declines in occupancy and rental
rates.

Fitch stressed the value of the non-defeased loans by generally
applying a 5% haircut to 2009 fiscal year end net operating income
(NOI) and applying an adjusted market cap rate between 7.5% 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 that
attained a DSCR of 1.25x or higher were assumed to pay off at
maturity.  Of the non-defeased or non-specially serviced loans, 66
loans (74%) were assumed not to be able to refinance, of which
Fitch modeled losses for 37 loans (33%) where Fitch's derived
value was less than the outstanding debt.

Fitch has downgraded and assigned recovery ratings to these
classes:

  -- $10.6 million class M to 'CCCsf/RR1' from 'B-/LS5';
  -- $2.6 million class N to 'CCCsf/RR2' from 'B-/LS5';
  -- $7.9 million class O to 'CCsf/RR3' from 'B-/LS5'.

Fitch affirms and revises the Outlooks to Stable from Negative to
these classes:

  -- $13.2 million class B at 'AAsf/LS5'; Outlook Stable;
  -- $29.1 million class C at 'Asf/LS5'; Outlook Stable;
  -- $21.2 million class D at 'BBBsf/LS5'; Outlook Stable;
  -- $34.4 million class E at 'BBB-sf/LS5'; Outlook Stable;
  -- $18.5 million class F at 'BBsf/LS5'; Outlook Stable.

Fitch affirms these classes:

  -- $145.4 billion class A-4 at 'AAAsf/LS1'; Outlook Stable;
  -- $118.2 million class A-5 at 'AAAsf/LS1'; Outlook Stable;
  -- $75 million class A-6 at 'AAAsf/LS1'; Outlook Stable;
  -- $74.5 million class A-AB at 'AAAsf/LS1'; Outlook Stable;
  -- $386.7 million class A-7A at 'AAAsf/LS1'; Outlook Stable;
  -- $55.2 million class A-7B at 'AAAsf/LS1'; Outlook Stable;
  -- $435.8 million class A-1A at 'AAAf/LS1'; Outlook Stable;
  -- $161.4 million class A-J at 'AAsf/LS3'; Outlook Stable;
  -- $23.8 million class G at 'BBsf/LS5'; Outlook Negative;
  -- $21.2 million class H at 'Bsf/LS5'; Outlook Negative;
  -- $31.7 million class J at 'B-sf/LS5; Outlook Negative;
  -- $7.9 million class K at 'B-sf/LS5'; Outlook Negative;
  -- $7.9 million class L at 'B-sf/LS5'; Outlook Negative.

The $7.9 million class P and $23.8 million class Q are not rated
by Fitch.  Classes A-1, A-2, A-3FX and A-3FL have paid in full.
Fitch withdraws the ratings on the interest only classes X-C and
X-P.


GMAC COMMERCIAL: Moody's Raises Rating on 2000-C1 Certificates
--------------------------------------------------------------
Moody's Investors Service upgraded the rating of one class,
downgraded one class and affirmed three classes of GMAC Commercial
Mortgage Securities, Inc., Series 2000-C1 Mortgage Pass-Through
Certificates:

  -- Cl. X, Affirmed at Aaa (sf); previously on March 16, 2000
     Assigned Aaa (sf)

  -- Cl. H, Upgraded to Ba1 (sf); previously on Nov. 2, 2004
     Downgraded to B1 (sf)

  -- Cl. J, Affirmed at B2 (sf); previously on Nov. 2, 2004
     Downgraded to B2 (sf)

  -- Cl. K, Downgraded to C (sf); previously on June 1, 2006
     Downgraded to Caa1 (sf)

  -- Cl. L, Affirmed at C (sf); previously on June 1, 2006
     Downgraded to C (sf)

                        Ratings Rationale

The upgrade is due to the significant increase in subordination
due to loan payoffs and amortization and the pool's high exposure
to defeased loans, which represent 15% of the current pool
balance.  The pool has paid down 96% since Moody's prior review.

The downgrade is due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans, a decline in loan level diversity, as
measured by the Herfindahl Index and concerns about loans
approaching maturity in an adverse environment.  Seven loans,
representing 83% of the pool, either have matured or mature within
the next six months.  All of these loans are in special servicing.

Moody's is affirming Classes J, L and X because current
subordination levels for these classes are sufficient for the
current ratings.

Moody's rating action reflects a cumulative base expected loss of
42.6% of the current balance.  At last review, Moody's cumulative
base expected loss was 0.9%.  Moody's stressed scenario loss is
50.9% of the current balance.

Due to paydowns and amortization, all of the investment grade
classes of this transaction have paid off.  If future performance
materially declines, the expected level of credit enhancement for
the remaining outstanding classes may be insufficient for their
current ratings.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions as well as the excel-based CMBS Large Loan Model v.
8.0 which is used for Large Loan transactions.  Conduit model
results at the Aa2 level are driven by property type, Moody's
actual and stressed DSCR, and Moody's property quality grade
(which reflects the capitalization rate used by Moody's to
estimate Moody's value).  Conduit model results at the B2 level
are driven by a paydown analysis based on the individual loan
level Moody's LTV ratio.  Moody's Herfindahl score, a measure of
loan level diversity, is a primary determinant of pool level
diversity and has a greater impact on senior certificates.  Other
concentrations and correlations may be considered in Moody's
analysis.  Based on the model pooled credit enhancement levels at
Aa2 and B2, the remaining conduit classes are either interpolated
between these two data points or determined based on a multiple or
ratio of either of these two data points.  For fusion deals, the
credit enhancement for loans with investment-grade credit
estimates is melded with the conduit model credit enhancement into
an overall model result.  Fusion loan credit enhancement is based
on the underlying rating of the loan which corresponds to a range
of credit enhancement levels.  Actual fusion credit enhancement
levels are selected based on loan level diversity, pool leverage
and other concentrations and correlations within the pool.
Negative pooling, or adding credit enhancement at the underlying
rating level, is incorporated for loans with similar credit
estimates in the same transaction.

The pool has a Herf of 7, compared to 36 at last review.  In cases
where the Herf falls below 20, Moody's also employs the large
loan/single borrower methodology.  This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation.  The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios.  Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship.  These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated May 23, 2008.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

                        Deal Performance

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 96% to
$27.24 million from $879.8 million at securitization.  The
Certificates are collateralized by 11 mortgage loans ranging in
size from less than 2% to 18% of the pool, with the top eight non-
defeased loans representing 85% of the pool.  The pool only
contains one performing conduit loan.  The remaining loans are
either defeased (three loans representing 15% of the pool) or are
in special servicing (seven loans representing 83% of the pool).

Twenty five loans have been liquidated from the pool, resulting in
an aggregate realized loss of $22.9 million (16% loss severity on
average).  Due to realized losses, classes O through M have been
eliminated entirely and Class L has experienced a 31% principal
loss.  The seven specially serviced loans were transferred to
special servicing due to imminent maturity default.  The largest
specially serviced loan is the Brookscrossing Apartments Loan
($5.06 million -- 18.9% of the pool), which is secured by a 224
unit multifamily property located in Riverdale, Georgia.  The loan
was transferred to special servicing in July 2009 and became real
estate owned on July 6, 2010.  The servicer has recognized a
$1.1 million appraisal reduction on the loan.  The remaining six
specially serviced loans are secured by a mix of property types.
Moody's has estimated an aggregate $11.3 million loss (50%
expected loss on average) for the specially serviced loans.

Based on the most recent remittance statement, Class L has a
cumulative interest shortfalls totaling $323,907.  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.

Due to the high percentage of loans in special servicing, Moody's
analysis was largely based on a loss and recovery analysis for
specially serviced and troubled loans.  The performance of the
conduit component, which only represents 1.5% of the pool, is
stable and performing in-line with Moody's expectations.


GMAC COMMERCIAL: Moody's Takes Rating Actions on Various Classes
----------------------------------------------------------------
Moody's Investors Service upgraded the ratings of one class,
downgraded one class and affirmed four classes of GMAC Commercial
Mortgage Securities, Inc. Mortgage Pass-Through Certificates,
Series 1999-C3:

  -- Cl. X, Affirmed at Aaa (sf); previously on Sept. 13, 1999
     Definitive Rating Assigned Aaa (sf)

  -- Cl. G, Upgraded to A1 (sf); previously on March 8, 2007
     Upgraded to Baa3 (sf)

  -- Cl. H Affirmed at Ba2 (sf); previously on March 8, 2007
     Upgraded to Ba2 (sf)

  -- Cl. J, Affirmed at B3 (sf); previously on March 8, 2007
     Upgraded to B3 (sf)

  -- Cl. K, Downgraded to C (sf); previously on Nov. 22, 2005
     Downgraded to Caa3 (sf)

  -- Cl. L, Affirmed at C (sf); previously on March 8, 2007
     Downgraded to C (sf)

                        Ratings Rationale

The upgrade is due to the significant increase in subordination
due to loan payoffs and amortization and the pool's high exposure
to defeased loans, which represent 27% of the current pool
balance.  The pool has paid down 92% since Moody's prior review.

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans and concerns about loans approaching
maturity in an adverse environment.  Nine loans, representing 58%
of the pool, either have matured or mature within the next six
months.  All of these loans are in special servicing.

Moody's is affirming Classes H, J, L and X because current
subordination levels for these classes are sufficient for the
current ratings.

Moody's rating action reflects a cumulative base expected loss of
30.9% of the current balance.  At last review, Moody's cumulative
base expected loss was 1.0%.  Moody's stressed scenario loss is
32.4% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions as well as the excel-based CMBS Large Loan Model v.
8.0 which is used for Large Loan transactions.  Conduit model
results at the Aa2 level are driven by property type, Moody's
actual and stressed DSCR, and Moody's property quality grade
(which reflects the capitalization rate used by Moody's to
estimate Moody's value).  Conduit model results at the B2 level
are driven by a paydown analysis based on the individual loan
level Moody's LTV ratio.  Moody's Herfindahl score, a measure of
loan level diversity, is a primary determinant of pool level
diversity and has a greater impact on senior certificates.  Other
concentrations and correlations may be considered in Moody's
analysis.  Based on the model pooled credit enhancement levels at
Aa2 and B2, the remaining conduit classes are either interpolated
between these two data points or determined based on a multiple or
ratio of either of these two data points.  For fusion deals, the
credit enhancement for loans with investment-grade credit
estimates is melded with the conduit model credit enhancement into
an overall model result.  Fusion loan credit enhancement is based
on the underlying rating of the loan which corresponds to a range
of credit enhancement levels.  Actual fusion credit enhancement
levels are selected based on loan level diversity, pool leverage
and other concentrations and correlations within the pool.
Negative pooling, or adding credit enhancement at the underlying
rating level, is incorporated for loans with similar credit
estimates in the same transaction.

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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 9, compared to 39 at last review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology.  This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation.  The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios.  Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship.  These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated January 8, 2009.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

                         Deal Performance

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 95% to
$59.9 million from $1.15 billion at securitization.  The
Certificates are collateralized by 14 mortgage loans ranging in
size from 1% to 14% of the pool, with the top ten loans
representing 90% of the pool.  The pool only contains three
conduit loans.  The remaining loans are either defeased (two loans
representing 27% of the pool) or are in special servicing (nine
loans representing 58% of the pool).  One of the performing loans,
representing 4% of the pool, is on the master servicer's watchlist
due to low DSCR.

Twenty loans have been liquidated from the pool, resulting in an
aggregate realized loss of $19.7 million (10% loss severity on
average).  All of the loans in special servicing were transferred
to special due to imminent maturity default.  The largest
specially serviced loan is the Lakeside Place Office Building Loan
($6.6 million -- 11.0% of the pool), which is secured by a 84,000
square foot office building located in Cleveland, Ohio.  The loan
was transferred to special servicing in May 2009 and is currently
in the process of foreclosure.  The servicer has recognized a
$4.0 million appraisal reduction on the loan.  The remaining eight
specially serviced loans are secured by a mix of property types.
Moody's has estimated an aggregate $20.1 million loss (57%
expected loss on average) for the specially serviced loans.

Based on the most recent remittance statement, Classes J through
L have experienced cumulative interest shortfalls totaling
$2.0 million.  Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced loans.  Interest shortfalls are caused by
special servicing fees, including workout and liquidation fees,
appraisal subordinate entitlement reductions and extraordinary
trust expenses.

Moody's was provided with full year 2009 operating results for
100% of the pool's three performing conduit loans.  Moody's
weighted average LTV for these loans is 68% compared to 79% for
the conduit pool at Moody's prior review.  Moody's net cash flow
reflects a weighted average haircut of 14.8% to the most recently
available net operating income.  Moody's value reflects a weighted
average capitalization rate of 9.8%.

Moody's actual and stressed DSCRs for the performing conduit loans
are 1.34X and 1.64X, respectively, compared to 1.35X and 1.50X for
the pool 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.

Due to the high percentage of loans in special servicing, Moody's
analysis was largely based on a a loss and recovery analysis for
specially serviced loans.  The performance of the conduit
component, which only represents 15% of the pool, is stable and
performing in-line with Moody's expectations.


GRAND HORN: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B, C, and E notes issued by Grand Horn CLO Ltd., a
collateralized loan obligation transaction managed by Seix
Advisors.  At the same time, S&P removed its ratings on the class
A and B notes from CreditWatch with positive implications.  S&P
also affirmed its rating on the class D notes.

The raised ratings reflect improved credit enhancement available
to support the notes since S&P lowered its ratings on the class A,
C, D, and E notes in January 2010.  Since January 2010, the
transaction has paid down approximately $139.05 million to the
class A notes, including a $33.16 million payment on the Oct. 12
distribution, thereby increasing the overcollateralization
available to support the rated notes.

As of the Oct. 4, 2010, monthly report, which does not take into
account the Oct. 12 distribution, these O/C ratios were reported
by the trustee:

* The class A/B O/C ratio was 131.11%, compared with a reported
  ratio of 122.48% in January 2010;

* The class C O/C ratio was 119.57%, compared with a reported
  ratio of 114.43% in January 2010;

* The class D O/C ratio was 112.30%, compared with a reported
  ratio of 109.15% in January 2010;

* The class E O/C ratio was 106.23%, compared with a reported
  ratio of 104.62% in January 2010.

The reinvestment period was suspended in October 2009 due to
provisions in the transaction documents relating to downgrades of
certain classes.  As a result, all principal proceeds have been
used to pay down the class A notes.  S&P believes that certain
provisions in the transaction documents may permit the CLO to
resume trading and reinvestment activity after the class A note
rating has been raised to its original level of 'AAA (sf)'.
Reinstatement of the reinvestment period would likely give the
collateral manager the ability to use any available principal
proceeds to purchase additional collateral within the reinvestment
parameters set forth in the transaction documents.  The reinstated
reinvestment period could potentially run to the January 2014
payment date.  S&P has factored the potential resumption of the
reinvestment period and likely cessation of early amortization of
the notes into S&P's analysis of the transaction.

                  Rating And Creditwatch Actions

                       Grand Horn CLO Ltd.

                          Rating
                          ------
          Class       To            From
          -----       --            ----
          A           AAA (sf)      AA+ (sf)/Watch Pos
          B           AA+ (sf)      AA (sf)/Watch Pos
          C           AA- (sf)      A- (sf)
          E           BB (sf)       B+ (sf)

                         Rating Affirmed

                       Grand Horn CLO Ltd.

                      Class       Rating
                      -----       ------
                      D           BBB- (sf)

   Transaction Information
   -----------------------
Issuer:               Grand Horn CLO Ltd
Co-issuer:            Grand Horn CLO LLC
Collateral manager:   Seix Advisors
Underwriter:          Suntrust Robinson Humphrey
Trustee:              Citibank N.A.  New York, NY
Transaction type:     Cash Flow CLO


GREENFIELD REDEVELOPMENT: S&P Cuts Rating on Tax Bonds to 'BB+'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating and
underlying rating to 'BB+' from 'A-' on Greenfield Redevelopment
Agency, Calif.'s nonhousing tax allocation bonds.  The outlook is
stable.

"The rating action reflects S&P's view of the decline in the
agency's tax increment revenues, which management attributes to a
significant drop in assessed value in the agency's project area,"
said Standard & Poor's credit analyst Bryan Moore.  "As a result,
coverage of nonhousing bonds fell to below 1x maximum annual debt
service."

Project area assessed value in fiscals 2009, 2010, and 2011
declined by 8%, 23% and 12%, respectively, due to the recent
recession and a drop in housing prices, according to management.
(The incremental decline was 10%, 29%, and 17%, respectively.)
The total AV in fiscal 2011 is $321 million, which is down from
the high of fiscal 2008's $413 million.  Management projects that
AV will continue to fall in fiscal 2012, at which point it will
stabilize.  As a result of these AV declines, tax increment
available to pay debt service has fallen.  The debt service
coverage based on fiscal 2011 AV dropped to 0.94x maximum annual
debt service (annual debt service coverage was 1.03x).  Should AV
remain level next year, the annual debt service coverage would
drop to 0.998x.  Agency management stated that it would use cash
on hand in order to meet debt service requirements should the tax
increment revenue drop below 1x the annual debt service amount.
Although it is not specifically pledged to the bonds, this cash
provides the agency with flexibility, in S&P's view.

The tax base has become slightly more concentrated between fiscals
2007 and 2011, though S&P still considers it to be very diverse.
The 10 leading taxpayers currently account for 11.4% of total AV
and 16.9% of incremental AV, up from 8.5% and 11.5%, respectively,
in fiscal 2007.  Moreover, recent AV declines have resulted in a
higher volatility ratio, which is a measure of how sensitive tax
increment revenues are to overall swings in AV.  The base-to-total
AV volatility ratio is, in S&P's view, a moderate 0.32 in fiscal
2011, up from 0.26 in fiscal 2007.

Established on July 18, 2000, and amended on April 20, 2004,
Greenfield Redevelopment Agency encompasses 893 acres, or about
82% of the City of Greenfield's land area.  Greenfield (population
15,000) is in the Salinas Valley, about 37 miles south of the City
of Salinas and 95 miles south of the City of San Jose.


GREENWICH CAPITAL: S&P Downgrades Ratings on Six 2007-RR2 Certs.
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes of commercial mortgage-backed securities pass-through
certificates from Greenwich Capital Commercial Mortgage Trust
2007-RR2, a U.S. resecuritized real estate mortgage investment
conduit transaction.  At the same time, S&P affirmed its 'D (sf)'
ratings on 13 classes from the transaction.

The downgrades and affirmations primarily reflect S&P's analysis
of the transaction following interest shortfalls to the
transaction.  S&P's analysis also considered the potential for
class A-1FX and A-1FL to experience interest shortfalls in the
future.

S&P downgraded classes D through Q to 'D (sf)' on March 26, 2010,
to reflect interest shortfalls that S&P expected to continue for
the foreseeable future.

According to the Oct. 21, 2010, trustee report, cumulative
interest shortfalls to the transaction totaled $6.5 million
affecting class A2 and the classes subordinate to it.  The
interest shortfalls to GCCMT 2007-RR2 resulted from interest
shortfalls on 17 of the underlying CMBS transactions primarily due
to special servicing fees and appraisal subordinate entitlement
reductions.  S&P lowered its ratings on classes A3, B, and C to 'D
(sf)' due to interest shortfalls since December 2009 that S&P
expects will continue for the foreseeable future.

According to the Oct. 21, 2010 trustee report, GCCMT 2007-RR2 is
collateralized by 63 CMBS classes ($528.7 million, 100%) from 29
distinct transactions issued between 2005 and 2007.  The rated
CMBS collateral has a weighted average rating of 'CCC+ (sf)' and a
rating range of 'B+ (sf)' to 'D (sf)'.  The weighted average
credit estimate of the unrated CMBS collateral is 'ccc+'.

Standard & Poor's analyzed the transaction and its underlying
collateral assets according to its current criteria.  S&P's
analysis is consistent with the lowered and affirmed ratings.

                         Ratings Lowered

       Greenwich Capital Commercial Mortgage Trust 2007-RR2
Commercial mortgage-backed securities pass-through certificates

                                  Rating
                                  ------
           Class            To               From
           -----            --               ----
           A-1FX            CCC- (sf)        BB- (sf)
           A-1FL            CCC- (sf)        BB- (sf)
           A2               CCC- (sf)        CCC+ (sf)
           A3               D (sf)           CCC- (sf)
           B                D (sf)           CCC- (sf)
           C                D (sf)           CCC- (sf)

                         Ratings Affirmed

       Greenwich Capital Commercial Mortgage Trust 2007-RR2
Commercial mortgage-backed securities pass-through certificates

                     Class            Rating
                     -----            ------
                     D                D (sf)
                     E                D (sf)
                     F                D (sf)
                     G                D (sf)
                     H                D (sf)
                     J                D (sf)
                     K                D (sf)
                     L                D (sf)
                     M                D (sf)
                     N                D (sf)
                     O                D (sf)
                     P                D (sf)
                     Q                D (sf)


GS MORTGAGE: Moody's Downgrades Ratings on Three 2004-C1 Certs.
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of three classes
and affirmed 13 classes of GS Mortgage Securities Corporation II,
Commercial Mortgage Pass-Through Certificates, Series 2004-C1:

  -- Cl. A-1A, Affirmed at Aaa (sf); previously on June 24, 2004
     Assigned Aaa (sf)

  -- Cl. A-2, Affirmed at Aaa (sf); previously on June 23, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X, Affirmed at Aaa (sf); previously on June 23, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. B, Affirmed at Aaa (sf); previously on May 22, 2008
     Upgraded to Aaa (sf)

  -- Cl. C, Affirmed at Aaa (sf); previously on May 22, 2008
     Upgraded to Aaa (sf)

  -- Cl. D, Affirmed at Aa3 (sf); previously on May 22, 2008
     Upgraded to Aa3 (sf)

  -- Cl. E, Affirmed at A2 (sf); previously on May 22, 2008
     Upgraded to A2 (sf)

  -- Cl. F, Affirmed at Baa2 (sf); previously on Jan. 6, 2010
     Downgraded to Baa2 (sf)

  -- Cl. G, Downgraded to B2 (sf); previously on Jan. 6, 2010
     Downgraded to Ba2 (sf)

  -- Cl. H, Downgraded to C (sf); previously on Jan. 6, 2010
     Downgraded to B3 (sf)

  -- Cl. J, Downgraded to C (sf); previously on Jan. 6, 2010
     Downgraded to Caa3 (sf)

  -- Cl. K, Affirmed at C (sf); previously on Jan. 6, 2010
     Downgraded to C (sf)

  -- Cl. L, Affirmed at C (sf); previously on Jan. 6, 2010
     Downgraded to C (sf)

  -- Cl. M, Affirmed at C (sf); previously on Jan. 6, 2010
     Downgraded to C (sf)

  -- Cl. N, Affirmed at C (sf); previously on Jan. 6, 2010
     Downgraded to C (sf)

  -- Cl. O, Affirmed at C (sf); previously on Jan. 6, 2010
     Downgraded to C (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from anticipated losses from specially serviced and
troubled loans and concerns about loans approaching maturity in an
adverse environment.  The entire pool matures within the next six
months.

The affirmations are due to key parameters, including Moody's loan
to value ratio, Moody's stressed DSCR and the Herfindahl Index,
remaining within acceptable ranges.  Based on Moody's current base
expected loss, the credit enhancement levels for the affirmed
classes are sufficient to maintain their current ratings.

Moody's rating action reflects a cumulative base expected loss of
23.7% of the current balance.  At last review, Moody's cumulative
base expected loss was 9.7%.  Moody's stressed scenario loss is
26.0% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions as well as the excel-based CMBS Large Loan Model v.
8.0 which is used for Large Loan transactions.  Conduit model
results at the Aa2 level are driven by property type, Moody's
actual and stressed DSCR, and Moody's property quality grade
(which reflects the capitalization rate used by Moody's to
estimate Moody's value).  Conduit model results at the B2 level
are driven by a paydown analysis based on the individual loan
level Moody's LTV ratio.  Moody's Herfindahl score , a measure of
loan level diversity, is a primary determinant of pool level
diversity and has a greater impact on senior certificates.  Other
concentrations and correlations may be considered in Moody's
analysis.  Based on the model pooled credit enhancement levels at
Aa2 and B2, the remaining conduit classes are either interpolated
between these two data points or determined based on a multiple or
ratio of either of these two data points.  For fusion deals, the
credit enhancement for loans with investment-grade credit
estimates is melded with the conduit model credit enhancement into
an overall model result.  Fusion loan credit enhancement is based
on the underlying rating of the loan which corresponds to a range
of credit enhancement levels.  Actual fusion credit enhancement
levels are selected based on loan level diversity, pool leverage
and other concentrations and correlations within the pool.
Negative pooling, or adding credit enhancement at the underlying
rating level, is incorporated for loans with similar credit
estimates in the same transaction.

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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 9, essentially the same as Moody's prior
review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology.  This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation.  The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios.  Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship.  These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated January 6, 2010.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

                         Deal Performance

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 83% to
$155.6 million from $892.3 million at securitization.  The
Certificates are collateralized by 17 mortgage loans ranging in
size from 1% to 18% of the pool, with the top ten loans
representing 78% of the pool.  The pool contains eight performing
conduit loans which represent 42% of the current pool balance.
Three loans, representing 15% of the pool, have defeased and are
collateralized with U.S. Government securities.  The remaining six
loans, representing 43% of the pool, have been transferred to
special servicing.

All of the performing loans 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 monthly reporting package.  Most of the loans are on the
watchlist because of near-term maturity.

Four loans have been liquidated from the pool, resulting in an
aggregate realized loss of $5.3 million (8% loss severity on
average).  Six loans, representing 43% of the pool, are currently
in special servicing.  The largest specially serviced loan is the
Hyatt Regency Dearborn Loan ($28.0 million -- 18.0% of the pool),
which is secured by a 772 key hotel located in Dearborn, Michigan.
The loan was transferred to special servicing in April 2009 and is
currently real estate owned.  The servicer has recognized a
$16.6 million appraisal reduction on the loan.  The remaining five
specially serviced loans are secured by a mix of property types.
Moody's has estimated an aggregate $36 million loss (53% expected
loss on average) for the specially serviced loans.

Based on the most recent remittance statement, Classes K through
NR have experienced cumulative interest shortfalls totaling $1.3
million.  Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced loans.  Interest shortfalls are caused by
special servicing fees, including workout and liquidation fees,
appraisal subordinate entitlement reductions and extraordinary
trust expenses.

Moody's was provided with full year 2009 operating results for
100% of the pool's eight performing loans.  Moody's weighted
average LTV for these loans is 74% compared to 84% for the conduit
pool at Moody's prior review.  Moody's net cash flow reflects a
weighted average haircut of 20.2% to the most recently available
net operating income.  Moody's value reflects a weighted average
capitalization rate of 9.4%.

Moody's actual and stressed DSCRs for the performing conduit loans
are 2.27X and 1.39X, respectively, compared to 1.92X and 1.24X 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.

The top three performing conduit loans represent 25% of the pool
balance.  The largest loan is the StoneRidge Plaza Loan
($21.3 million -- 13.7% of the pool), which is secured by a
217,000 square foot retail center located in Gahanna, Ohio.  The
center is anchored by Kroger's, which leases 36% of the net
rentable area through January 2022.  The property was 98% leased
as of June 2010, essentially the same as at last review.  The loan
is on the servicer's watchlist due to the borrower's failure to
pay an outstanding servicer advance and the loan's near-term
maturity.  The loan matures on January 1, 2011.  Moody's LTV and
stressed DSCR are 77% and 1.31X, respectively, compared to 78% and
1.29X at last review.

The second largest loan is the Mankato Heights Plaza Loan
($8.9 million -- 5.7% of the pool), which is secured by 129,000
square foot retail center located in Mankato, Minnesota.  The
property is 99% leased as of June 2010, essentially the same as at
last review.  Moody's is concerned about tenant rollover risk that
will occur in 2012.  The property is on the watchlist due to its
near-term on maturity on January 1, 2011.  Moody's LTV and
stressed DSCR are 61% and 1.64X, respectively, compared to 60% and
1.67X at last review.

The third largest loan is Village Ten Center Loan ($8.5 million --
5.5% of the pool), which is secured by a 208,000 square foot
retail center located in Coon Rapids, Minnesota.  The property was
98% leased as of June, 2010, essentially the same as at last
review.  The property is on the watchlist due to its near-term
maturity on January 1, 2011.  Moody's LTV and stressed DSCR are
81% and 1.24X, respectively, compared to 84% and 1.19X at last
review.


GS MORTGAGE: Moody's Downgrades Ratings on 11 2005-GG4 Certs.
-------------------------------------------------------------
Moody's Investors Service downgraded the ratings of 11 classes and
affirmed 14 classes of GS Mortgage Securities Corporation II,
Commercial Mortgage Pass-Through Certificates, Series 2005-GG4:

  -- Cl. A-DP, Affirmed at Aaa (sf); previously on July 15, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2, Affirmed at Aaa (sf); previously on July 15, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on July 15, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-ABA, Affirmed at Aaa (sf); previously on July 15, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-ABB, Affirmed at Aaa (sf); previously on July 15, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-P, Affirmed at Aaa (sf); previously on July 15, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-C, Affirmed at Aaa (sf); previously on July 15, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4A, Affirmed at Aaa (sf); previously on July 15, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Downgraded to Aa1 (sf); previously on Sept. 22, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-4B, Downgraded to Aa1 (sf); previously on Sept. 22,
     2010 Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-1A, Downgraded to Aa1 (sf); previously on Sept. 22,
     2010 Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-J, Downgraded to Baa1 (sf); previously on Sept. 22,
     2010 A1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Downgraded to Baa3 (sf); previously on Sept. 22, 2010
     A2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Downgraded to B1 (sf); previously on Sept. 22, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to Caa2 (sf); previously on Sept. 22, 2010
     Ba2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to Ca (sf); previously on Sept. 22, 2010 B2
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to C (sf); previously on Sept. 22, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to C (sf); previously on Sept. 22, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. H, Downgraded to C (sf); previously on Sept. 22, 2010 Ca
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. J, Affirmed at C (sf); previously on Nov. 19, 2009
     Downgraded to C (sf)

  -- Cl. K, Affirmed at C (sf); previously on Nov. 19, 2009
     Downgraded to C (sf)

  -- Cl. L, Affirmed at C (sf); previously on Nov. 19, 2009
     Downgraded to C (sf)

  -- Cl. M, Affirmed at C (sf); previously on Nov. 19, 2009
     Downgraded to C (sf)

  -- Cl. N, Affirmed at C (sf); previously on Nov. 19, 2009
     Downgraded to C (sf)

  -- Cl. O, Affirmed at C (sf); previously on Nov. 19, 2009
     Downgraded to C (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from anticipated losses from specially serviced and
troubled loans.  The affirmations are due to key parameters,
including Moody's loan to value ratio, Moody's stressed debt
service coverage ratio and the Herfindahl Index, remaining within
acceptable ranges.  Based on Moody's current base expected loss,
the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings.

On September 22, 2010, Moody's placed 11 classes on review for
possible downgrade.  This action concludes Moody's review.

Moody's rating action reflects a cumulative base expected loss of
10.2% of the current balance.  At last review, Moody's cumulative
base expected loss was 7.0%.  Moody's stressed scenario loss is
19.7% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the underlying rating of the
loan which corresponds to a range of credit enhancement levels.
Actual fusion credit enhancement levels are selected based on loan
level diversity, pool leverage and other concentrations and
correlations within the pool.  Negative pooling, or adding credit
enhancement at the underlying rating level, is incorporated for
loans with similar credit estimates in the same transaction.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated November 19, 2009.  Please
see the ratings tab on the issuer / entity page on moodys.com for
the last rating action and the ratings history.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

As of the October 13, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 12% to $3.54
billion from $4.00 billion at securitization.  The Certificates
are collateralized by 176 mortgage loans ranging in size from less
than 1% to 6% of the pool, with the top ten loans representing 32%
of the pool.  Seven loans, representing 7% of the pool, have
defeased and are collateralized with U.S. Government securities.
The pool contains two loans, representing 6% of the pool with
investment grade credit estimates.

Forty-five 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 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 since
securitization, resulting in an aggregate $765,996 loss (1.0% loss
severity on average).  Currently 24 loans, representing 18% of the
pool, are in special servicing.  The master servicer has
recognized an aggregate $140.2 million appraisal reduction for 21
of the specially serviced loans.  Moody's has estimated an
aggregate $227.9 million loss (35% expected loss on average) for
the specially serviced loans.

Moody's has assumed a high default probability for 15 poorly
performing loans representing 4.6% of the pool and has estimated a
$49.2 million loss (30% expected loss based on a 60% probability
default) from these troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 97% and 60% of the non-defeased performing
pool, respectively.  Excluding specially serviced and troubled
loans, Moody's weighted average LTV is 101% compared to 106% at
last review.  Moody's net cash flow reflects a weighted average
haircut of 13% to the most recently available net operating
income.  Moody's value reflects a weighted average capitalization
rate of 9.1%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.42X and 1.01X, respectively, compared to
1.40X and 0.99X 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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 50 compared to 57 at Moody's prior review.

The largest loan with a credit estimate is the The Streets at
Southpoint Loan ($155.5 million -- 4.4%), which is secured by a
1.3 million square foot regional mall located in Durham, North
Carolina.  The center is anchored by Macy's, Nordstrom, Hudson
Belk, J.C. Penney and Sears.  The loan sponsor is General Growth
Properties, Inc., which filed for Chapter 11 bankruptcy protection
on April 16, 2009.  This property was not included in the
bankruptcy filing.  The in-line mall stores were 95% leased as of
June 2010, compared to 99% at last review.  Despite a slight
decline in occupancy, property performance is inline with 2009
performance.  Moody's current credit estimate and stressed DSCR
are Baa3 and 1.37X, respectively, compared to Baa3 and 1.35X last
review.

The second largest loan with a credit estimate is the 200 Madison
Avenue Loan ($45.5 million -- 1.3%), which is secured by a 666,200
square foot office building located in the Midtown South submarket
of New York City.  The property was nearly 100% leased as of June
2010, essentially the same as at last review.  The largest tenant
is the Phillips-Van Heusen Corporation (Moody's senior unsecured
rating B2, stable outlook), which occupies 30% of the premises
through October 2023.  Performance remains similar to last review.
The loan is interest-only for its entire term.  Moody's current
underlying rating and stressed DSCR are Aa3 and 1.59X,
respectively, the same as at last review.

The top three performing conduit loans represent 14% of the pool
balance.  The largest loan is the Wells Fargo Center Loan
($200.0 million -- 5.7%), which is secured by a 1.2 million square
foot Class A office building located in downtown Denver, Colorado.
The property was 100% leased as of June 2010, the same as at last
review.  The largest tenant is Wells Fargo Bank, N.A.  (Moody's
senior unsecured bank note program rating Aa2, on review for
possible upgrade), which occupies 30% of the premises through
December 2020.  The loan sponsor is Maguire Properties.  Despite
an in increase in real estate taxes, the property is stable with
little upcoming lease rollover.  The loan is interest-only for its
entire ten-year term maturing in April 2015.  Moody's LTV and
stressed DSCR are 124% and 0.76X, respectively, compared to 134%
and 0.71X at last review.

The second largest loan is the Mall at Wellington Green Loan
($200.0 million -- 5.7%), which is secured by the borrower's
interest in a 1.3 million square foot regional mall located in
West Palm Beach, Florida.  The loan sponsor is the Taubman Realty
Group.  The mall is anchored by Dillard's, Macy's, J.C. Penney and
Nordstrom.  The center was 91% leased as of July 2010 compared to
97% last review.  Property performance declined in 2009 and first
half 2010 due to lower rental revenues from decreased occupancy.
The loan is interest-only for its entire ten-year term maturing in
May 2015.  Moody's LTV and stressed DSCR are 110% and 0.83X,
respectively, compared to 107% and 0.86X at last review.

The third largest loan is the Hyatt Regency Dallas Loan
($90.0 million -- 2.5% of the pool), which is secured 1,122-room,
30-story full service hotel located in downtown Dallas, Texas.
Performance remains relatively stable since last review, despite
the decline in the hotel sector due to the recession.  The loan is
interest-only for its entire ten-year term maturing in January
2015.  Moody's LTV and stressed DSCR are 116% and 1.25X,
respectively, compared to 114% and 1.27X at last review.


GS MORTGAGE: S&P Downgrades Ratings on 11 2006-RR2 Certificates
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 11
classes of commercial mortgage-backed securities pass-through
certificates from GS Mortgage Securities Corp. II's series 2006-
RR2, a U.S. resecuritized real estate mortgage investment conduit
transaction.  At the same time, S&P affirmed its ratings on six
other classes from this transaction.

The downgrades and affirmations primarily reflect S&P's analysis
following interest shortfalls to the transaction.  S&P's analysis
also considered the potential for classes A-1 and A-2 to
experience interest shortfalls in the future.

S&P lowered its ratings on classes P and Q to 'D (sf)' on June 22,
2010, to reflect interest shortfalls that S&P expected to continue
for the foreseeable future.

According to the Oct. 25, 2010, trustee report, remaining deferred
interest to the transaction totaled $3.2 million, affecting class
B and the classes subordinate to it.  The interest shortfalls to
GSMS 2006-RR2 resulted from interest shortfalls on 15 of the
underlying CMBS transactions, primarily resulting from special
servicing fees and appraisal subordinate entitlement reductions.
S&P lowered its ratings on classes J through O to 'D (sf)' due to
interest shortfalls since February 2010 that S&P expects will
continue for the foreseeable future.

According to the Oct. 25, 2010 trustee report, GSMS 2006-RR2 is
collateralized by 78 CMBS classes ($756.2 million, 100%) from 58
distinct transactions issued between 1996 and 2006.  The rated
CMBS collateral has a weighted average rating of 'BB- (sf)' and a
rating range of 'AA- (sf)' to 'D (sf)'.  The weighted average
credit estimate of the unrated CMBS collateral is 'ccc'.

Standard & Poor's analyzed the transaction and its underlying
collateral assets in accordance with its current criteria.  S&P's
analysis is consistent with the lowered and affirmed ratings.

                         Ratings Lowered

                 GS Mortgage Securities Corp. II
Commercial mortgage-backed securities pass-through certificates
                         series 2006-RR2

                                  Rating
                                  ------
           Class            To               From
           -----            --               ----
           A-1              CCC- (sf)        BB+ (sf)
           A-2              CCC- (sf)        B (sf)
           B                CCC- (sf)        B- (sf)
           C                CCC- (sf)        CCC+ (sf)
           D                CCC- (sf)        CCC (sf)
           J                D (sf)           CCC- (sf)
           K                D (sf)           CCC- (sf)
           L                D (sf)           CCC- (sf)
           M                D (sf)           CCC- (sf)
           N                D (sf)           CCC- (sf)
           O                D (sf)           CCC- (sf)

                        Ratings Affirmed

                 GS Mortgage Securities Corp. II
Commercial mortgage-backed securities pass-through certificates
                         series 2006-RR2

                    Class            Rating
                    -----            ------
                    E                CCC- (sf)
                    F                CCC- (sf)
                    G                CCC- (sf)
                    H                CCC- (sf)
                    P                D (sf)
                    Q                D (sf)


GUAM WATERWORKS: Fitch Assigns 'BB' Rating to $118.8 Mil. Bonds
---------------------------------------------------------------
Fitch Ratings has assigned a 'BB' rating to these bonds issued by
Guam Waterworks Authority:

  -- $118.8 million water and wastewater system revenue bonds,
     series 2010.

The bonds are expected to price the week of Nov. 8, 2010, via
negotiation.  Proceeds will be used to fund capital improvements,
provide for capitalized interest, fund a debt service reserve, and
pay costs of issuance.

At this time, Fitch also affirms the 'BB' rating on these GWA
bonds:

  -- $95.3 million in outstanding water and wastewater system
     revenue bonds, series 2005.

The Rating Outlook is Stable.

Rating Rationale:

  -- Financial performance of GWA's combined water and wastewater
     system (the system) is marginal but is expected to improve
     over the near term.

  -- Debt levels are high and significant capital needs remain to
     meet ongoing regulatory requirements.

  -- Rate affordability will be limited over the long term based
     on the level of increases required to fund the capital
     improvement program and the low wealth levels.

  -- Management has made substantial progress to date in
     addressing remedial actions and improving operating
     performance.

  -- The service territory is isolated and limited and has had a
     historical disposition to natural disasters.

Key Rating Drivers:

  -- Continued timeliness of rate relief in light of mandated
     capital costs and other identified needs will be paramount.

  -- Maintenance of adequate financial performance despite capital
     and operating pressures will be key.

  -- Required contributions by the authority to address capital
     needs associated with the military build-up could pressure
     operations and possibly result in deferral of necessary
     projects already identified.

  -- Preservation of groundwater supplies and water quality is
     critical to operations.

Security:

The bonds are senior lien bonds secured by the authority's net
system revenues.

Credit Summary:

Historically, the system has been plagued with weak financial
performance and violations of the federal Clean Water Act and Safe
Drinking Water Act (SDWA), which necessitated involvement at the
federal regulatory level.  However, since 2002 when the
authority's governance was changed from an appointed board to an
elected governing board, significant strides have been made
towards returning the system to regulatory compliance and ensuring
stable operations.  Nevertheless, significant challenges persist
which will pressure utility operations over the long term.

Over each of the most recent two audited fiscal years (2008 and
2009), senior lien annual debt service coverage fell below 1.0
times based on the bond indenture's methodology for calculating
net revenues, resulting in violations of the rate covenant.
Despite these results, GWA made all debt service payments for both
years as scheduled without drawing on its debt service reserve
fund.  However, this was accomplished through a drawdown of GWA's
cash position, which in turn prohibited the authority from
depositing sufficient monies in its operations and replacement
reserves as required under the bond indenture.

Given the authority's financial results for these years and as
prescribed by the indenture, the authority engaged a consulting
engineer to make recommendations as to necessary revisions in
rates and changes to operating methods.  Based on these
recommendations and in conformance with GWA's five-year financial
plan, the Consolidated Commission on Utilities (the CCU, GWA's
governing body) and the Public Utilities Commission (the PUC)
approved a series of base rate adjustments, including a 14% hike
(effective August 2009) and an 8% increase (effective October
2011).  In total, rates will rise nearly 40% by fiscal 2013 from
fiscal 2008 levels; rate increases for fiscals 2012 and 2013 are
subject to annual review by the PUC prior to implementation.

With these adjustments and changes to operating methods
recommended by the consulting engineer, GWA forecasts -- and GWA's
consulting engineer concurs - that it comfortably will be able to
meet its rate covenant and that it should be able to reach its
1.75x ADS target coverage as well starting in fiscal 2011.
Indeed, unaudited results for fiscal 2010 are much improved from
the prior year, with senior lien ADS coverage estimated at over
1.4x on a cash basis.  In addition, GWA recently procured a $30
million loan from the Bank of Guam, a portion of which was used to
fully fund the operations and replacement reserves requirements.

While financial performance appears to be improving, GWA faces
significant capital needs to meet regulatory requirements.  In
2003 the authority negotiated a stipulated order with the U.S.
Environmental Protection Agency as a result of violations to the
CWA and SDWA.  To date, GWA has completed close to 90% of the
deliverables associated with the SO and remaining items are
addressed in the fiscal 2010-2014 CIP.  However, to address
system-wide deficiencies and ensure ongoing regulatory compliance,
GWA and EPA are in the process of negotiating a new consent
decree.  At present, it is unknown what capital and operating
requirements may be required from any new consent decree or
whether or not these items would add to or cause an acceleration
of GWA's 20-year financial plan, which identifies as much as
$893 million in capital needs (2007 dollars); the fiscal 2010-2014
CIP totals around $201 million and is a subset of the 20-year
plan.

Compounding GWA's operating and capital pressures, an immense
military troop build-up is expected on the island over the next
several years that is expected to increase the island's permanent
population by around 32,000 people (approximately a 20% rise).
This will necessitate significant additional capital investment
that currently is not included in the authority's CIP.  While GWA
and the U.S. Department of Defense have been working together to
identify system needs and funding resources to service this influx
of population, it is currently unclear what the ramifications will
be to GWA's operations or the form of capital funding; the CCU
maintains that none of the costs will be borne by the island's
current customer base.

There is a possibility that some of the capital costs associated
with the 20-year financial plan as well as possible costs from the
consent decree under negotiation could be paid by the DOD.  Fitch
believes that this would be a positive development as it would
alleviate some rate pressure on GWA's existing customers.
Currently, the monthly residential bill is estimated at a
relatively high 2.7% of 2008 median household income (the most
recent statistics available).  This will continue to rise as
approved rate hikes are adopted.  In addition, annual forecasted
adjustments are currently envisioned as needed to support the 20-
year financial plan.  Apart from the capital needs associated with
the military build-up, there is the potential that the additional
population could strain water supplies or lead to water quality
degradation, although it appears that GWA and DOD are effectively
coordinating their efforts to alleviate these concerns.


GUAM WATERWORKS: Moody's Assigns 'Ba2' Rating to $118.8 Mil. Bonds
------------------------------------------------------------------
Moody's Investors Service has assigned a Ba2 rating to Guam
Waterworks Authority's $118.8 million Water and Wastewater Revenue
Bonds, Series 2010.  Concurrently, Moody's has affirmed the
Authority's Ba2 rating, affecting approximately $95.3 million of
outstanding parity debt.  The rating outlook is stable.  The bonds
are scheduled to price during the week of November 8, and proceeds
will finance a portion of the Authority's capital improvement plan
for fiscal years 2010 through 2013, largely to address regulatory
compliance violations in accordance with a 2003 stipulated order
administered by the Environmental Protection Agency.

                        Ratings Rationale

The Ba2 rating reflects the essentiality of services provided by
the authority and management oversight provided by through the
Consolidated Commission on Utilities.  The rating also factors a
history of operating losses, including recent operating challenges
that led to failure to meet the rate covenant as directed for the
outstanding $95.3 million Series 2005 parity bonds, tempered by
the willingness of the Public Utilities Commission to raise rates.
In addition, the rating reflects the underlying economic position
of Guam and its population and a capital plan driven by an EPA
stipulated order (arising from a myriad of regulatory violations),
which is roughly 85% complete.  The rating also incorporates the
expectation that infrastructure improvements to support a planned
military build-up on Guam will be fully funded by the United
States and the Government of Japan.

Credit Strengths:

  -- Supplier of essential water and waste water services to most
     of the island's population

  -- Independent managerial oversight

  -- CIP driven by regulatory requirements and public support

  -- Planned infrastructure improvements expected to be funded by
     the U.S. and Japanese governments will provide increased
     system capacity and address regulatory concerns

Credit Challenges:

  -- Rate covenant breach on the Series 2005 bonds
  -- Poor collection rates
  -- History of operating losses and regulatory non-compliance

Satisfactory Bondholder Legal Provisions:

Satisfactory bondholder legal protections include a 1.25 times
rate covenant and additional bonds test requiring either 1.25
times coverage on a historic basis (last complete fiscal year or
any 12 month period out of the 18 months preceding the issuance of
additional bonds) or on a projected basis as certified by a
consulting engineer.  The indenture requires a debt service
reserve funded at maximum annual debt service, and an operations
and maintenance reserve equal to three months budgeted operating
and renewal and replacement expenses.  The closed loop flow of
funds includes equal monthly transfers to the trustee-held debt
service fund.

Financial Operating Results Weakened By Low System Collection
Rates:

Despite staffing reductions implemented in 2004, which decreased
headcount by 22% and reduced operating expenditures by more than
$5 million (10%); and implementation of annual rate increases
averaging 8.5% since 2004, the Authority has posted a series of
operating losses in recent years.  Financial operations have been
significantly challenged by poor revenue collections resulting
from the failure of new meters installed beginning in 2005 as part
of the Authority's compliance with a 2003 EPA Stipulated Order.
These meters failed over time, causing significant under-reporting
of water consumption by 2008, impacting both water and wastewater
revenues.  In addition to the revenue losses, the authority also
experienced pressure on the expenditure side due to the rise in
the price of natural resources.  Approximately 1/3 of the
authority's operating costs are related to energy purchases.  In
each of fiscal years 2008 and 2009, power purchase expenses
exceeded projections by nearly 50% (approximately $5 million in
each year).  Additionally, the Authority purchases approximately
10% of its water from the U.S. Navy.  Navy water supply costs
increased by 83.2% (approximately $2 million) from fiscal 2007 to
fiscal 2009.

The authority has put in place a number of solutions to address
the financial challenges of the system, including the replacement
of faulty meters, as well as a comprehensive management audit to
reduce costs.  The plan includes multi-year rate increases
conditionally approved by the PUC in March 2009, which will
ultimately increase rates by 41.5% between 2009 and 2013.  The
first three increases have already gone into effect; increases of
4.9% and 8% scheduled to take effect as of October 2011 and
October 2012, respectively, are subject to annual PUC review.
Favorably, the PUC has approved all rate increases requested by
the Authority to date.

Failure to Meet Rate Covenant On Series 2005 Revenue Bonds:

The authority issued $103 million of revenue bonds in 2005,
representing the authority's initial venture into the capital
markets.  The indenture governing the bonds pledged the
authority's revenues to the payment of debt service.  This pledge
is bolstered by a covenant to maintain rates at a level where net
revenues exceed annual debt service by 1.25 times.  While the PUC
set rates in 2004 that would have provided for net revenues to
exceed 1.25 times annual debt service, the substantial revenue
losses from the faulty water meters resulted in net revenues equal
to less than 1 times debt service in fiscal 2008 and fiscal 2009
(approximately 0.8 times and 0.6 times, respectively).  Debt
service on the bonds was paid in both years from other revenues
legally available to the authority, including the system's
operation and maintenance reserve, and by delaying payments to
vendors.  This reserve was subsequently funded and vendors paid
with the proceeds of a $30 million bank loan, secured by a
subordinate lien on system revenues.

Failure to comply with the rate covenant does not constitute an
event of default under the bond indenture.  According to the bond
indenture, failure to meet the rate covenant requires the
authority to engage a consulting engineer to make recommendations
as to a revision of such system rates, fees and charges or the
methods of operations of the system.  The authority engaged R.W.
Beck as consulting engineer to provide a Rates and Operation
Report, which states that the authority's actions to date and
planned future action, if implemented, are reasonably expected to
provide sufficient net revenue to meet the rate covenant moving
forward.  The Indenture also requires the authority to maintain a
bond reserve fund equal to maximum annual debt service, which
continues to be fully funded from bond proceeds.

Improved Performance Projected For Fiscal 2010:

Favorably, operating performance is projected to have improved in
fiscal 2010 (year ended September 30, 2010), based upon unaudited
results.  Revenues reportedly increased 20% over fiscal 2009
collections, reflecting implementation of rate increases during
2009, including a 6.6% increase effective April 1 and a 14%
increase effective August 1; and ongoing replacement of failing
meters.  Officials project fiscal 2010 net revenue provided
healthier 1.4 times debt service coverage.  The authority projects
exceeding its 1.75 times coverage target in the current fiscal
year 2011 (1.9 times coverage projected).  Per the consulting
engineer's report, modest rate increases (3.6% and 0.5%,
respectively) would be required to meet this target in fiscal 2012
and 2013 while also funding certain planned capital needs from net
revenues, well below the 4.9% and 8% increases conditionally
approved by the PUC.  Future credit reviews will factor debt
service coverage trends going forward, including the authority's
ability to manage the scheduled increase in debt service in fiscal
2014, when debt service on the current bonds ramps up following a
period of capitalized interest.  Liquidity was bolstered during
the year by proceeds from a $30 million bank loan which
replenished reserves drawn upon in 2009.

    The Authority Is The Key Provider Of Services To The Local
                            Population

The authority is the largest provider of water and wastewater
services to Guam's civilian population of 178,000.  The water
system serves roughly 95% of the population.  Its water operations
rely exclusively on rainfall, which averages 90 inches per annum
and is driven by the prevailing Pacific tradewinds.  The authority
operates over 200 water facilities and 110 wells to pump the
ground water.  It also relies on 2 natural springs and purchases
from the Navy to maintain adequate supply.  Together, these
sources provide a minimum reliable freshwater supply of roughly 44
MGD to 48 MGD.

Daily usage approaches system capacity, at 43 MGD, of which
approximately 17 MGD is accounted for.  System losses and low
collection rates have historically been and continue to be a
weakness for the authority.  In 2005 the authority attempted to
reduce system losses through the use of new water meters, a leak
detection program and other remedial measures, however, in 2008
the authority discovered that the new water meters were defective,
resulting in the significant under-reporting of water consumption
on the island, as discussed above.  The authority formed a task
force to address the meter problem, and replacement of faulty
meters is ongoing and expected to be completed by the end of
fiscal 2012.  After correcting a meter, GWA may retroactively bill
the customer for the previous four-month period to recoup a
portion of the lost revenues.

In contrast to the broad reach of the authority's water services,
its wastewater network reaches only 68% of the local civilian
population.  The remainder relies on septic tanks and other
disposal methods.  The authority also provides wastewater service
to all Air Force and a portion of the island's Navy installations.
The wastewater system is comprised of 300 miles of sewer lines
managed by 77 pumping stations.  The authority's two largest
treatment facilities have a design capacity of 12 MGD each
(although one is currently permitted for just 6 MGD) and total
design capacity of 26 MGD accommodates current average daily flow
of 17 MGD.  The system provides primary treatment with discharge
through ocean outfalls.  The authority historically had a
secondary treatment waiver issued by the EPA permitting primary
treatment effluent to be discharged into the ocean, although
extension of the waiver was denied in September 2009, potentially
requiring significant investment in the treatment plants.  GWA is
appealing this decision, and has requested a stay in the
proceedings given the recently announced plans to upgrade to
secondary treatment in support of the planned military build-up on
Guam (discussed below); these improvements would be funded by the
U.S. government.

The authority is governed by the Consolidated Commission on
Utilities (CCU), which was formed in January of 2003 and is
comprised of 5 elected members who are responsible for managing
Guam Water and Guam Power.  The CCU is charged with adding
transparency to the management component of the authority.  In
addition to the CCU, the Public Utilities Commission, a regulatory
board appointed by the Governor and charged with balancing utility
and customer concerns and approval of system rate increases, adds
another layer of oversight.

    Guam's Economy Driven By Us Military Presence And Tourism

Guam is the westernmost territory of the United States of America,
located approximately 6,000 miles southwest of San Francisco,
3,700 miles west-southwest of Honolulu, and 1,500 miles southeast
of Tokyo.  The island encompasses a total land area of
approximately 212 square miles.  Most food and goods are imported,
75% of which are from the U.S. mainland, and the island serves as
a transshipment distribution center for trade among its
neighboring islands in the western Pacific.  Guam has a population
of 178,000 and personal income per capita of approximately
$15,000, substantially below the $39,138 of the United States.
Unemployment in September 2010, at 9.4%, was just below the 9.6%
U.S. unemployment rate.

Tourism revenues and U.S. federal and military spending underpin
the island's economy.  The United States Navy and Air Force have a
substantial presence in Guam.  Total military employment on the
island is currently estimated to be about 18%.  It is anticipated
that this number will rise substantially as the U.S. moves ahead
with plans to increase military presence in Guam, by relocating
military bases from Japan to Guam.  Overall, the planned build-up
is projected to add 32,000 military personnel and dependents with
a planned opening date in 2014, although it is likely that this
timeframe will be extended by several years.  Related construction
work is expected to contribute to economic growth on Guam in the
interim, given $16.4 billion of anticipated investment ($2 billion
currently appropriated) by the U.S. government (including
$10 billion to construct the new bases, $5 billion of improvement
at existing bases, and $1.4 billion of infrastructure
improvements); as well $6 billion anticipated from the Government
of Japan ($900 million currently appropriated).

The island's proximity to major Asian cities greatly contributes
to the diversity of the island's population and visitor industry.
Tourism experienced declines in 2008 and 2009 as a result of the
global economic downturn.  However, officials report that through
the first nine months of calendar 2010, visitor arrivals have
increased 14.9% from the same period in 2009.  Tourism could
increase over the near-term given expansion of air service from
Asia.

Current Bonds Will Fund Remaining Projects Directed By 2003 Epa
Stipulated Order:

The authority has a history of non-compliance with EPA regulation,
particularly the Safe Drinking Water Act and the Clean Water Act,
which has resulted in two consent decrees and a stipulated order
(the latter was issued in 2003).  The stipulated order, which
resulted from non-compliance with the consent decrees, addresses a
broad spectrum of managerial, operational, financial, construction
and rehabilitation requirements to be implemented over a
prescribed period.  The requirements were included in the
authority's 2006 Water and Wastewater Master Plan.  At the time,
the authority estimated that the total cost of the program would
be $222 million over the next three to five years.  A portion of
the authority's outstanding $95.3 million Series 2005 Revenue
Bonds funded projects to comply with the EPA stipulated order.
The authority is currently on track to fully comply with the EPA
and has completed approximately 85% of the projects required under
the stipulated order.  The current bonds will fund completion of
these projects, as well as other needs of the authority.  GWA and
the EPA are currently negotiating a new consent decree which will
replace the 2003 stipulated order.

Moody's continues to view the involvement of the EPA through the
stipulated order as a long-term positive development for the
authority.  The public nature of the stipulated order and the
overall benefits to the entire population should marshal support
within the government to take the steps necessary to implement the
capital investment plan.

                             Outlook

The stable outlook reflects the authority's actions to combat the
financial and operational challenges of the system and the
willingness of the PUC to support additional rate increases.

                  What could move the rating Up?

  -- An established trend of positive financial performance,
     especially cost rationalization

  -- Implementation of timely rate increases to provide for
     adequate debt service coverage, particularly given the
     scheduled increase in debt service requirements in fiscal
     2014

  -- Successful implementation of management plan to improve
     system collection and water loss

                 What could move the rating Down?

  -- Continued deterioration in financial performance

  -- Lack of willingness to raise rates or poor collections in the
     face of higher rates

  -- No improvement in system collections, resulting in net
     operating revenues failing to cover debt service

  -- Failure to make a debt service payment


GULF STREAM-COMPASS: S&P Affirms Junk CLO 2004-1 Rating
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A and C notes from Gulf Stream-Compass CLO 2004-1 Ltd., a
collateralized loan obligation transaction managed by Gulf Stream
Asset Management LLC, and removed them from CreditWatch positive.
At the same time, S&P affirmed its rating on the class D notes.
The upgrades reflect the improved performance S&P has observed in
the deal since its last rating action in November 2009.

According to the Sept. 3, 2010, trustee report, the transaction
held $8.0 million in defaulted assets, down from $26.8 million
noted in the Oct. 7, 2009, trustee report.  The senior
overcollateralization ratio test for this deal rose to 129.2% from
116.1% in October 2009.

Additionally, since October 2009, the class A notes have
experienced over $70 million in paydowns reducing their current
outstanding amount to 58.9% of their original balance.

Standard & Poor's will continue to review whether, in its view,
the ratings currently assigned to the notes remain consistent with
the credit enhancement available to support them and take rating
actions as S&P deems necessary.

                          Rating Actions

               Gulf Stream-Compass CLO 2004-1 Ltd.

                             Rating
                             ------
          Class         To           From
          -----         --           ----
          A             AA+ (sf)     A- (sf)/Watch Pos
          C             BBB+ (sf)    BB+ (sf)/Watch Pos

                         Rating Affirmed

               Gulf Stream-Compass CLO 2004-1 Ltd.

                     Class          Rating
                     -----          ------
                     D              CCC- (sf)


GULF STREAM-COMPASS: S&P Ups Rating on Class D Notes to BB
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B, C, and D notes from Gulf Stream-Compass CLO 2003-1 Ltd., a
collateralized loan obligation transaction managed by Gulf Stream
Asset Management LLC.  At the same time, S&P removed the ratings
on the class A and B notes from CreditWatch positive.  S&P also
affirmed its rating on the class E notes.  The upgrades reflect
the improved performance S&P has observed in the transaction since
S&P's last rating action in December 2009.

According to the Sept. 15, 2010, trustee report, the transaction
held $8 million in defaulted assets, down from $23 million noted
in the Nov. 19, 2009, trustee report.  In addition, assets from
obligors rated in the 'CCC' category were $28 million in September
2010, compared with $36 million in November 2009.  The class A/B
overcollateralization test improved to 122.07% in September 2010
from 112.16% as of November 2009.  The class A notes were paid
down by $59 million since S&P's last rating action and represent
approximately 51% of their original balance at issuance.

Standard & Poor's will continue to review whether, in its view,
the ratings currently assigned to the notes remain consistent with
the credit enhancement available to support them and take rating
actions as S&P deem necessary.

                  Rating And Creditwatch Actions

               Gulf Stream-Compass CLO 2003-1 Ltd.

                             Rating
                             ------
        Class             To           From
        -----             --           ----
        A notes           AAA (sf)     AA+ (sf)/Watch Pos
        B notes           AA+ (sf)     A+ (sf)/Watch Pos
        C notes           A+ (sf)      BBB+ (sf)
        D notes           BB (sf)      B+ (sf)

                        Ratings Affirmed

               Gulf Stream-Compass CLO 2003-1 Ltd.

                   Class             Rating
                   -----             ------
                   E notes           CCC- (sf)


HAMPTON ROADS: Fitch Maintains Negative Watch on Three Bonds
------------------------------------------------------------
Fitch Ratings has maintained the Negative Rating Watch for these
classes of Hampton Roads PPV, LLC military housing taxable revenue
bonds (Hampton Roads Unaccompanied Housing Project), 2007 series
A:

  -- Approximately $210 million class I rated 'A-';
  -- Approximately $58 million class II rated 'BB+';
  -- Approximately $9 million class III rated 'B+'.

The bond ratings remain on Rating Watch Negative.  Fitch first
assigned a Negative Outlook to the bonds on May 1, 2009, and
placed the ratings on Rating Watch Negative on April 1, 2010.

Rating Rationale:

  -- This ratings are based on the construction completion, the
     delivery of all units in July/August 2010 following the
     construction delay in spring 2010, and the successful
     absorption of the new units.  Currently there is strong
     project occupancy at 95% as of September 2010.

  -- Overall project occupancy for the four months following full
     delivery of end-state units ending Sept. 30, 2010, is 93.5%
     and 87.3% for all of 2010 to date.  The project currently
     maintains a waiting list of 532 individuals.

  -- Property net operating income has benefited from management's
     efforts to control project expenses on a year-to-date basis;
     however, interest income continued to fall far short of
     original projections due to the cancellation of the AIG
     guaranteed investment contract and the reinvestment of
     proceeds in lower yielding instruments.

  -- The ratings remain on Watch reflecting debt service coverage
     ratios (based on annualized data for the 10 months ending
     Sept. 30, 2010) that continue to remain below developer
     projections that were revised in April 2010.  Debt service
     coverage, based on actual annualized operating data, does not
     assume an additional vacancy factor and demonstrates 1.32
     times, 1.02x and 0.97x coverage, respectively.  While
     these coverage ratios are below developer projections, they
     are above the Fitch stress cash flow projection that
     incorporated a 20% vacancy factor (and were used when the
     bonds were downgraded on April 20, 2010) and projected ratios
     of 1.22x, 0.94x and 0.9x, respectively.

  -- While the construction has reached completion and the project
     performance has improved, the higher occupancy rates have
     only been in effect for August and September and additional
     months demonstrating strong project occupancy are needed
     before a trend is established.  If current occupancy rates
     hold for the remainder of 2010, debt service ratios are
     expected to outpace those noted above based on annualized
     operating data.

  -- Also supporting the continued rating watch, the 2011 Basic
     Allowance for Housing rates are expected to be released
     in December 2010 and will play an important role in projected
     cash flows for 2011.  Fitch expects that BAH rates will be
     flat based on third party Property and Portfolio Research
     projections for apartment rent levels in the Norfolk area.

Key Rating Drivers:

  -- Management's ability to maintain high project occupancy
     levels, control property expenses and manage bad debt issues;

  -- Volatility in future BAH rates will have significant impact
     on future bond debt service coverage ratios.

Security:

The bonds are secured by a first lien on all receipts of the
project, the majority of which comes from the monthly housing
allowance deposited in a lock box.  The monthly housing allowance,
or BAH, is a cash allowance based on local rental rates and is an
integral part of the compensation of U.S. military personnel.

Credit Summary:

In April 2010, the developer revised pro forma cash flows to
reflect construction delays, reduced occupancy levels, increased
operating expenses, and reduced interest income.  The revised
projections incorporated a 12% vacancy assumption and demonstrated
this expectation for reduced debt service coverage ratios for
2010:

  -- Class I bonds: 1.38
  -- Class II bonds: 1.06
  -- Class III bonds: 1.02

The developer reports that the June 1, 2010 net operating income
shortfall was addressed through the use of excess project
operating reserves and the developer did not need to request funds
from the debt service reserve fund, provided by an AMBAC surety
bond, for the June 1, 2010 debt service payment.

Property management reports that the project is still experiencing
issues as it relates to bad debt from former residents that have
separated from the military.  They are actively managing the
situation and the amount of total bad debt is small relative to
overall revenue representing only 1.4% of total project revenue.

The bonds have a debt service reserve fund whereby AMBAC serves as
the surety bond provider.  Fitch does not assign any value to the
AMBAC surety bond and does not rely on their presence in the event
of project financial deterioration.

Fitch expects to review the 2011 BAH rates and will monitor future
project occupancy data within the next six months.


HELLER FINANCIAL: Moody's Cuts Ratings on Five 2000 PH-1 Notes
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five classes
and affirmed five classes of Heller Financial Commercial Mortgage
Asset Corp., Mortgage Pass-Through Certificates, Series 2000 PH-1:

  -- Cl. X, Affirmed at Aaa (sf); previously on Feb. 10, 2000
     Definitive Rating Assigned Aaa (sf)

  -- Cl. C, Affirmed at Aaa (sf); previously on Dec. 8, 2006
     Upgraded to Aaa (sf)

  -- Cl. D, Affirmed at Aaa (sf); previously on Dec. 8, 2006
     Upgraded to Aaa (sf)

  -- Cl. E, Affirmed at Aaa (sf); previously on Aug. 20, 2007
     Upgraded to Aaa (sf)

  -- Cl. F, Affirmed at Aaa (sf); previously on Sept. 25, 2008
     Upgraded to Aaa (sf)

  -- Cl. H, Downgraded to Caa3 (sf); previously on Aug. 20, 2007
     Upgraded to Baa3 (sf)

  -- Cl. J, Downgraded to Ca (sf); previously on Aug. 20, 2007
     Upgraded to Ba2 (sf)

  -- Cl. K, Downgraded to C (sf); previously on Feb. 10, 2000
     Definitive Rating Assigned B1 (sf)

  -- Cl. L, Downgraded to C (sf); previously on Feb. 10, 2000
     Definitive Rating Assigned B2 (sf)

  -- Cl. M, Downgraded to C (sf); previously on April 27, 2005
     Downgraded to Caa1 (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans, a decline in loan diversity, as
measured by the Herfindahl Index and concerns about loans
approaching maturity in an adverse environment.  Fifteen loans,
representing 39% of the pool, have either matured or mature within
the next six months and have a Moody's stressed debt service
coverage ratio less than 1.0X.

The affirmations are due to key parameters, including Moody's loan
to value ratio and Moody's stressed DSCR remaining within
acceptable ranges.  Based on Moody's current base expected loss,
the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings.

Moody's rating action reflects a cumulative base expected loss of
15.9% of the current balance.  At last review, Moody's cumulative
base expected loss was 1.6%.  Moody's stressed scenario loss is
18.0% of the current balance.  Moody's provides a current list of
base and stress scenario losses for conduit and fusion CMBS
transactions on moodys.com at:

  http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions as well as the excel-based CMBS Large Loan Model v.
8.0 which is used for Large Loan transactions.  Conduit model
results at the Aa2 level are driven by property type, Moody's
actual and stressed DSCR, and Moody's property quality grade
(which reflects the capitalization rate used by Moody's to
estimate Moody's value).  Conduit model results at the B2 level
are driven by a paydown analysis based on the individual loan
level Moody's LTV ratio.  Moody's Herfindahl score, a measure of
loan level diversity, is a primary determinant of pool level
diversity and has a greater impact on senior certificates.  Other
concentrations and correlations may be considered in Moody's
analysis.  Based on the model pooled credit enhancement levels at
Aa2 and B2, the remaining conduit classes are either interpolated
between these two data points or determined based on a multiple or
ratio of either of these two data points.  For fusion deals, the
credit enhancement for loans with investment-grade credit
estimates is melded with the conduit model credit enhancement into
an overall model result.  Fusion loan credit enhancement is based
on the underlying rating of the loan which corresponds to a range
of credit enhancement levels.  Actual fusion credit enhancement
levels are selected based on loan level diversity, pool leverage
and other concentrations and correlations within the pool.
Negative pooling, or adding credit enhancement at the underlying
rating level, is incorporated for loans with similar credit
estimates in the same transaction.

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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 11 compared to 56 at Moody's prior review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology.  This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation.  The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios.  Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship.  These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated September 25, 2008.  See
the ratings tab on the issuer / entity page on moodys.com for the
last rating action and the ratings history.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.

                         Deal Performance

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 83% to $167.4
million from $956.9 million at securitization.  The Certificates
are collateralized by 35 mortgage loans ranging in size from less
than 1% to 15% of the pool, with the top ten loans representing
53% of the pool.  The pool contains 15 conduit loans representing
46% of the pool.  The remaining pool consists of seven defeased
loans (25% of the pool) and thirteen specially serviced loans (29%
of the pool).

Three loans, representing 11% 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 monthly reporting package.  Moody's has assumed a
high default probability for all the watchlisted loans.  Moody's
has estimated a $4.8 million loss (26% expected loss based on an
85% default probability) from these troubled loans.

Nineteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $33 million (41% loss severity
overall).  Thirteen loans, representing 29% of the pool, are
currently in special servicing.  The largest specially serviced
loan is 5000 West Roosevelt Loan ($11.6 million -- 7% of the
pool), which is secured by a 1.2 million square foot industrial
property located in Chicago, Illinois.  The loan was transferred
to special servicing in October 2009 due to maturity default.  The
remaining twelve specially serviced loans are secured by a mix of
property types.  Moody's has estimated an aggregate $20.6 million
loss (42% expected loss on average) for the specially serviced
loans.

Based on the most recent remittance statement, Classes N through
K have experienced cumulative interest shortfalls totaling
$5.2 million.  Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced loans.  Interest shortfalls are caused by
special servicing fees, including workout and liquidation fees,
appraisal subordinate entitlement reductions and extraordinary
trust expenses.

Moody's was provided with full year 2009 operating results for 62%
of the pool's nine performing conduit loans.  Excluding specially
serviced and troubled loans, Moody's weighted average LTV is 71%
compared to 84% at Moody's prior review.  Moody's net cash flow
reflects a weighted average haircut of 11.6% to the most recently
available net operating income.  Moody's value reflects a weighted
average capitalization rate of 9.6%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.32X and 1.56X, respectively, compared to
1.48X and 1.30X at last review.  Moody's actual DSCR is based on
Moody's net cash flow (NCF) 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.

Due to the high percentage of loans in special servicing, Moody's
analysis was largely based on a loss and recovery analysis for
specially serviced and troubled loans.  The performance of the
performing conduit component, which only represents 34% of the
pool, is stable and performing in-line with Moody's expectations.


HOLIDAY SYNTHETIC: Moody's Takes Rating Actions on CDO Deals
------------------------------------------------------------
Moody's Investors Service announced these rating actions on
Holiday Synthetic CLO Class A and Class D, collateralized debt
obligation transactions.

The CSOs, issued in 2007, referenced a portfolio of synthetic
corporate syndicated loans.

Issuer: Holiday Synthetic CLO Class A (Oddo Cash Dollar)

  -- US$1.25M Class A Notes, Upgraded to Aa1 (sf); previously on
     March 11, 2009 Downgraded to Aa3 (sf)

Issuer: Holiday Synthetic CLO Class A (Oddo Cash Plus)

  -- EUR4M Class A Notes, Upgraded to Aa1 (sf); previously on
     March 11, 2009 Downgraded to Aa3 (sf)

Issuer: Holiday Synthetic CLO Class A (Oddo Cash Tritisation)

  -- EUR5M Class A Notes, Upgraded to Aa1 (sf); previously on
     March 11, 2009 Downgraded to Aa3 (sf)

Issuer: Holiday Synthetic CLO Class A (Oddo Cash)

  -- EUR30M Class A Notes, Upgraded to Aa1 (sf); previously on
     March 11, 2009 Downgraded to Aa3 (sf)

Issuer: Holiday Synthetic CLO Class D (Mizuho International plc)

  -- US$15M Class D Notes, Upgraded to Ba3 (sf); previously on
     March 11, 2009 Downgraded to Caa2 (sf)

                        Ratings Rationale

Moody's explained that the rating action taken is the result of
the credit improvement of the referenced portfolio, the shortened
time to maturity of the CSO and the substantial level of credit
enhancement remaining.

The 10-year weighted average rating factor of the portfolio is
2976, equivalent to B3 (excluding settled credit events).  The
portfolio continues to improve with 61% of the portfolio currently
rated B1 or below, compared to 75% from the last review.  There
are 3 entities with a negative outlook compared to 2 with a
positive outlook, and 2 entities on watch for downgrade compared
to none on watch for upgrade.  In the near to medium term, the
outlook of the portfolio is neutral.

The portfolio has experienced 6 credit events, equivalent to 2.38%
of the portfolio based on the portfolio value at closing.  The
deal has 70% fixed recovery.  The deal will mature in 1.42 years.

Moody's rating action factors in the modeling the results of a
number of sensitivity analyses and stress scenarios, including:

* The Effect of the time to maturity -- The committee has reviewed
  the impact of a scenario consisting of reducing the maturity by
  6 months and 1 year, keeping all other variables constant.
  Reducing the maturity of the transaction by 6 months generated a
  result with one notch higher for the Class A swaps and two
  notches higher for the Class D swaps from the base case.
  Reducing the maturity of the transaction by 1 year resulted in
  one notch higher for the Class A swaps and three notches higher
  for the Class D swaps from the base case.

* MIRs -- Moody's also considered the results of a sensitivity
  analysis consisting of modeling MIRs in place of the corporate
  fundamental ratings to derive the default probability of each
  corporate name in the reference portfolio.  The gap between an
  MIR and a Moody's corporate fundamental rating is an indicator
  of the extent of the divergence of credit view between Moody's
  and the market on each referenced name in the CSO portfolio.
  The results of this run had no ratings impact for Class A and D
  swaps compared to the base case.

* Potential Additional Defaults -- A sensitivity analysis
  consisting of defaulting all entities rated Caa1 and below was
  included.  This case generated a result four and seven notches
  lower than the base case for the Class A and Class D swaps,
  respectively.

* Removing the notch down on all reference entities on negative
  outlook -- There was no material impact to the model result for
  Class A and D swaps compared to the base case.

* Sector-wide weakening -- A sensitivity analysis consisting of
  notching down by 1 all the entities in the Hotel, Gaming and
  Leisure industry sector, the sector most highly represented in
  the reference portfolio, was examined.  This run had no material
  impact for the Class A swaps and had a one notch lower for the
  Class D swaps compared to the base case.

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.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Corporate Synthetic
Obligations", key model inputs used by Moody's in its analysis may
be different from the manager/arranger's reported numbers.  In
particular, rating assumptions for all publicly rated corporate
credits in the underlying portfolio have been adjusted for "Review
for Possible Downgrade", "Review for Possible Upgrade", or
"Negative Outlook".

Moody's did not run a separate loss and cash flow analysis other
than the one already done using the CDOROM model.  For a
description of the analysis, refer to the methodology and the
CDOROM user guide on Moody's website.

Moody's analysis of CSOs is subject to uncertainties, the primary
sources of which includes complexity, governance and leverage.
Although the CDOROM model captures many of the dynamics of the
Corporate CSO structure, it remains a simplification of the
complex reality.  Of greatest concern are (a) variations over
time in default rates for instruments with a given rating,
(b) variations in recovery rates for instruments with particular
seniority/security characteristics and (c) uncertainty about the
default and recovery correlations characteristics of the reference
pool.  Similarly on the legal/structural side, the legal analysis
although typically based in part on opinions (and sometimes
interpretations) of legal experts at the time of issuance, is
still subject to potential changes in law, case law and the
interpretations of courts and (in some cases) regulatory
authorities.  The performance of this CSO is also dependent on on-
going decisions made by one or several parties, including the
Manager and the Trustee.  Although the impact of these decisions
is mitigated by structural constraints, anticipating the quality
of these decisions necessarily introduces some level of
uncertainty in Moody's assumptions.  Given the tranched nature of
Corporate CSO liabilities, rating transitions in the reference
pool may have leveraged rating implications for the ratings of the
Corporate CSO liabilities, thus leading to a high degree of
volatility.  All else being equal, the volatility is likely to be
higher for more junior or thinner liabilities.

The base case scenario modeled fits into the central macroeconomic
scenario predicted by Moody's of a sluggish recovery scenario of
the corporate universe.  Should macroeconomics conditions evolves
towards a more severe scenario such as a double dip recession, the
CSO ratings will be reevaluated in light of the potential severity
of such worsening conditions.


JP MORGAN: Fitch Downgrades Ratings on Nine 2005-CIBC12 Certs.
--------------------------------------------------------------
Fitch Ratings has downgraded nine classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp., Series 2005-CIBC12
commercial mortgage pass-through certificates, due to the further
deterioration of performance, most of which involves increased
losses on the specially serviced loans.

As a result of the expected losses on loans currently in special
servicing, Fitch expects classes H through P to be fully depleted.
As of the October 2010 distribution date, the pool's aggregate
principal balance has been paid down by approximately 8% to
$2.05 billion from $2.2 billion at issuance.  Four loans (2.9%)
are currently defeased.  As of October 2010, interest shortfalls
are affecting classes F through P.

Fitch has designated 52 loans (24.6%) as Fitch Loans of Concern,
which includes 25 specially serviced loans (14.6%).  The largest
specially serviced loan (4%) is secured by a 440,127 square foot
office building in downtown New York City.  The loan transferred
in June 2010 for maturity default after the sponsor was unable to
refinance the existing debt.  Of additional concern to Fitch is
the largest tenant, the City of New York (49.2% of the net
rentable area), had a lease expiration on July 23, 2010, and the
tenant is currently in-place on a month-to-month lease.  The loss
of this tenant would result in a significant decrease in the
property's cash flow.  Currently, the special servicer is in
discussions with the borrower on workout options, and the borrower
continues to negotiate with the City of New York for a renewal of
their space.  Fitch will continue to monitor the workout.

The next largest loan of concern (2.1%) is secured by 685,585 sf
of an 813,165 sf regional mall in Steubenville, OH, approximately
35 miles west of Pittsburgh, PA.  Major tenants at the center
include Wal-Mart (30.6% of NRA), Sears (17.7%), J.C. Penney
(8.1%), and Dick's Sporting Goods (7.5%).  The mall has
experienced a steady decline in performance over the last two
years, mainly due to an increase in vacancy and the negative
effects that the recession had on the subject's local market.  The
debt service coverage ratio and occupancy experienced additional
declines in 2009, with year-end figures of 1.02 times and 82.6%,
respectively, compared with 1.16x and 90% at year-end 2008 and
1.39x and 86% at issuance.  Any additional decline in cash flow
may impact the borrower's ability to pay future debt service
obligations.

The next loan of concern is secured by a 82,337 sf retail center
in Corona, CA.  The loan transferred to special servicing in April
2010 for maturity default.  According to the servicer, the
property remains well occupied (99%), and the special servicer is
attempting to finalize a modification which would provide the
borrower with a loan extension.  The terms of the extension, if
executed, will likely be finalized by year-end.

Fitch stressed the value of the non-defeased loans by applying a
5% haircut to 2009 fiscal year-end net operating income and
applying an adjusted market cap rate between 7.25% and 10% to
determine value.

Similar to Fitch's prospective analysis of recent vintage
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 DSCR of 1.25x or higher were considered to
pay off at maturity.  Of the non-defeased or non-specially
serviced loans, 100 loans (57.9% of the overall pool) were assumed
not to be able to refinance, of which Fitch modeled losses for 25
loans (13.7%) in instances where Fitch's derived value was less
than the outstanding balance.  The high number of loans that fail
Fitch's refinance test is due to the pool's above-average
leverage, with 44 loans (29.9%) (non-defeased and non-specially
serviced) having a Fitch loan-to-value greater than 90%.

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

  -- $162.5 million Class A-J to 'Asf/LS3' from 'AA/LS5'; Outlook
     Stable;

  -- $43.3 million Class B to 'BBB-sf/LS5' from 'BBB/LS5'; Outlook
     Stable;

  -- $19 million Class C to 'BBsf/LS5' from 'BBB-/LS5'; Outlook
     Stable;

  -- $32.5 million Class D to 'Bsf/LS5' from 'BB/LS5'; Outlook to
     Negative from Stable;

  -- $27.1 million Class E to 'Bsf/LS5' from 'BB/LS5'; Outlook to
     Negative from Stable;

  -- $24.4 million Class F to 'CCCsf/RR1' from 'B/LS5';

  -- $24.4 million Class G to 'CCCsf/RR1' from 'B-/LS5';

  -- $29.8 million Class H to 'Csf/RR6' from 'B-/LS5';

  -- $8.1 million Class J to 'Csf/RR6' from 'CC/RR3'.

In addition, Fitch has affirmed these classes as indicated:

  -- $112 million Class A-2 at 'AAA/LS1'; Outlook Stable;
  -- $163.6 million Class A-3A1 at 'AAA/LS1'; Outlook Stable;
  -- $122.9 million Class A-3A2 at 'AAA/LS1'; Outlook Stable;
  -- $200 million Class A-3B at 'AAA/LS1'; Outlook Stable;
  -- $649.3 million Class A-4 at 'AAA/LS1'; Outlook Stable;
  -- $137.4 million Class A-SB at 'AAA/LS1'; Outlook Stable;
  -- $216.7 million Class A-M at 'AAA/LS3'; Outlook Stable;
  -- $8.1 million Class K at 'C/RR6';
  -- $8.1 million Class L at 'C/RR6';
  -- $5.4 million Class M at 'C/RR6';
  -- $8.1 million Class N at 'C/RR6';
  -- $5.4 million Class P at 'C/RR6';
  -- $50 million Class UHP at 'B-/LS5'; Outlook Negative.

The class A-1 has been paid in full.  Fitch withdraws the ratings
on the interest-only classes X-1 and X-2.


JP MORGAN: Fitch Downgrades Ratings on 16 2005-LDP2 Certs.
----------------------------------------------------------
Fitch Ratings has downgraded 16 classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp. 2005-LDP2 commercial mortgage
pass-through certificates.

As a result of the expected losses on loans currently in special
servicing, Fitch expects classes L through NR to be fully
depleted.  As of the October 2010 distribution date, the pool's
aggregate principal balance has been paid down by 13.8% to
$2.57 billion from $2.98 billion at issuance.  Nine loans (1.7%)
are currently defeased.  As of October 2010, cumulative interest
shortfalls affect classes L through NR.

Fitch has designated 64 loans (21.2%) as Fitch Loans of Concern,
which includes 25 specially serviced loans (10.9%).  The largest
specially serviced loan (1.8%) is secured by a 363,333 square foot
anchored shopping center located in Memphis, TN.  The loan
transferred to special servicing in January 2010 due to monetary
default.  The loan is 90+ days delinquent and the special servicer
is proceeding with foreclosure.

The next largest specially serviced loan (1.2%) is secured by a
293,276 sf anchored retail property located in Temecula, CA.  The
loan was transferred in June 2010 due to maturity default.  The
special servicer is in discussions with the borrower for a
possible extension of the loan.

The third largest specially serviced loan (1.1%) is secured by a
408-unit multifamily property located in Cordova, TN.  The loan
transferred to special servicing in July 2010 for monetary
default.  The loan is 90+ days delinquent and the special servicer
is proceeding with foreclosure.

Fitch stressed the value of the non-defeased loans by applying a
5% haircut to 2009 fiscal year-end net operating income (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 that
could refinance to a DSCR of 1.25 times or higher were considered
to pay off at maturity.  Of the non-defeased or non-specially
serviced loans, 76 loans (48.6% of the overall pool) were assumed
not to be able to refinance, of which Fitch modeled losses for 15
loans (15.4%) in instances where Fitch's derived value was less
than the outstanding balance.

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

  -- $216 million class A-J to 'A/LS3' from 'AA/LS3'; Outlook
     Stable;

  -- $18.6 million class B to 'A/LS5' from 'AA/LS5'; Outlook
     Stable;

  -- $41 million class C to 'BBB-/LS5' from 'A/LS5'; Outlook
     Stable;

  -- $26.1 million class D to 'BB/LS5' from 'BBB/LS5'; Outlook
     Stable;

  -- $26.1 million class E to 'BB/LS5' from 'BBB/LS5'; Outlook
     Negative;

  -- $26.1 million class G to 'B/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $44.7 million class H to 'B-/LS5' from 'B/LS5'; Outlook
     Negative;

  -- $29.8 million class J to 'CCC/RR1' from 'B-/LS5';

  -- $37.2 million class K to 'CCC/RR4' from 'B-/LS5';

  -- $11.2 million class L to 'C/RR6' from 'B-/LS5';

  -- $14.9 million class M to 'C/RR6' from 'B-/LS5';

  -- $11.2 million class N to 'C/RR6' from 'B-/LS5';

  -- $7.4 million class O to 'C/RR6' from 'B-/LS5';

  -- $7.4 million class P to 'C/RR6' from 'B-/LS5 ';

  -- $11.2 million class Q to 'C/RR6' from 'CCC/RR1'.

Fitch has affirmed and revised the LS ratings of these classes:

  -- $542.1 million class A-1A at 'AAA/LS3'; Outlook Stable;
  -- $250 million class A-2 at 'AAA/LS5'; Outlook Stable;
  -- $367.4 million class A-3 at 'AAA/LS3'; Outlook Stable;
  -- $122.7 million class A-3A at 'AAA/LS5'; Outlook Stable;
  -- $561.3 million class A-4 at 'AAA/LS3'; Outlook Stable;
  -- $123.4 million class A-SB at 'AAA/LS5'; Outlook Stable;
  -- $247.9 million class A-M at 'AAA/LS3'; Outlook Stable;
  -- $50 million class A-MFL at 'AAA/LS5'; Outlook Stable.

Fitch affirmed this class:

  -- $29.8 million class F at 'BB/LS5'; Outlook Negative.

The $12 million class NR is not rated by Fitch.  Class A-1 has
paid in full.  Fitch has withdrawn the ratings on the interest-
only classes X-1 and X-2.


JP MORGAN: Fitch Downgrades Ratings on Six 2005-LDP5 Certs.
-----------------------------------------------------------
Fitch Ratings has downgraded six classes of JP Morgan Chase
Commercial Mortgage Securities Corp., 2005-LDP5 commercial
mortgage pass-through certificates, due to the further
deterioration of performance, most of which involves increased
losses on the specially serviced loans.

As a result Fitch's increased loss expectations, largely
attributed to the Hanover Mall loan, Fitch expects class Q to be
fully depleted upon liquidation of the asset.  As of the October
2010 distribution date, the pool's aggregate principal balance has
been paid down by 8% to $3.98 billion from $4.32 billion at
issuance.  As of October 2010, cumulative interest shortfalls
affect classes L-Q.

Fitch has designated 32 loans (13.5%) as Fitch Loans of Concern,
which includes 10 specially serviced loans (5.9%).  The largest
specially serviced loan, the Atlantic Development Portfolio
(2.27%), is secured by a portfolio of eight office/flex properties
located in Warren, NJ (five properties) and Somerset, NJ (three).
The loan transferred to the special servicer in April 2010.
Property performance suffered following the loss of several large
tenants in the fourth quarter of 2008 and occupancy remained at
76.7% at Aug. 30, 2010.  The servicer reported DSCR as of YE2009
was 1.09x.  The loan is current and the special servicer is
negotiating a loan modification with the borrower.  As of the
October 2010 remittance report, leasing reserves of approximately
$3.5 million were available, including a $1.5 million letter of
credit.

The next largest specially serviced asset (2.16%) is secured by
the Hanover Mall, which transferred to the special servicer in
November 2009 for imminent default.  The borrower and the special
servicer were unable to agree to terms on a modification and the
servicer ultimately took title to the property in February 2010.
The loan is collateralized by a 706,005 square foot anchored
retail center located in Hanover, MA.  Property performance
declined in 2009 due to the requests for rent relief from tenants
as well as several store closures, including Circuit City, KB
Toys, Ritz Camera, and Zale's Jewelers.  As of Sept. 1, 2010, the
property is 91% occupied and the servicer is in discussions with
several existing tenants to expand.  Fitch stressed the value of
the non-defeased loans by applying a 5% haircut to 2009 fiscal
year-end net operating income and applying an adjusted market cap
rate between 7.25% and 10% to determine value.

Similar to Fitch's prospective analysis of recent vintage
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 DSCR of 1.25x or higher were considered to
pay off at maturity.  Of the non-defeased or non-specially
serviced loans, 125 loans (54.9% of the overall pool) were assumed
not to be able to refinance, of which Fitch modeled losses for 29
loans (13.5%) in instances where Fitch's derived value was less
than the outstanding balance.

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

  -- $26.2 million class L to 'CCCsf/RR1' from 'B-/LS5';
  -- $15.7 million class M to 'CCsf/RR3' from 'B-/LS5';
  -- $15.7 million class N to 'CCsf/RR3' from 'B-/LS5';
  -- $5.2 million class O to 'Csf/RR6' from 'B-/LS5';
  -- $5.2 million class P to 'Csf/RR6' from 'B-/LS5';
  -- $10.5 million class Q to 'Csf/RR6' from 'CCC/RR6'.

In addition, Fitch has affirmed and revised the Outlooks on these
classes as indicated:

  -- $125.5 million class A-2FL at 'AAAsf/LS1'; Outlook Stable;

  -- $297.5 million class A-2 at 'AAAsf/LS1'; Outlook Stable;

  -- $171.5 million class A-3 at 'AAAsf/LS1'; Outlook Stable;

  -- $1,395.9 million class A-4 at 'AAAsf/LS1'; Outlook Stable;

  -- $160.8 million class A-SB at 'AAAsf/LS1'; Outlook Stable;

  -- $439.4 million class A-1A at 'AAAsf/LS1'; Outlook Stable;

  -- $419.7 million class A-M at 'AAAsf/LS3'; Outlook Stable.

  -- $299 million class A-J at 'AAsf/LS3'; Outlook Stable;

  -- $26.2 million class B at 'AAsf/LS5''; Outlook Stable

  -- $73.4 million class C at 'Asf/LS5''; Outlook Stable;

  -- $42 million class D at 'Asf/LS5'; Outlook Stable;

  -- $21 million class E at 'Asf/LS5'; Outlook Stable;

  -- $52.5 million class F at 'BBBsf/LS5'; Outlook Stable;

  -- $36.7 million class G at 'BBsf/LS5'; Outlook Stable;

  -- $52.5 million class H at 'BBsf/LS5''; Outlook to Negative
     from Stable;

  -- $42 million class J at 'BBsf/LS5''; Outlook to Negative from
     Stable;

  -- $63 million class K at 'B-sf/LS5'; Outlook Negative.

Fitch does not rate the $52.5 million class NR or any of the rake
classes HG-1 through HG-5.  The class A-1 has been paid in full.
Fitch withdraws the ratings on the interest-only class X-1 and X-
2.


JP MORGAN: Moody's Downgrades Ratings on Seven 2002-CIBC4 Certs.
----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of seven classes
and affirmed six classes of J.P. Morgan Chase Commercial Mortgage
Securities Corp., Commercial Mortgage Pass-Through Certificates,
Series 2002-CIBC4:

  -- Cl. A-2, Affirmed at Aaa (sf); previously on April 29, 2002
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on April 29, 2002
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-1, Affirmed at Aaa (sf); previously on April 29, 2002
     Definitive Rating Assigned Aaa (sf)

  -- Cl. B, Affirmed at Aaa (sf); previously on Sept. 27, 2005
     Upgraded to Aaa (sf)

  -- Cl. C, Downgraded to Aa2 (sf); previously on Sept. 22, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to A2 (sf); previously on Sept. 22, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to Ba2 (sf); previously on Sept. 22, 2010
     Baa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to Caa3 (sf); previously on Sept. 22, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to Ca (sf); previously on Sept. 22, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. H, Downgraded to C (sf); previously on Sept. 22, 2010 B2
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. J, Downgraded to C (sf); previously on Sept. 22, 2010 B3
     (sf) Placed Under Review for Possible Downgrade

  -- Cl.K, Affirmed at C (sf); previoulsy on Sept. 22, 2010
     Downgraded to C (sf)

  -- Cl. L, Affirmed at C (sf); previoulsy on Sept. 22, 2010
     Downgraded to C (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans and concerns about refinancing risk
associated with loans approaching maturity in an adverse
environment.  Seventy-two loans, representing 63% of the pool,
mature within the next 24 months.  Sixteen of these loans,
representing 23% of the pool, have a Moody's stressed debt service
coverage less than 1.00X.

The affirmations are due to key parameters, including Moody's loan
to value ratio, Moody's stressed debt service coverage ratio and
the Herfindahl Index , remaining within acceptable ranges.  Based
on Moody's current base expected loss, the credit enhancement
levels for the affirmed classes are sufficient to maintain their
current ratings.

On September 22, 2010, Moody's placed seven classes on review for
possible downgrade.  This action concludes Moody's review.

Moody's rating action reflects a cumulative base expected loss of
9.1% of the current balance.  At last review, Moody's cumulative
base expected loss was 4.0%.  Moody's stressed scenario loss is
11.3% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl score
, a measure of loan level diversity, is a primary determinant of
pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the underlying rating of the
loan which corresponds to a range of credit enhancement levels.
Actual fusion credit enhancement levels are selected based on loan
level diversity, pool leverage and other concentrations and
correlations within the pool.  Negative pooling, or adding credit
enhancement at the underlying rating level, is incorporated for
loans with similar credit estimates in the same transaction.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated February 26, 2009.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 25% to
$598.93 million from $798.91 million at securitization.  The
Certificates are collateralized by 107 mortgage loans ranging in
size from less than 1% to 11% of the pool, with the top ten loans
representing 30% of the pool.  Twenty-seven loans, representing
31% of the pool, have defeased and are collateralized with U.S.
Government securities.

Twenty-six 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 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 $20.1 million (42% loss severity
overall).  Three loans, representing 12% of the pool, are
currently in special servicing.  The largest specially serviced
loan is the Highland Mall Loan ($62.6 million -- 10.5%), which is
secured by the borrower's interest in a 1.1 million square foot
regional mall located in Austin, Texas.  The center is anchored by
Dillard's and Macy's.  J.C.  Penney, which was the center's fourth
anchor at securitization, vacated the center in 2006.  This has
resulted in increased vacancy of the in-line stores.  The center's
in-line occupancy was 70% as of June 2009 compared to 76% at last
review.  The borrower is a joint venture between General Growth
Properties, Inc. and The Simon Property Group.  The loan
transferred to special servicing in June 2009 and is REO.

The master servicer has recognized an aggregate $17.9 million
appraisal reduction on two of the specially serviced loans.
Moody's has estimated an aggregate $36.0 million loss (51%
expected loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for 11 poorly
performing loans representing 9% of the pool and has estimated a
$11.1 million aggregate loss (22% expected loss based on a 43%
probability default) from these troubled loans.  Moody's rating
action recognizes potential uncertainty around the timing and
magnitude of loss from these troubled loans.

Moody's was provided with full year 2009 operating results for 98%
of the pool.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 77% compared to 90% at Moody's
prior review.  Moody's net cash flow reflects a weighted average
haircut of 12% to the most recently available net operating
income.  Moody's value reflects a weighted average capitalization
rate of 9.9%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.34X and 1.50X, respectively, compared to
1.50X and 1.29X 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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 21 compared to 25 at Moody's prior review.

The top three performing conduit loans represent 9% of the pool
balance.  The largest loan is the Sugarland Crossing Loan
($22.7 million -- 3.5%), which is secured by a 256,500 square foot
power center located approximately 27 miles from Washington, D.C.,
in Sterling, Virginia (Loudoun County).  The largest tenants are
Burlington Coat Factory, Shoppers Food Warehouse and The Room
Store.  The property was 95% occupied as of June 2010, similar to
last review.  The loan matures in August 2011.  Moody's LTV and
stressed DSCR are 78% and 1.32X, respectively, compared to 83% and
1.23X at last review.

The second largest loan is the Oak Park Town Center Loan
($15.4 million -- 2.6%), which is secured by a 168,000 square foot
retail center located in Chattanooga, Tennessee.  The property is
shadow anchored by a Super Wal-Mart.  Major tenants include Famous
Labels, Marshall's and Home Depot.  The loan is on the master
servicer's watchlist due to low DSCR.  The property was 89% leased
as of June 2010 compared to 82% at last review.  Despite the
increased occupancy, performance has declined since last review
and the loan is on the servicer's watchlist for low DSCR.  The
loan matures in May 2012.  Due to the decline in performance
Moody's considers this loan to have a high probability of default.
Moody's LTV and stressed DSCR are 153% and 0.71X, respectively,
compared to 146% and 0.74X at last review.

The third largest loan is Springdale Plaza Loan ($13.6 million --
2.3%), which is secured by an 188,000 square foot retail center
located in suburban Cincinnati, Ohio.  The center was 70% leased
as of April 2010.  The loan is on the master servicer's watchlist
due to low occupancy.  The occupancy decrease is primarily due to
Circuit City declaring bankruptcy and vacating the center in 2009.
The loan matures in January 2012.  Moody's LTV and stressed DSCR
are 125% and 0.86X, respectively, compared to 85% and 1.27X at
last review.


JP MORGAN: Moody's Reviews Ratings on 15 2006-CIBC14 Certificates
-----------------------------------------------------------------
Moody's Investors Service placed 15 classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp., Commercial Mortgage Pass-
Through Certificates, Series 2006-CIBC14 on review for possible
downgrade:

  -- Cl. A-M, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on March 28, 2006 Definitive Rating Assigned Aaa
      (sf)

  -- Cl. A-J, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Aa3 (sf)

  -- Cl. B, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to A2 (sf)

  -- Cl. C, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to A3 (sf)

  -- Cl. D, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Baa2 (sf)

  -- Cl. E, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Baa3 (sf)

  -- Cl. F, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Ba2 (sf)

  -- Cl. G, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to B1 (sf)

  -- Cl. H, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to B3 (sf)

  -- Cl. J, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa2 (sf)

  -- Cl. K, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa2 (sf)

  -- Cl. L, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa3 (sf)

  -- Cl. M, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa3 (sf)

  -- Cl. N, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa3 (sf)

  -- Cl. P, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa3 (sf)

The classes were placed on review due to higher expected losses
for the pool resulting from actual and anticipated losses from
specially serviced and troubled loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated February 11, 2009.

                   Deal And Performance Summary

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 3% to $2.66 billion
from $2.75 billion at securitization.  The Certificates are
collateralized by 197 mortgage loans ranging in size from less
than 1% to 11% of the pool, with the top ten loans representing
39% of the pool.

Fifty-six loans, representing 23% 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 (CREFC; formerly the 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.

Two loans have been liquidated from the pool, resulting in an
aggregate realized loss of $5.4 million (55% loss severity
overall).  Thirty-six loans, representing 18% of the pool, are
currently in special servicing.  The specially serviced loans are
secured by a mix of multifamily, office, retail, hotel and
industrial property types.  The master servicer has recognized
appraisal reductions totaling $131.6 million for 30 of the
specially serviced loans.

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


JP MORGAN: Moody's Reviews Ratings on 19 2007-C1 Certificates
-------------------------------------------------------------
Moody's Investors Service placed 19 classes of J.P. Morgan Chase
Commercial Mortgage Securities Trust 2007-C1 Commercial Mortgage
Pass-Through Certificates, Series 2007-C1 on review for possible
downgrade:

  -- Cl. A-SB, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Jan. 14, 2008 Definitive Rating
     Assigned Aaa (sf)

  -- Cl. A-4, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Jan. 14, 2008 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. A-M, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Jan. 14, 2008 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. A-J, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to A1 (sf)

  -- Cl. B, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to A2 (sf)

  -- Cl. C, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to A3 (sf)

  -- Cl. D, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Baa1 (sf)

  -- Cl. E, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Baa2 (sf)

  -- Cl. F, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Baa3 (sf)

  -- Cl. G, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Ba1 (sf)

  -- Cl. H, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Ba3 (sf)

  -- Cl. J, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to B2 (sf)

  -- Cl. K, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to B3 (sf)

  -- Cl. L, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Caa1 (sf)

  -- Cl. M, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Caa1 (sf)

  -- Cl. N, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Caa2 (sf)

  -- Cl. P, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Caa2 (sf)

  -- Cl. Q, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Ca (sf)

  -- Cl. T, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Ca (sf)

The classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from anticipated
losses from specially serviced and troubled loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated February 6, 2009.

                   Deal And Performance Summary

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 1% to
$1.165 billion from $1.178 billion at securitization.  The
Certificates are collateralized by 59 mortgage loans ranging in
size from less than 1% to 12% of the pool, with the top ten loans
representing 61% of the pool.  No loans have defeased or have
credit estimates.

Eighteen loans, representing 34% 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 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.

To date no loans have been liquidated from the trust.  Currently
seven loans, representing 16% of the pool, are in special
servicing.  The master servicer has recognized an aggregate
$59 million appraisal reduction for six of the specially serviced
loans.

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


JP MORGAN: Moody's Takes Rating Actions on Three Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the rating of class 1-A-1,
confirmed the rating of class 2-A-1, and downgraded the rating of
class 1-A-2 issued by J.P. Morgan Mortgage Trust, Series 2008-R4.

Issuer: J.P.  Morgan Mortgage Trust, Series 2008-R4

  -- Cl. 1-A-1, Upgraded to Baa1 (sf); previously on Jan. 13, 2010
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-2, Downgraded to Ca (sf); previously on Jan. 13, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-1, Confirmed at B3 (sf); previously on Jan. 13, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

                        Ratings Rationale

The upgrade action on class 1-A-1 is result of sufficient credit
enhancement available as compared to the revised loss expectation
on the pool of mortgages backing the underlying certificate.
Similarly, class 2-A-1 was confirmed because it had sufficient
credit enhancement while class 1-A-2 was downgraded because it did
not have sufficient credit enhancement to maintain the current
ratings compared to the revised loss expectations on the pools of
mortgages backing the underlying certificates.

The resecuritization bonds 1-A-1 and 1-A-2 are backed by Class 11-
L1 issued by Chase Mortgage Finance Trust Series 2007-A1.  The
resecuritization bonds 2-A-1 and 2-A-2 are backed by Class III-A-1
issued by RFMSI Series 2006-SA4 Trust.  Both underlying
certificates are backed primarily by first-lien, prime residential
mortgage loans.

The Class 1-A-1 issued in the resecuritization transaction is a
senior class, supported by a subordinated bond Class 1-A-2, which
receives principal payments after Class 1-A-1 but absorbs losses
before Class 1-A-1.  The Class 2-A-1 issued in the
resecuritization transaction is a senior class, supported by a
subordinated bond Class 2-A-2, which receives principal payments
after Class 2-A-1 but absorbs losses before Class 2-A-1.

Moody's ratings on certificates in a resecuritization are based
on:

   (i) The updated expected loss of the pool of loans backing the
       underlying certificates and the updated ratings on the
       underlying certificates.  Moody's current loss expectation
       on the pool backing Chase Mortgage Finance Trust Series
       2007-A1 is 15% expressed as a percentage of outstanding
       deal balance.  The current rating on the 11-L1 bond is
       Caa2.  Moody's current loss expectation on the pool backing
       RFMSI Series 2006-SA4 Trust is 27.5% expressed as a
       percentage of outstanding deal balance.  The current rating
       on the III-A-1 bond is Caa2.

  (ii) The credit enhancement available to the underlying
       certificates, and

(iii) The structure of the resecuritization transaction.

Moody's first updated its loss assumptions on the underlying pools
of mortgage loans (backing the underlying certificates) and then
arrived at updated ratings on the underlying certificates.  The
ratings on the underlying certificates are based on expected
recoveries on the bonds under ninety-six different combinations 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.
In order to determine the ratings of the resecuritized bonds, the
loss on the underlying certificates were ascribed to the
resecuritized classes, according to the structure of the
resecuritized transaction.  The losses on the group 1
resecuritized certificates are allocated "bottom up" with Class 1-
A-2 taking loss ahead of Class 1-A-1.  Principal payments to these
certificates are allocated sequentially, with Class 1-A-1 being
paid ahead of Class 1-A-2.  Similarly, losses on the group 2
resecuritized certificates are allocated "bottom up" with Class 2-
A-2 taking loss ahead of Class 2-A-1.  Principal payments to these
certificates are allocated sequentially, with Class 2-A-1 being
paid ahead of Class 2-A-2.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment remains at high
levels, and weakness persists in the housing market.  Moody's
notes an increasing potential for a double-dip recession, which
could cause a further 20% decline in home prices (versus its
baseline assumption of roughly 5% further decline).  Overall,
Moody's assumes a further 5% decline in home prices with
stabilization in early 2011, accompanied by continued stress in
national employment levels through that timeframe.

As a part of the sensitivity analysis, Moody's stressed the
updated expected loss of the pool of loans backing the underlying
certificate by an additional 10% and found that the implied
ratings on the resecuritization bonds did not change.

Moody's Investors Service received and took into account a third
party due diligence report on the underlying assets or financial
instruments in this transaction and the due diligence report had a
neutral impact on the rating.


KEYCORP STUDENT: Moody's Reviews Ratings on Eight Student Loans
---------------------------------------------------------------
Moody's Investors Service concluded its review of eight KeyCorp's
student loan transactions.  It downgraded twelve classes, upgraded
one class and confirmed the ratings of five classes of notes.
Some of the affected classes are collateralized by pools that
include both FFELP and private student loans and some by pools of
exclusively private student loans.

                        Ratings Rationale

The downgrades were prompted by a deterioration in performance
of the private student loan collateral.  In some cases the
deterioration is significant, with Moody's expected losses
increasing by as much as 70%.  Moody's revised expected net losses
across all affected deals range between 4% and 20% of the original
pool balance (or the original balance of the private loan group
for the deals in which private and FFELP loans are separated into
separate groups).

As of the July 2010 distribution date, cumulative defaults on
private student loans of the transactions closed prior to 2001
were 5%-7% of the original pool balances.  The cumulative defaults
of the transactions that closed in 2001 or thereafter ranged from
12%-18% of the original private student loan pool balances.  In
particular, the significantly worse performance of the post 2003
transactions can be explained in part by the composition of the
underlying student loan pools: Moody's see higher percentage of
Key Career loans and Campus Dooor Loans in these transactions
compared to 2001-2003 transactions.  Key Career loans are loans
primarily to adult vocational education students, and Campus Door
loans were originated through the direct-to-consumer channel.
Both of these products have higher default rates than loans to
undergraduate and graduate students originated through the
schools' financial aid offices.

The high defaults have been eroding the collateral base and have
caused steady declines in the parity levels of the 2004, 2005, and
2006 transactions.  Between May 2009 and May 2010 the total parity
of these transactions has decreased from a range of 94%-101% to a
range of 92%-99%.  The parity levels of the 2002 and 2003
transactions have remained stable at 100% due to draws on the cash
reserve accounts in order to supplement collections and meet the
required payment obligations.

Although the delinquencies have either stabilized or even improved
over the past year, periodic defaults remain at elevated levels,
which could indicate that the roll rates from delinquencies to
defaults have increased.

Available credit enhancement in most transactions has been
declining.  High defaults have depleted overcollateralization in
all post 2000 transactions to the point that in some deals,
subordinated classes are not even fully collateralized with the
student loan collateral.  Other forms of credit enhancement
include reserve funds, subordination, and excess spread.  Some
senior notes (2003 and later transactions) also benefit from the
subordinate note interest trigger event, which redirects interest
payments on the subordinate notes to principal payments on the
senior notes.

Moody's expected lifetime net losses as a percentage of the
original pool balance plus any loans added subsequently are 4.4%,
5.2%, 7.6%, 12%, 16.8%, 19.6%, 17.6%, and 20% for the 1999-A,
2000-A, 2000-B trusts and 2001-A , 2003-A , 2004-A , 2005-A , and
2006-A private student loan pools, respectively.  The ratings
across almost all tranches could be upgraded if lifetime expected
net losses were 10% lower, or downgraded if the lifetime expected
net losses were 10% higher.  The ratings of Class II A-2 of the
2004 trust and Classes II A-3 and II-C of the 2006 transaction
will not be affected in the future if lifetime expected net losses
are 10% lower or 10% higher than the levels indicated above.

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 uncertainty with
regard to expected losses are the weak economic environment and
the high unemployment rate, which adversely impacts the income-
generating ability of the borrowers.  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.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.

Complete rating actions are:

Issuer: KeyCorp Student Loan Trust 1999-A

  -- Certificates, Upgraded to Aa2 (sf), previously on
     July 22, 2010 A1 (sf) Placed Under Review for Possible
     Downgrade

Issuer: KeyCorp Student Loan Trust 2000-A

  -- Cl. A-2, Downgraded to Baa2 (sf), previously on July 22, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

Issuer: KeyCorp Student Loan Trust 2000-B

  -- Cl. A-2, Downgraded to B1 (sf), previously on July 22, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

Issuer: KeyCorp Student Loan Trust 2001-A

  -- Cl. II-A-2, Downgraded to Baa3 (sf), previously on
     July 22, 2010 Aa2 (sf) Placed Under Review for Possible
     Downgrade

Issuer: KeyCorp Student Loan Trust 2003-A

  -- Cl. II-A-3, Downgraded to Aa1 (sf), previously on
     July 22, 2010 Aaa (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. II-A-IO, Downgraded to Aa1 (sf), previously on
     July 22, 2010 Aaa (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. II-B, Downgraded to Baa3 (sf), previously on July 22,
     2010 A3 (sf) Placed Under Review for Possible Downgrade

Issuer: KeyCorp Student Loan Trust 2004-A

  -- Class II-A-2, Confirmed at Aaa (sf), previously on
     July 22, 2010 Aaa (sf) Placed Under Review for Possible
     Downgrade

  -- Class II-B, Confirmed at Aa3 (sf), previously on July 22,
     2010 Aa3 (sf) Placed Under Review for Possible Downgrade

  -- Class II-C, Confirmed at Baa3 (sf), previously on
     July 22, 2010 Baa3 (sf) Placed Under Review for Possible
     Downgrade

  -- Class II-D, Downgraded to Ca (sf), previously on July 22,
     2010 B2 (sf) Placed Under Review for Possible Downgrade

Issuer: KeyCorp Student Loan Trust 2005-A

  -- Cl. II-A-4, Confirmed at Aaa (sf), previously on July 22,
     2010 Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. II-B, Downgraded to Baa2 (sf), previously on July 22,
     2010 A2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. II-C, Downgraded to Caa1 (sf), previously on July 22,
     2010 Ba3 (sf) Placed Under Review for Possible Downgrade

Issuer: KeyCorp Student Loan Trust 2006-A

  -- Cl. II-A-3, Confirmed at Aaa (sf), previously on July 22,
     2010 Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. II-A-4, Downgraded to Aa3 (sf), previously on
     July 22, 2010 Aa1 (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. II-B, Downgraded to Ba3 (sf), previously on July 22, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. II-C, Downgraded to C (sf), previously on July 22, 2010
     B1 (sf) Placed Under Review for Possible Downgrade


KODIAK CDO: Moody's Assigns 'Ba2' Rating to Interest Rate Swap
--------------------------------------------------------------
Moody's Investors Service has assigned this rating to an interest
rate swaps on the transaction issued by Kodiak CDO I, Ltd.:

  -- Interest Rate Swap ID 1391852B, assigned Ba2 (sf)

                        Ratings Rationale

Moody's rating addresses the credit risk posed to the swap
counterparty.  The rating addresses only the risk attributable to
the ability of the Issuer to continue to honor its obligations
under the swap.

The rating assigned, which is referred to as a "counterparty
instrument rating", takes into account the rating of the swap
counterparty, the transaction's legal structure and the
characteristics of the transaction's underlying collateral pool.
The collateral pool in this case consists primarily of trust
preferred securities issued by trust subsidiaries of a real estate
investment trust, commonly referred to as REIT "TRUPS" securities.
Because there is relatively limited historical performance data
for this type of instrument, the credit rating may have a greater
potential rating volatility than would ratings for transactions
backed by collateral with more historical performance data.

Moody's rating approach for a CIR rests on three propositions:

* A CIR is based on an analysis of the payment promise made by the
  Issuer, the position of the instrument in the payment waterfall,
  the credit quality of the rated payment flows, the security
  arrangements governing the Issuer's relationship with the
  counterparty, the support mechanisms available to the
  counterparty and other structural features of the transaction in
  question.  In this regard, the rating process is similar to that
  for all other ratings assigned by Moody's.

* The credit quality and ratings assigned to a counterparty
  instrument obligation of the Issuer may differ from those of its
  payment obligations to noteholders.  As a result, ratings
  assigned to the Issuer's notes may diverge from a CIR.

* Although a counterparty instrument rating addresses payments to,
  rather than from, the counterparty, in certain circumstances the
  credit strength of the counterparty itself may have a bearing on
  the CIR.  For example, where a counterparty's non-performance
  under a swap agreement leads to the Issuer having to make a
  termination payment to that counterparty, Moody's will take into
  account the likelihood of the counterparty's non-performance
  occurring and the position of termination payments in the cash
  flow waterfall.  Specifically, in the event that the swap
  counterparty causes a termination event, any termination payment
  owed to the swap counterparty may be paid at the bottom of the
  cash flow waterfall.  As a result, a default by the swap
  counterparty makes payment in full to the counterparty unlikely.

By way of background, the swap counterparty, Barclays Bank PLC,
pays a floating coupon based on LIBOR to, and receives a fixed
rate of interest from, the Issuer on a notional amount that is
amortizing according to a schedule to the swap agreement.  The
swap transaction matures in August 2011.  Per the terms of the
Issuer's transaction documentation, the swap transaction receives
payment prior to noteholders and is thus in a senior position to
all notes issued by the Issuer.  To pay the swap transaction, the
Issuer has access to interest collections, principal payments and
liquidation proceeds, strengthening the nature of the senior
payment right of the swaps transaction's counterparty.

Driving the ratings on the swaps are certain risks, primarily the
probability of default on the underlying TRUPS collateral assets
and the resulting inability of the Issuer to make the required
payments on the swaps.  Nearly 30 percent of the assets in the
Issuer's collateral pool have defaulted to date, largely as a
result of weak economic conditions in the real estate sector.  The
credit fundamentals for the REITs sector continue to be
challenging with a continuing expectations of asset defaults,
interest deferrals, and reduced recovery prospects for REIT TRUPS.

Although there is also the risk of a termination event triggered
by a default of the swap counterparty, the significance of this
risk is lessened in this case because the swap counterparty,
Barclays Bank PLC, currently has a Moody's long term rating of Aa3
and a Moody's short term rating of P-1.

Moody's methodology for rating swaps includes,collateral cashflow
analysis.  Moody's stress the cashflows by increasing defaults to
determine what level of collateral stress would cause a shortfall
in proceeds owed to the swap counterparty.  The cashflows are
modeled to reflect the waterfall of the underlying transaction,
which calls for all swap payments other than termination payments
caused by a counterparty default to be paid at the top of the
waterfall.  Termination payments owed to the swap counterparty
resulting from a default of the swap counterparty may be paid at
the bottom of the waterfall, but Moody's did not model this
cashflow scenario given the counterparty's relatively high current
ratings.

Moody's Investors Service received and took into account one or
more third-party due diligence reports on the underlying assets or
financial instruments in this transaction and the due diligence
reports had a neutral impact on the rating.


LB COMMERCIAL: Moody's Upgrades Ratings on Two 1999-C1 Certs.
-------------------------------------------------------------
Moody's Investors Service upgraded the ratings of two classes,
downgraded three classes and affirmed three classes of LB
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 1999-C1:

  -- Cl. X, Affirmed at Aaa (sf); previously on June 10, 1999
     Definitive Rating Assigned Aaa (sf)

  -- Cl. D, Affirmed at Aaa (sf); previously on May 28, 2009
     Upgraded to Aaa (sf)

  -- Cl. E, Upgraded to Aaa (sf); previously on May 28, 2009
     Upgraded to Aa3 (sf)

  -- Cl. F, Upgraded to Baa1 (sf); previously on May 16, 2006
     Upgraded to Baa3 (sf)

  -- Cl. G, Affirmed at Ba2 (sf); previously on June 10, 1999
     Definitive Rating Assigned Ba2 (sf)

  -- Cl. H, Downgraded to Caa2 (sf); previously on May 28, 2009
     Downgraded to B1 (sf)

  -- Cl. J, Downgraded to C (sf); previously on May 28, 2009
     Downgraded to Ca (sf)

  -- Cl. K, Downgraded to C (sf); previously on Feb. 19, 2008
     Downgraded to Ca (sf)

                        Ratings Rationale

The upgrades are due to the significant increase in subordination
due to loan payoffs and amortization and the pool's high exposure
to defeased loans, which represent 18% of the current pool
balance.  The pool has paid down ny 52% since Moody's prior
review.

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans, a decline in loan diversity, as
measured by the Herfindahl Index, and concerns about loans
approaching maturity in an adverse environment.  Ten loans,
representing 23% of the pool, either have matured or mature within
the next six months.  Eight of these loans, representing 20% of
the pool, are in special servicing.

The affirmations are due to stable overall performance of the
performing portion of the pool and increased subordination levels
which are sufficient for the current ratings.

Moody's rating action reflects a cumulative base expected loss of
17.9% of the current balance.  At last review, Moody's cumulative
base expected loss was 9.2%.  Moody's stressed scenario loss is
18.4% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions as well as the excel-based CMBS Large Loan Model v.
8.0 which is used for Large Loan transactions.  Conduit model
results at the Aa2 level are driven by property type, Moody's
actual and stressed DSCR, and Moody's property quality grade
(which reflects the capitalization rate used by Moody's to
estimate Moody's value).  Conduit model results at the B2 level
are driven by a paydown analysis based on the individual loan
level Moody's LTV ratio.  Moody's Herfindahl score, a measure of
loan level diversity, is a primary determinant of pool level
diversity and has a greater impact on senior certificates.  Other
concentrations and correlations may be considered in Moody's
analysis.  Based on the model pooled credit enhancement levels at
Aa2 and B2, the remaining conduit classes are either interpolated
between these two data points or determined based on a multiple or
ratio of either of these two data points.  For fusion deals, the
credit enhancement for loans with investment-grade credit
estimates is melded with the conduit model credit enhancement into
an overall model result.  Fusion loan credit enhancement is based
on the underlying rating of the loan which corresponds to a range
of credit enhancement levels.  Actual fusion credit enhancement
levels are selected based on loan level diversity, pool leverage
and other concentrations and correlations within the pool.
Negative pooling, or adding credit enhancement at the underlying
rating level, is incorporated for loans with similar credit
estimates in the same transaction.

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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 12 compared to 8 at Moody's prior review.  In
cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology.  This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation.  The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios.  Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship.  These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated May 28, 2009.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

                         Deal Performance

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 90% to
$152.97 million from $1.58 billion at securitization.  The
Certificates are collateralized by 38 mortgage loans ranging in
size from less than 1% to 25% of the pool, with the top ten non-
defeased loans representing 62% of the pool.  The pool includes
one loan, representing 25% of the pool, with an investment grade
credit estimate.  Four loans, representing 18% of the pool, have
defeased and are collateralized with U.S. Government securities.
Defeasance at last review represented 8% of the pool.

Thirty-one loans have been liquidated from the pool, resulting in
an aggregate realized loss of $14.96 million (14% loss severity on
average).  Due to realized losses, classes M and L have been
eliminated entirely and Class K has experienced a 29% principal
loss.  Currently, 12 loans, representing 34% of the pool, are in
special servicing.  The largest specially serviced loan is the
Wal-Mart Portfolio Loan ($17.6 million -- 11.5% of the pool),
which is secured by 13 multi-tenant retail centers located in
seven Midwestern states.  The centers are shadow-anchored by
either Wal-Mart or Sams Club.  The portfolio was 61% leased as of
September 2009 compared to 65% at last review.  The loan was
transferred to special servicing in April 2009 for imminent
default.  Negotiations for a loan modification are currently
underway.

The remaining 10 specially serviced loans are secured by a mix of
property types.  The master servicer has recognized an aggregate
$13.5 million appraisal reduction for nine of the specially
serviced loans.  Moody's has estimated an aggregate $27.1 million
loss (52% expected loss on average) for the specially serviced
loans.

Based on the most recent remittance statement, Classes K and J
have a cumulative interest shortfall totaling $1.1 million.
Moody's anticipates that the pool will continue to experience
interest shortfalls because of the high exposure to specially
serviced loans.  Interest shortfalls are caused by special
servicing fees, including workout and liquidation fees, appraisal
subordinate entitlement reductions and extraordinary trust
expenses.

Moody's was provided with full year 2008 and 2009 operating
results for 81% and 48% of the pool, respectively.  Excluding
specially serviced and troubled loans, Moody's weighted average
LTV for the conduit component is 76% compared to 83% at Moody's
prior review.  Moody's net cash flow reflects a weighted average
haircut of 11.8% to the most recently available net operating
income.  Moody's value reflects a weighted average capitalization
rate of 9.7%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs for the conduit component are 1.06X and 1.45X,
respectively, compared to 1.18X and 1.39X 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.

The loan with a credit estimate is the Crossroads Mall Loan
($38.6 million -- 25.2%), which is secured by the borrower's
interest in a 765,000 square foot regional mall located in
Portage, Michigan.  The center is anchored by Macy's, Sears, J.C.
Penney, and Burlington Coat Factory.  The center was 97% leased as
of December 2009 compared to 94% at last review.  The property is
owned by an affiliate of GGP and was included in GGP's April 16,
2009 bankruptcy filing.  The loan was subsequently transferred to
special servicing but has since been transferred back to the
master servicer.  Moody's credit estimate and stressed DSCR are
Aa2 and 2.46X, respectively, compared to Aa2 and 2.55X at last
review.

The largest performing conduit loan is the Kohl's Shopping Center
Loan ($5.2 million -- 3.4%), which is secured by a 100,000 square
foot retail center located in suburban Knoxville, Tennessee.  The
property was 100% leased as of December 2008 with Kohl's
Department Store occupying 86% of the net rentable area through
February 2019.  Moody's LTV and stressed DSCR are 79% and 1.32X,
respectively, compared to 81% and 1.27X at last review.


LB-UBS COMMERCIAL: Moody's Cuts Ratings on Five 2000-C4 Certs.
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five classes
and affirmed five classes of LB-UBS Commercial Mortgage Trust
2000-C4, Commercial Mortgage Pass-Through Certificates, Series
2000-C4:

  -- Cl. X, Affirmed at Aaa (sf); previously on Jan. 15, 2003
     Assigned Aaa (sf)

  -- Cl. C, Affirmed at Aaa (sf); previously on Dec. 8, 2006
     Upgraded to Aaa (sf)

  -- Cl. D, Affirmed at Aaa (sf); previously on Feb. 25, 2008
     Upgraded to Aaa (sf)

  -- Cl. E, Affirmed at Aa1 (sf); previously on Feb. 25, 2008
     Upgraded to Aa1 (sf)

  -- Cl. F, Affirmed at A1 (sf); previously on Dec. 8, 2006
     Upgraded to A1 (sf)

  -- Cl. G, Downgraded to B2 (sf); previously on Feb. 9, 2007
     Upgraded to Baa1 (sf)

  -- Cl. H, Downgraded to Ca (sf); previously on Jan. 15, 2003
     Assigned Ba1 (sf)

  -- Cl. J, Downgraded to C (sf); previously on Feb. 26, 2009
     Downgraded to B2 (sf)

  -- Cl. K, Downgraded to C (sf); previously on July 16, 2009
     Downgraded to Caa3 (sf)

  -- Cl. L, Downgraded to C (sf); previously on July 16, 2009
     Downgraded to Ca (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans, a decline in loan diversity, as
measured by the Herfindahl Index and concerns about loans
approaching maturity in an adverse environment.  Fourteen loans,
representing 56% of the pool, have either matured or mature within
the next six months.  All of these loans have a Moody's stressed
debt service coverage ratio below 1.0X.

The affirmations are due to key parameters, including Moody's loan
to value ratio and Moody's stressed DSCR remaining within
acceptable ranges.  Based on Moody's current base expected loss,
the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings.

Moody's rating action reflects a cumulative base expected loss of
29.9% of the current balance.  At last review, Moody's cumulative
base expected loss was 3.6%.  Moody's stressed scenario loss is
30.8% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions as well as the excel-based CMBS Large Loan Model v.
8.0 which is used for Large Loan transactions.  Conduit model
results at the Aa2 level are driven by property type, Moody's
actual and stressed DSCR, and Moody's property quality grade
(which reflects the capitalization rate used by Moody's to
estimate Moody's value).  Conduit model results at the B2 level
are driven by a paydown analysis based on the individual loan
level Moody's LTV ratio.  Moody's Herfindahl score, a measure of
loan level diversity, is a primary determinant of pool level
diversity and has a greater impact on senior certificates.  Other
concentrations and correlations may be considered in Moody's
analysis.  Based on the model pooled credit enhancement levels at
Aa2 and B2, the remaining conduit classes are either interpolated
between these two data points or determined based on a multiple or
ratio of either of these two data points.  For fusion deals, the
credit enhancement for loans with investment-grade credit
estimates is melded with the conduit model credit enhancement into
an overall model result.  Fusion loan credit enhancement is based
on the underlying rating of the loan which corresponds to a range
of credit enhancement levels.  Actual fusion credit enhancement
levels are selected based on loan level diversity, pool leverage
and other concentrations and correlations within the pool.
Negative pooling, or adding credit enhancement at the underlying
rating level, is incorporated for loans with similar credit
estimates in the same transaction.

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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 9 compared to 27 at Moody's prior review.  In
cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology.  This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation.  The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios.  Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship.  These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated July 16, 2009.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 89% to
$107.6 million from $999.1 million at securitization.  The
Certificates are collateralized by 29 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 63% of the pool.  The conduit component includes 12
loans representing 45% of the pool.  The remaining pool consists
of nine specially serviced loans (41% of the pool), two defeased
loans (3% of the pool) and six tenant leases (CTL; 11% of the
pool).

Nine loans, representing 41% 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 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.

Twenty loans have been liquidated from the pool, resulting in an
aggregate realized loss of $30.8 million (31% loss severity
overall).  These losses have resulted in a the liquidation of
Classes M, N and P in their entirety and a 14% principal loss to
Class L.

Nine loans, representing 41% of the pool, are currently in special
servicing.  The largest specially serviced loan is the 111
Franklin Place Loan ($10.8 million -- 10.1% of the pool), which is
secured by a 138,801 square foot office building located in
Roanoke, Virginia.  The loan was transferred to special servicing
in April 2010 due to imminent monetary default but has remained
current.  The remaining eight specially serviced loans are secured
by a mix of property types.  The servicer has recognized an
aggregate $6.3 million appraisal reduction for three of the
specially serviced loans.  Moody's has estimated an aggregate
$14.9 million loss (34% expected loss on average) for the
specially serviced loans.

Moody's has assumed a high default probability for all of the
watchlisted loans, representing 32% of the pool.  Moody's
aggregate estimated losses for these loans is $8.4 million loss
(25% expected loss based on a 100% probability default) from these
troubled loans.

Based on the most recent remittance statement, Classes H through
L have experienced cumulative interest shortfalls totaling
$3.9 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 was provided with full year 2009 operating results for 76%
of the three performing conduit loans.  Moody's weighted average
LTV for these loans is 61% compared to 85% for the pool at Moody's
prior review.  Moody's net cash flow reflects a weighted average
haircut of 10.0% to the most recently available net operating
income.  Moody's value reflects a weighted average capitalization
rate of 10.1%.

Moody's actual and stressed DSCRs for these loans are 1.63X and
1.87X, respectively, compared to 1.32X and 1.49X 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.

The CTL component consists of six loans leased under bondable
triple net leases to three corporate credits.  The largest
corporate credits include CVS/Caremark Corp.  (51% of the CTL
component; senior unsecured rating Baa2, stable outlook) and
Walgreen Co. (40% of the CTL component; senior unsecured rating
A2, stable outlook).

Due to the high percentage of loans in special servicing, Moody's
analysis was largely based on a loss and recovery analysis for
specially serviced and troubled loans.  The performance of the CTL
component and performing conduit loans is stable and performing
in-line with Moody's expectations.


LB-UBS COMMERCIAL: Moody's Cuts Ratings on Nine 2007-C6 Certs.
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of nine classes
and affirmed ten classes of LB-UBS Commercial Mortgage Trust 2007-
C6, Commercial Mortgage Pass-Through Certificates, Series 2007-C6:

  -- Cl. A-2, Affirmed at Aaa (sf); previously on Sept. 11, 2007
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2FL, Affirmed at Aaa (sf); previously on Sept. 11, 2007
     Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on Sept. 11, 2007
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X, Affirmed at Aaa (sf); previously on Sept. 11, 2007
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-AB, Affirmed at Aaa (sf); previously on Sept. 11, 2007
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed Aaa (sf); previously on May 26, 2010
     Confirmed at Aaa (sf)

  -- Cl. A-1A, Affirmed Aaa (sf); previously on May 26, 2010
     Confirmed at Aaa (sf)

  -- Cl. A-M, Downgraded to A1 (sf); previously on Sept. 16, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-MFL, Downgraded to A1 (sf); previously on Sept. 16,
     2010 Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-J, Downgraded to Ba1 (sf); previously on Sept. 16, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Downgraded to B1 (sf); previously on Sept. 16, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Downgraded to Caa1 (sf); previously on Sept. 16, 2010
     B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to Caa3 (sf); previously on Sept. 16, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to Ca (sf); previously on Sept. 16, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to Ca (sf); previously on Sept. 16, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to C (sf); previously on Sept. 16, 2010 Ca
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. H, Affirmed at C (sf); previously on May 26, 2010
     Downgraded to C (sf)

  -- Cl. J, Affirmed at C (sf); previously on May 26, 2010
     Downgraded to C (sf)

  -- Cl. K, Affirmed at C (sf); previously on May 26, 2010
     Downgraded to C (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from anticipated losses from specially serviced and
troubled loans.  The affirmations are due to key parameters,
including Moody's loan to value ratio, Moody's stressed debt
service coverage ratio and the Herfindahl Index, remaining within
acceptable ranges.  Based on Moody's current base expected loss,
the credit enhancement levels for the affirmed classes are
sufficient to maintain their existing ratings.

On September 16, 2010, Moody's placed nine classes on review for
possible downgrade.  This action concludes Moody's review.

Moody's rating action reflects a cumulative base expected loss of
12.0% of the current balance.  At last review, Moody's cumulative
base expected loss was 10.5%.  Moody's stressed scenario loss is
23.9% of the current balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a pay down analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade underlying ratings is melded with the
conduit model credit enhancement into an overall model result.
Fusion loan credit enhancement is based on the credit estimate of
the loan which corresponds to a range of credit enhancement
levels.  Actual fusion credit enhancement levels are selected
based on loan level diversity, pool leverage and other
concentrations and correlations within the pool.  Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 10 compared to 15 at Moody's prior review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology.  This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation.  The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios.  Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship.  These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated May 26, 2010.  Please see
the ratings tab on the issuer / entity page on moodys.com for the
last rating action and the ratings history.

Moody's Investors Service received and took into account one or
more third party due diligence reports on the underlying assets or
financial instruments in this transaction and the due diligence
reports had a neutral impact on the ratings.

                         Deal Performance

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 1% to
$2.849 billion from $2.979 billion at securitization.  The
Certificates are collateralized by 181 mortgage loans ranging in
size from less than 1% to 14% of the pool, with the top ten loans
representing 58% of the pool.  The pool contains one loan,
representing 1.4% of the pool, with an investment grade credit
estimate.  No loans have defeased.

Forty-two 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 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 an
aggregate realized loss of $2.1 million (80% loss severity).
Nineteen loans, representing 23% of the pool, are currently in
special servicing.  The largest specially serviced loan is the
Innkeepers Portfolio Loan ($412.7 million -- 14% of the pool),
which represents a pari-passu interest in an $825.4 million first
mortgage loan.  The loan is secured by 45 extended stay, limited
service, and full service hotels across 16 states.  The properties
are primarily flagged as Residence Inns, which comprise 74% of the
portfolio by loan balance.  The loan was transferred to special
servicing in April 2010 due to imminent default.  Innkeepers USA
Trust, the loan sponsor, declared Chapter 11 bankruptcy on
July 19, 2010.  Five Mile Capital has submitted a competitive
"stalking horse bid" and is also providing debtor-in-possession
financing.  Five Mile Capital's proposal includes writing down a
portion of the A note; a partial paydown of the remaining A note;
writing off both the Mezzanine loan and B Note and an equity
infusion to cover Property Improvement Plans and reserve funds.
Bankruptcy hearings remain ongoing.  In October a 25% appraisal
reduction equal to $103.2 million was recognized pending the
outcome of a recently ordered appraisal.

The second largest specially serviced loan is the Greensboro Park
Loan ($108.9 million -- 3.7% of the pool), which is secured by a
485,047 square foot two-building office property located in
McLean, Virginia.  The property was 86% leased as of December 2009
compared to 91% at last review.  The loan transferred into special
servicing in March 2010 due to imminent default and is currently
less than one month delinquent.  The remaining 17 specially
serviced loans are secured by a mix of property types.  The
servicer has recognized a $148.2 million appraisal reduction for
11 of the specially serviced loans.  Moody's has estimated an
aggregate $214.4 million loss (31% expected loss on average) for
the specially serviced loans.

Moody's has assumed a high default probability for 27 loans
representing 21% of the pool.  Moody's aggregate estimated losses
for these loans is $122.1 million (20% expected loss based on a
50% probability default) from these troubled loans.

Moody's was provided with partial year 2009 operating results for
88% of the pool.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 112% compared to 111% at Moody's
prior review.  Moody's net cash flow reflects a weighted average
haircut of 11.5% to the most recently available net operating
income.  Moody's value reflects a weighted average capitalization
rate of 8.7%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.52X and 1.03X, respectively, compared to
1.29X and 0.91X 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.

The loan with a credit estimate is the 707 Broad Street Loan
($42 million -- 1.4% of the pool), which is secured by an office
building located in Newark, New Jersey.  The property was 98%
leased as of December 2009.  Property performance has remained
stable, but Moody's stressed the cash flow due to potential cash
flow volatility resulting from weak office market conditions and
the October 2010 lease expiration and subsequent holdover of the
State of New Jersey, which leases 58% of the net rentable area
(NRA).  Moody's current credit estimate is Baa3 compared to A2 at
Moody's last full review.

The top three performing conduit loans represent 15% of the
pool balance.  The largest loan is the PECO Portfolio Loan
($323 million -- 11% of the pool), which is secured by 39 cross-
collateralized retail properties totaling 4.25 million square
feet.  The properties are located across thirteen different
states, with the majority located in New York (31%), North
Carolina (14%) and Florida (13%) by portfolio net rentable area
(NRA).  Moody's LTV and stressed DSCR are 114% and 0.86X,
respectively, compared to 120% and 0.82X at last review.

The second largest loan is the Potomac Mills Loan ($246 million
-- 8.3% of the pool), which represents a pari-passu interest in
a $410 million first mortgage loan.  The loan is secured by a
1.5 million square foot retail center in Woodbridge, Virginia.
Anchor tenants include Costco, JC Penney Outlet and AMC Theatres.
Performance has improved since last review due to increased
revenue achievement.  Moody's LTV and stressed DSCR are 119% and
0.77X, respectively, compared to 121% and 0.74X at last review.

The third largest loan is the One Sansome Street Loan
($139.6 million -- 4.7% of the pool), which is secured by a Class
A office building located in the financial district of San
Francisco, California.  Property occupancy has declined to 77%
compared to 80% at last review.  Moody's LTV and stressed DSCR are
120% and 0.77, respectively, the same as last review.


LCM I: S&P Raises Ratings on Various Classes of Notes
-----------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, D-1, and D-2 notes from LCM I Ltd. Partnership, a
collateralized loan obligation transaction, which TCW Asset
Management Co. manages.  At the same time, S&P removed its ratings
on the class D-1 and D-2 notes from CreditWatch with positive
implications.  S&P also affirmed its ratings on the class A-1 and
A-2 notes.

The upgrades reflect the improved performance S&P has observed in
the underlying portfolio since January 2010, when S&P lowered its
ratings on the D-1 and D-2 notes following a review of the
transactions under S&P's updated criteria for rating corporate
collateralized debt obligations published in September 2009.

According to the Dec. 8, 2009, trustee report, the transaction was
holding approximately $3.9 million in defaulted obligations and
$10.7 million in underlying obligors with a rating, either by
Standard & Poor's or another rating agency, in the 'CCC+' or lower
range.  As of Sept. 8, 2010, the transaction was holding $0 in
defaulted obligations and $8.4 million in underlying obligors with
ratings in the 'CCC+' or lower range.  To date, the LCM I Ltd.
Partnership transaction has paid down the class A-1 and A-2 notes
to approximately 72% of their original outstanding balances,
including $39.7 million since the beginning of the year.

The reductions in the defaulted and 'CCC+' or lower assets, and
the $39.7 million paydown on the class A-1 and A-2 notes has
reduced the overall credit risk for the remaining outstanding
notes.  However, the class D-1 and D-2 notes pass the largest-
obligor default test, one of the supplemental stress tests S&P
introduced as part of its criteria update published in September
2009, at the 'B (sf)' rating category.  S&P partially base its
ratings on the class D-1 and D-2 notes on the application of the
largest-obligor default test.

Standard & Poor's will continue to review whether, in its view,
the ratings currently assigned to the notes remain consistent with
the credit enhancement available to support them and take rating
actions as S&P deem necessary.

                  Rating And Creditwatch Actions

                      LCM I Ltd. Partnership

                                 Rating
                                 ------
    Class                   To           From
    -----                   --           ----
    B                       AA+ (sf)     AA (sf)
    C                       AA (sf)      A+ (sf)
    D-1                     B+ (sf)      CCC+ (sf)/Watch Pos
    D-2                     B+ (sf)      CCC+ (sf)/Watch Pos

                        Ratings Affirmed

                     LCM I Ltd. Partnership

                 Class                   Rating
                 -----                   ------
                 A-1                     AAA (sf)
                 A-2                     AAA (sf)


LEGG MASON: Moody's Takes Rating Actions on Various Classes
-----------------------------------------------------------
Moody's has affirmed two and downgraded eight classes of Notes
issued by Legg Mason Real Estate CDO I, Ltd. due to the
deterioration in the credit quality of the underlying portfolio as
evidenced by an increase in the weighted average rating factor and
the sensitivity of the transaction to recovery rates.  The rating
action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation
transactions.

Issuer: Legg Mason Real Estate CDO I, Ltd.

  -- Cl. A1-T, Affirmed at Aaa (sf); previously on April 21, 2009
     Confirmed at Aaa (sf)

  -- Cl. A1-R, Affirmed at Aaa (sf); previously on April 21, 2009
     Confirmed at Aaa (sf)

  -- Cl. A2, Downgraded to A1 (sf); previously on April 21, 2009
     Downgraded to Aa2 (sf)

  -- Cl. B, Downgraded to Baa3 (sf); previously on April 21, 2009
     Downgraded to Baa1 (sf)

  -- Cl. C, Downgraded to Ba2 (sf); previously on April 21, 2009
     Downgraded to Baa3 (sf)

  -- Cl. D, Downgraded to B1 (sf); previously on April 21, 2009
     Downgraded to Ba2 (sf)

  -- Cl. E, Downgraded to B2 (sf); previously on April 21, 2009
     Downgraded to Ba3 (sf)

  -- Cl. F-1, Downgraded to Caa1 (sf); previously on April 21,
     2009 Downgraded to B1 (sf)

  -- Cl. F-2, Downgraded to Caa1 (sf); previously on April 21,
     2009 Downgraded to B1 (sf)

  -- Cl. G, Downgraded to Caa3 (sf); previously on April 21, 2009
     Downgraded to B3 (sf)

                        Ratings Rationale

Legg Mason Real Estate CDO I, Ltd., is a revolving cash CRE CDO
transaction backed by a portfolio of whole loans (88.7% of the
pool balance), commercial mortgage backed securities (6.4%), B-
note debt (3.5%), and mezzanine debt (1.3%).  As of the
September 27, 2010 Trustee report, the aggregate Note balance of
the transaction, including Income Notes and Class A-1R Undrawn
Amount, is $532 million, the same as at issuance, while the
transaction is passing all Principal Coverage Ratio and Interest
Coverage Ratio tests.

There are seven assets with par balance of $72.6 million (13.3% of
the current pool balance) that are classified as Defaulted
Securities as of the September 27, 2010 Trustee report.  Moody's
expects meaningful losses from those Defaulted Securities to occur
once they are realized.

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.  These parameters are typically modeled as actual
parameters for static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's have completed updated credit estimates for the non-
Moody's rated collateral.  For non-CUSIP collateral, Moody's is
eliminating the additional default probability stress applied to
corporate debt in CDOROM(R) v2.6 as Moody's expect the underlying
non-CUSIP collateral to experience lower default rates and higher
recovery compared to corporate debt due to the nature of the
secured real estate collateral.  The bottom-dollar WARF is a
measure of the default probability within a collateral pool.
Moody's modeled a bottom-dollar WARF of 7,927 (including Defaulted
Securities) compared to 3,350 at last review.  The distribution of
current ratings and credit estimates is: A1-A3 (3.6% compared to
3.7% at last review), Baa1-Baa3 (0.1% compared to 0.0% at last
review), Ba1-Ba3 (0.0% compared to 1.0% at last review), B1-B3
(1.8% compared to 94.4% at last review), and Caa1-C (94.5%
compared to 0.9% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of 2.3
years compared to 7.2 years at last review.  Moody's are modeling
the actual remaining WAL of the collateral pool in the current
review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool.  Moody's modeled a fixed WARR
of 53.8% (excluding Defaulted Securities) compared to 52.8% 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).  For
non-CUSIP collateral, Moody's is reducing the maximum over
concentration stress applied to correlation factors due to the
diversity of tenants, property types, and geographic locations
inherent in the pooled transactions.  Moody's modeled a MAC of
100.0% compared to 25.3% at last review.  The greater MAC is due
to higher default probability assets concentrated within a small
number of collateral names.

Moody's review incorporated CDOROM(R) v2.6, one of Moody's CDO
rating models, which was released on May 27, 2010.

The cash flow model, CDOEdge(R) v3.2, was used to analyze the cash
flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes.  However,
in many instances, a change in key parameter assumptions in
certain stress scenarios may be offset by a change in one or more
of the other key parameters.  Rated notes are particularly
sensitive to changes in recovery rate assumptions.  Holding all
other key parameters static, changing the recovery rate assumption
down from 53.8% to 43.6% or up to 64.0% would result in average
rating movement on the rated tranches of 0 to 9 notches downward
or 0 to 6 notches upward, respectively.

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 stressed macroeconomic environment and
continuing weakness in the commercial real estate and lending
markets.  Moody's currently views the commercial real estate
market as stressed with further performance declines expected in a
majority of property sectors.  The availability of debt capital is
improving with terms returning towards market norms.  Job growth
and housing price stability will be necessary precursors to
commercial real estate recovery.  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's largest
economies, returning to trend growth rate with elevated fiscal
deficits and persistent unemployment levels.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.


LEHMAN BROS: S&P Downgrades Ratings on Nine 2006-LLF C5 Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on nine
classes of commercial mortgage pass-through certificates from
Lehman Bros.  Floating Rate Commercial Mortgage Trust 2006-LLF C5,
a U.S. commercial mortgage-backed securities transaction.
Concurrently, S&P affirmed its ratings on four other classes from
this transaction.

S&P's rating actions follow its analysis of the transaction, which
included the revaluation of the collateral securing the remaining
eight floating-rate loans in the pool (five of which are currently
with the special servicers) and one lodging real estate owned
asset.  All of the loans are indexed to one-month LIBOR.  Due to
revised asset valuations, lodging properties were the primary
driver of S&P's downgrades, as this asset type constitutes 80.8%
of the pooled trust balance ($548.1 million) according to the
Oct. 15, 2010 trustee remittance report.  Based on S&P's analysis,
its lodging property valuations have declined, on average, by
32.1% from the levels S&P assessed in its last review dated
May 27, 2009.  The other two asset types are multifamily
($69.6 million, 10.2%) and office properties ($60.8 million,
9.0%).

The class X-2 and X-FLP certificates are interest-only
certificates.  S&P affirmed its ratings on these two classes based
on its current criteria.

S&P previously lowered its rating on class L to 'D (sf)' on
March 3, 2009, due to ongoing interest shortfalls.  According to
the October 2010 trustee remittance report, class L has
accumulated outstanding interest shortfalls of $314,420.

                       Lodging Collateral

Lodging properties secure four loans in the pool totaling $548.1
million (80.8% of the pooled trust balance).  These properties are
in Lake Buena Vista, Fla. (47.1% of the pooled trust balance);
Manhattan (19.1%); Kailua-Kona, Hawaii (8.3%); and Lansdowne, Va.
(6.3%).  S&P based its hotel analyses, in part, on a review of the
borrowers' operating statements for the full year 2009, operating
statements for the interim 2010 (where available), the borrowers'
2010 budgets, and Smith Travel Research reports.  S&P noted that
reduced business and leisure travel, in its opinion, significantly
affected the performance of lodging collateral in 2009 compared
with 2008.  S&P's analysis also considered improved conditions in
some of the local lodging markets that have occurred for year-to-
date 2010.  According to STR, the Orlando, Fla., and New York
lodging markets posted 1.0% and 14.7% increases, respectively, in
revenue per available room for the first nine months of 2010
compared with 2009, whereas the general U.S. hotel industry
reported a 4.5% increase in RevPAR for the same period.

                    The Largest Lodging Loan

The Walt Disney World Swan & Dolphin loan, the largest loan in the
pool, is secured by two upscale full-service convention and resort
hotels totaling 2,267 rooms in Lake Buena Vista, Fla., which is
near Orlando.  The loan has a trust and whole-loan balance of
$330.0 million that is split into a $319.6 million (47.1% of the
pooled trust balance) senior pooled component and a $10.4 million
subordinate nonpooled component that supports the class WSD raked
certificate (not rated by Standard & Poor's).  The master
servicer, Wells Fargo Bank N.A., reported an in-trust debt service
coverage of 8.63x for year-end 2009 and occupancy of 74.2% for the
12-month ended July 31, 2010.  S&P's adjusted valuation, which
yielded a stressed in-trust loan-to-value ratio of 120.4%, is down
30.4% from its last review.  The decline is due primarily to a
drop in the average daily rate, which reduced the borrower's
reported year-to-date July 2010 net operating income by 24.6% from
the same period in 2009.  The loan matures on Sept. 12, 2011, and
has two 12-month extension options remaining.

          Lodging Exposures With The Special Servicers

One lodging loan and one lodging REO asset are with the special
servicers.  Details are:

The Sheraton Keauhou Bay Resort & Spa asset, the third-largest
exposure in the pool, has a trust balance of $56.0 million
(8.3% of pooled trust balance).  The 521-room full-service
resort hotel property in Kailua-Kona, Hawaii, was transferred
to the special servicer, TriMont Real Estate Advisors Inc., on
Aug. 18, 2008, and became REO on Jan. 1, 2010.  An appraisal
reduction amount of $32.4 million is in effect against the asset.
The master servicer, Wells Fargo, indicated that it will revise
the ARA downward based on an Oct. 5, 2009, appraisal value of
$39.2 million.  Wells Fargo stated that it expects the revised
ARA to be reflected as early as on the November 2010 trustee
remittance report.  According to TriMont, the property is
currently not generating sufficient cash flow to pay debt service.
The reported occupancy was 45.5% for the 12 months ended Aug. 31,
2010.  TriMont indicated that the property is currently under
contract for sale.  S&P expects a significant loss upon the
eventual resolution of this asset.

The other lodging loan in special servicing, the National
Conference Center loan, is secured by a 1.2-million-sq.-ft.
conference facility in Lansdowne, Va., that includes 917
guestrooms and 265,000 sq. ft. of meeting space.  The loan,
the fourth-largest loan in the pool, has a trust balance of
$42.7 million (6.3% of the pooled trust balance) and a whole-loan
balance of $64.7 million.  The loan was transferred to the special
servicer, TriMont, on July 22, 2010, due to imminent default.  The
loan matured on Aug. 9, 2010, and it is S&P's understanding that
it did not meet the DSC test necessary for the borrower to
exercise its remaining one one-year extension option.  TriMont
stated that it is exploring various workout strategies with the
borrower.  An updated September 2010 appraisal value was in excess
of the trust balance.  The master servicer reported an in-trust
DSC of 1.77x for year-end 2009 and occupancy of 27.1% for the 12
months ended Aug. 31, 2010.  S&P's adjusted valuation, which
yielded a stressed in-trust LTV ratio of 214.1%, has declined
67.3% since its last review due to lower-than-expected occupancy.

                      Multifamily Collateral

Multifamily properties secure three loans totaling $69.6 million
(10.2% of the pooled trust balance).  Details on these three loans
are:

The Praedium Rental Portfolio I, II, and III loans, which are not
cross-collateralized or cross-defaulted, have a $79.7 million
whole-loan balance that consists of senior pooled components
totaling $69.6 million (10.2% of the pooled trust balance) and
subordinate nonpooled components totaling $10.1 million that are
raked to the class PR1-1, PR1-2, PR2, PR3-1, and PR3-2
certificates.  Standard & Poor's does not rate the "PR" raked
certificates.  In addition, the equity interests in the borrowers
of the whole loans secure mezzanine debt totaling $65.3 million.
These loans are secured by 50 low-income multifamily apartment
buildings with 1,369 units in the Morningside Heights, Hamilton
Heights, and East Harlem markets of northern Manhattan.  The loans
were transferred to the special servicers, TriMont and Aegon USA
Realty Advisors LLC, on Aug. 17, 2010, due to imminent maturity
default.  The related borrowers did not pay off their loans on
their Sept. 9, 2010, maturities.  The special servicers stated
that they are exploring various workout strategies with the
related borrowers.  Wells Fargo reported in-trust DSCs for the
three loans ranging from 3.79x to 5.32x for year-end 2009 and
occupancies at the collateral properties ranging from 89.8% to
95.7% as of September 2010.  S&P's adjusted valuations, which
yielded an average stressed in-trust LTV ratio of 124.0%, is down,
on average, 16.5% since its last review, primarily due to higher-
than-expected operating expenses.

                        Office Collateral

Office properties secure two loans totaling $60.8 million (9.0% of
the pooled trust balance).  Details on these two loans are:

The Continental Grand II loan, the fifth-largest loan in the pool,
is secured by a 238,400-sq.-ft. class A office building in El
Segundo, Calif.  The loan has a trust and whole-loan balance of
$36.0 million (5.3% of the pooled trust balance).  In addition,
the equity interests in the borrower of the whole loan secure
mezzanine debt totaling $22.0 million.  The loan, which is
current, was transferred to TriMont on June 8, 2010, due to
imminent default.  The borrower indicated that it expects cash
flow at the property to be insufficient to cover debt service due
to a drop in occupancy to 37.9%.  The decline in occupancy follows
the departure of a major tenant (occupying 42.5% of the net
rentable area) from the property upon its June 30, 2010, lease
expiration.  TriMont stated that the loan has since been modified
(on Sept. 10, 2010) and is expected to be returned to the master
servicer as early as the November 2010 trustee remittance report.
The loan modification included a maturity date extension to
Aug. 6, 2011, three one-year extension options, and the funding of
certain reserves.  Wells Fargo reported an in-trust DSC of 13.28x
for year-end 2009 and occupancy of 55.0% as of September 2010.
S&P's adjusted valuation, which yielded a stressed in-trust LTV
ratio of 168.2%, is down 41.7% since its last review, due
primarily to lower-than-expected occupancy.

The 30 Montgomery Street loan, the seventh-largest loan in the
pool, is secured by a 292,200-sq.-ft. class B+ office building in
Jersey City, N.J.  The loan has a trust and whole-loan balance of
$24.8 million (3.7%).  Wells Fargo reported an in-trust DSC of
8.71x for year-end 2009 and occupancy of 62.2% as of June 2010.
S&P's adjusted valuation, which yielded a stressed in-trust LTV
ratio of 134.5%, is down 25.2% since S&P's last review, due
primarily to lower-than-expected in-place rental rates and
occupancy.  The loan matures on June 9, 2011, and has no extension
options remaining.

                         Ratings Lowered

Lehman Bros. Floating Rate Commercial Mortgage Trust 2006-LLF C5
          Commercial mortgage pass-through certificates

                   Rating
                   ------
   Class    To               From       Credit enhancement (%)
   -----    --               ----       ----------------------
   B        AA- (sf)         AA+ (sf)                    49.96
   C        BBB- (sf)        AA (sf)                     42.05
   D        BB+ (sf)         AA- (sf)                    37.02
   E        B+ (sf)          A- (sf)                     30.32
   F        B- (sf)          BBB (sf)                    26.44
   G        CCC+ (sf)        BB+ (sf)                    19.80
   H        CCC (sf)         BB (sf)                     13.78
   J        CCC (sf)         BB- (sf)                    13.24
   K        CCC- (sf)        B+ (sf)                      8.40

                        Ratings Affirmed

Lehman Bros. Floating Rate Commercial Mortgage Trust 2006-LLF C5
          Commercial mortgage pass-through certificates

    Class         Rating              Credit enhancement (%)
    -----         ------              ----------------------
    A-2           AAA (sf)                             58.58
    X-2           AAA (sf)                               N/A
    X-FLP         AAA (sf)                               N/A
    L             D (sf)                                 N/A

                      N/A - Not applicable.


LOCAL INSIGHT: Moody's Downgrades Ratings on Two Classes of Notes
-----------------------------------------------------------------
Moody's downgraded two classes of notes issued in two series of
the Local Insight Media securitization transaction, leaving the
notes under review for further possible downgrade.  The
transaction is a securitization of telephone directory publishing
businesses (primarily Yellow Pages) of three subsidiaries of Local
Insight Media, Inc.: CBD Media Finance LLC, a publisher of print
and online directories in the greater Cincinnati metropolitan
area, ACS Media Finance LLC, a publisher of print and online
directories in Alaska, and HYP Media Finance LLC, a publisher of
print and online directories in Hawaii.  Essentially all assets of
CBD, ACS and HYP were transferred to securitization entities,
which issued fixed rate notes supported by the assets.

The complete rating actions are:

Issuer: Local Insight Media Finance LLC, Series 2007-1

  -- Class A-2, Downgraded to B1 (sf), under review for possible
     downgrade; previously on June 9, 2010, Baa3 (sf), under
     review for possible downgrade

Issuer: Local Insight Media Finance LLC, Series 2008-1

  -- Class A-2, Downgraded to B1 (sf), under review for possible
     downgrade; previously on June 9, 2010, Baa3 (sf), under
     review for possible downgrade

                        Ratings Rationale

The rating actions reflect the declining collections (revenue),
net securitizable cash flow (cash flow after expenses available to
service debt) and Debt Service Coverage Ratio.  Annualized nine-
month collections as of September 30, 2010 were more than 18.4%
lower than total collections for the 12-month period ending
September 30, 2009, while the 12-month net securitizable cash flow
was 12% lower than the net securitizable cash flow for the 12-
month period ending September 30, 2009.  The 12-month rolling
average DSCR was 1.62x, which is substantially lower than the
original DSCR of approximately 2.1x.  As a result of the declining
net securitizable cash flow, the leverage ratio (senior
securitized debt divided by last 12 months net securitizable cash
flow) was 8.94x as of September 30 2010, significantly higher than
the original 7.4x.  In July 2010 a partial amortization event
occurred due to the leverage ratio exceeding the relevant trigger
level of 7.82x.  As the partial amortization event continues, all
residual cash is allocated to senior notes until the ratio is
reduced below the trigger level.

In addition, in September 2010, Moody's lowered the corporate
family rating of affiliate Local Insight Regatta Holdings, parent
of The Berry Company, to Ca.  Berry as the transaction manager for
the securitization plays a significant role in utilizing issuer
LIM's assets to generate cash flow.  The Ca rating of Regatta
reflects a high probability of default, which in turn suggests an
increased potential that the transaction manager could default in
its duties.

Moody's notes that LIM's business has come under increased
pressure in recent quarters due to recessionary conditions, which
have particularly affected the small and medium size businesses
who are the main users of search engine print and internet-based
advertising.  In addition, while LIM has an internet strategy that
complements the traditional yellow pages business, increasing use
of internet by consumers may be a contributing factor to LIM's
declining performance.  LIM's assets (CBD, ACS, HYP) are based in
non-urban or less competitive markets, however Moody's believe
that these markets may now be experiencing pressures that
previously affected major markets dominated by larger players,
pressures which ultimately forced these larger players into
bankruptcy.

The notes remain under review for further possible downgrade due
to the negative performance trends.  During the review period
Moody's will observe performance of the transaction with respect
to collections, net securitizable cash flow, DSCR and leverage.

Principal Methodology.  Moody's analyses of whole business
securitizations includes cash flow simulation analysis and the
assessment of the ability of the net cash flows to make timely
interest payments on the notes and ultimate repayment of the
principal by the legal maturity date.  Moody's identify key
drivers of the cash flow and estimate their expected values over
the course of the transaction as well as the probability
distribution around these values based on the analysis of the
historical collateral performance trends.  The simulated revenues
are then fed through the payment waterfall to assess performance
of the notes under different expected and stressed scenarios.

Parameters which were incorporated in projecting ongoing cash
flows for LIM included (i) annual growth/decline of print revenue,
(ii) the default risk of Berry, and the potential adverse impact
on the transaction's cash flows.  Revenue streams, were derived
from historical data and modeled using triangular distributions.
In addition, a corporate family rating of Local Insight Regatta
Holdings, Inc., the parent of Berry, was incorporated into the
analysis to derive the corresponding probability of its default.
In certain cash flow runs, Moody's assume that Berry's default
results in a 25%-50% reduction of revenues for at least two years,
followed by their restoration to the previous levels.

The simulated cash flows were used to make all required payments
per the transaction's priority of payments, including interest and
principal payments due on the notes.  A resulting loss of yield to
investors, if any, was calculated.  Other methodologies and
factors that may have been considered in the process of rating
this issuer can also be found on Moody's website.

The main sources of uncertainty for this transaction include the
timing of economic recovery, as the weak economic environment
adversely affects demand for advertising by small and medium-sized
businesses.  Overall, Moody's central global scenario remains
"hook-shaped" for 2010 and 2011; overall Moody's expect a sluggish
recovery in most of the world largest economies, returning to
trend growth rate with elevated fiscal deficits and persistent
unemployment levels.

The ratings could be downgraded further if the average revenue
declines by more than 17% in each of the next two years.

Moody's Investors Service received and took into account one or
more third party due diligence reports on the underlying assets or
financial instruments in this transaction, and the due diligence
reports had a neutral impact on the rating.


MAGNOLIA FINANCE: S&P Downgrades Ratings on Two Classes of Notes
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class D and E notes issued by Magnolia Finance II PLC's series
2007-2, a synthetic collateralized debt obligation transaction, to
'D (sf)'.

The lowered ratings follow the notice dated Sept. 30, 2010, that
indicated the notes experienced interest shortfalls caused by
interest shortfalls in the underlying reference obligations.

                         Ratings Lowered

                     Magnolia Finance II PLC
                          Series 2007-2

                Class         To        From
                -----         --        ----
                D             D (sf)    CCC- (sf)
                E             D (sf)    CCC- (sf)


MARICOPA COUNTY: Moody's Cuts Rating to $10.4 Mil. Notes to 'B3'
----------------------------------------------------------------
Moody's Investors Service has downgraded to B3 from Ba3 the rating
on approximately $10.4 million Maricopa County (Arizona)
Industrial Development Authority, Multifamily Housing Revenue
Bonds (Sun King Apartments Project), Series 2000 A and B.  The
Series 2000 B bonds have been retired in June of 2001 and no
longer outstanding.  Further, initial issuance included the
subordinate Series 2000 C which is not rated by Moody's.
Approximately $3.6 million of the Series 2000 C remains
outstanding.

Ratings Rationale: The rating downgrade is based on the weak
financial performance of the properties and soft local real-estate
market.  The Negative outlook reflects the possibility of further
performance deterioration.

Legal Security: The bonds are secured by revenues derived from
operations of the Sun King and Casa Castillo projects located in
Scottsdale and Phoenix, Arizona, respectively, and containing 375
units.  The bonds are also secured by other funds pledged under
the indenture.

                            Strengths

  -- Owner/management support and oversight

  -- Improving occupancy rate

  -- Fully funded debt service reserve funds and renewal and
     replacement fund

                            Challenges

  -- Weak revenue stream and debt service coverage
  -- Soft local real-estate market

Recent Developments:

Strong competition from other developments forced management to
offer high concessions to retain tenants which together with
vacancies have resulted in weak revenue steam and lower debt
service coverage.  Based on audited financial statements, debt
service coverage on the senior Series 2000 A dropped from 1.26x in
2009 to 0.90x in 2010.  Occupancy has improved slightly in recent
months reaching 90% in September but given the soft local real-
estate market, it's unlikely that management will be able to raise
rents any time in the near future to improve performance.  There
is no excess operating revenue to meet potential required
maintenance and repairs; however, repair and renewal fund is fully
funded at $134,850.  The owner continues to support operating
shortfalls but that support is not a legal/contractual obligation
and may be pulled at anytime.  Both senior and subordinate debt
service reserve fund have not been tapped and remain fully funded
at maximum annual debt service.

                             Outlook

The outlook on the bonds remains Negative due to continued
weakness of the Phoenix / Scottsdale housing markets and possible
further project performance deterioration.

                What Could Change the Rating -- Up

  -- Significant increase in occupancy and rents charged that
     translates into an increase in net operating income and debt
     service coverage ratio.

               What Could Change the Rating -- Down

  -- Tapping of debt service reserve fund
  -- Further decline in debt service coverage
  -- Discontinuance of owner financial support


MERRILL LYNCH: DBRS Upgrades Class F Rating From 'BB' to 'BBB'
--------------------------------------------------------------
DBRS has upgraded these seven classes of Merrill Lynch Financial
Assets Inc., Commercial Mortgage Pass-Through Certificates, Series
2004-Canada 14:

Class B from AA to AA (high)
Class C from A to A (high)
Class D-1 from BBB to A (low)
Class D-2 from BBB to A (low)
Class E-1 from BBB (low) to BBB (high)
Class E-2 from BBB (low) to BBB (high)
Class F from BB (high) to BBB

In addition, DBRS has confirmed these eleven classes:

Class A-1 at AAA
Class A-2 at AAA
Class XP-1 at AAA
Class XP-2 at AAA
Class XC-1 at AAA
Class XC-2 at AAA
Class G at BB
Class H at BB (low)
Class J at B (high)
Class K at B
Class L at B (low)

All trends for the rated classes of this transaction are Stable.

DBRS does not rate the $5.1 Million first loss piece, Class M.

The pool collateral has been reduced by 46.5% with the current
pool balance at approximately $282.9 million.

The rating action reflects a strong outlook for the pool, with the
successful maturity of 19 loans since issuance (34.9% of the pool
at issuance).  There is one defeased loan, Prospectus ID#27,
Crowsfoot Square, with 1.12% of the current pool balance.
Overall, financial performance for the remaining collateral is
strong, with a weighted-average debt service coverage ratio
(WADSCR) of 1.86x and a weighted-average loan-to-value (WALTV) of
61.2%.  All 32 of the loans remaining in the pool are current.

There are three loans on the servicer's watchlist and DBRS has not
placed any of these loans on the DBRS HotList.

DBRS has applied a net cash flow (NCF) stress scenario of 20%
across all the loans in the pool and the resulting DBRS required
credit enhancement levels, when compared to the current credit
enhancement levels to the bonds, warrant the ratings upgrades.

DBRS continues to monitor this transaction on a monthly basis in
the Global CMBS Monthly Surveillance report, which can provide
more detailed information on the individual loans in the pool.


MERRILL LYNCH: DBRS Upgrades Class H Rating From 'BB' to 'BBB'
--------------------------------------------------------------
DBRS has upgraded these five classes of Merrill Lynch Financial
Assets Inc., Commercial Mortgage Pass-Through Certificates, Series
2001-Canada 6:

Class E from AA (low) to AAA
Class F from A (low) to AA
Class G from BBB to A
Class H from BB (low) to BBB
Class J from B (high) to BB

In addition, DBRS has confirmed these five classes:

Class A-2 at AAA
Class B at AAA
Class C at AAA
Class D at AAA
Class X at AAA

All trends for the rated classes of this transaction are Stable.

DBRS does not rate the $3.98 Million first loss piece, Class K.

The pool collateral has been reduced by 47.5% with the current
pool balance at approximately $139.4 million.

The rating action reflects a strong outlook for the pool,
primarily because of the successful maturity of 17 loans since
issuance (35.48% of the pool at issuance) and the defeasance of
five loans, including two of the loans currently in the Top Ten
for the transaction, Prospectus ID#12, The National Building,
representing 4.42% of the current pool balance, and Prospectus
ID#13, Shaughnessy Village, representing 4.10% of the current pool
balance.  Overall, financial performance for the remaining
collateral is strong, with a weighted-average debt service
coverage ratio (WADSCR) of 1.62x and a weighted-average loan-to-
value (WALTV) of 69.9%.  In addition, the weighted-average debt
yield (WADY) is strong at 12.56%.  All 23 loans remaining in the
pool are current.

There is only one loan on the servicer's watchlist, Prospectus
ID#40, Elmira Road, representing 0.71% of the current pool
balance.  The loan's collateral is a two-building industrial
property with a combined 40,427 sf of rentable space, located in
Guelph, Ontario, approximately 30 kilometers northeast of
Kitchener, Ontario.  The loan is on the servicer's watchlist for a
low Q2 2010 DSCR of 0.40x.  The property has experienced
fluctuations in occupancy over the last two years after losing the
largest tenant (38% of the NRA) in January 2010.  Part of the
space was re-leased, but overall occupancy had fallen to 76% as of
June 30, 2010, from 100% at YE2009.  15% of the NRA is set to
expire in July 2011; the servicer reports that the borrower is in
discussions with that tenant to renew and expand into the 24%
currently vacant at the property.  Also affecting cash flows at
the property, the property's largest tenant with 16% of the NRA,
was granted a 70% reduction in their rent at lease expiry of
November 2009 and is now occupying their space on a month to month
basis with a 90 day exit clause.  DBRS will continue to monitor
this loan for occupancy and DSCR issues; the loan remains current.

There are no loans on the DBRS HotList.

DBRS has applied a net cash flow (NCF) stress scenario of 20%
across all the loans in the pool and the resulting DBRS required
credit enhancement levels, when compared to the current credit
enhancement levels to the bonds, warrant the ratings upgrades.

DBRS continues to monitor this transaction on a monthly basis in
the Global CMBS Monthly Surveillance report, which can provide
more detailed information on the individual loans in the pool.


MERRILL LYNCH: Moody's Reviews Ratings on 2006-C2 Certs.
--------------------------------------------------------
Moody's Investors Service placed 15 classes of Merrill Lynch
Mortgage Trust 2006-C2, Commercial Mortgage Pass-Through
Certificates, Series 2006-C2 on review for possible downgrade:

  -- Cl. AM, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Aug. 22, 2006 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. AJ, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Aa3 (sf)

  -- Cl. B, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to A2 (sf)

  -- Cl. C, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to A3 (sf)

  -- Cl. D, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Baa2 (sf)

  -- Cl. E, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Ba1 (sf)

  -- Cl. F, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Ba2 (sf)

  -- Cl. G, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to B2 (sf)

  -- Cl. H, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to B3 (sf)

  -- Cl. J, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Caa1 (sf)

  -- Cl. K, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Caa1 (sf)

  -- Cl. L, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Caa2 (sf)

  -- Cl. M, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Caa2 (sf)

  -- Cl. N, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Caa3 (sf)

  -- Cl. P, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 6, 2009 Downgraded to Caa3 (sf)

The classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from realized and
anticipated losses from specially serviced and troubled loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated February 6, 2009.

                   Deal And Performance Summary

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 15% to $1.3 billion
from $1.5 billion at securitization.  The Certificates are
collateralized by 124 mortgage loans ranging in size from less
than 1% to 8% of the pool.

Forty-eight loans, representing 45% 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 monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Two loans have been liquidated from the trust since
securitization, resulting in a $6.2 million loss (61% loss
severity).  A $7.1 million loss has also been incurred due to the
modification of two loans that remain in the pool.  Currently 15
loans, representing 13% of the pool, are in special servicing.
The largest specially serviced loan is the Mall at Whitney Field
loan ($74.5 million -- 5.7%), which was transferred to special
servicing in April 2009 The master servicer has recognized an
appraisal reductions of $45.5 million for this loan and an
aggregate $35.3 million appraisal reduction for 11 of the
specially serviced loans.

Based on the most recent remittance statement, Classes H through Q
have cumulative interest shortfalls totaling $1.4 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 review will focus on potential losses from specially
serviced and troubled loans and the performance of the overall
pool.


MERRILL LYNCH: Moody's Reviews Ratings on Three Classes of Certs.
-----------------------------------------------------------------
Moody's Investors Service placed three classes of Merrill Lynch
Mortgage Loans, Inc., Commercial Mortgage Pass-Through
Certificates 2001-Canada 5 on review for possible downgrade:

  -- Cl. C, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 2, 2010 Confirmed at A1 (sf)

  -- Cl. D, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 2, 2010 Downgraded to Ba2 (sf)

  -- Cl. E, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Sept. 2, 2010 Downgraded to B2 (sf)

The classes were placed on review for possible downgrade due to an
anticipated increase in interest shortfalls.  Classes G and F are
currently experiencing interest shortfalls.  Midland Loan
Services, Inc., the master servicer for the transaction, has
indicated that interest shortfalls will impact additional classes
as of the November distribution statement due to the recovery of
servicing advances related to two liquidated loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated September 2, 2010.

                   Deal And Performance Summary

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 43% to
$141.2 million from $248.7 million at securitization.  The
Certificates are collateralized by 32 mortgage loans ranging in
size from less than 1% to 12% of the pool.  Six loans,
representing 15% of the pool, have defeased and are collateralized
with Canadian Government securities.

Ten loans, representing 35% 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 monthly reporting package.  Most of the loans
which are included on the watchlist mature within the next four
months.

Two loans have been liquidated from the pool since securitization,
resulting in an aggregate $8.7 million loss.  The realized loss
resulted in a 100% loss to Classes H through K and a 67% loss to
class G.  Currently one loan, representing 5% of the pool, is
in special servicing.  The master servicer has recognized a
$3.3 million appraisal reduction for the specially serviced loan.

Based on the most recent remittance statement, Classes G and F
have experienced cumulative interest shortfalls totaling $156,108.
It is expected that interest shortfalls will increase and affect
additional classes as of the November remittance statement due to
Midland's intent to recover approximately $247,000 in servicer
advances related to two hotel properties which were liquidated in
May 2010 for a 100% loss.  It is expected that these advances will
be fully recouped over the next two to three months.

Moody's review will focus on the impact of increased interest
shortfalls, potential losses from specially serviced and troubled
loans and the performance of the overall pool.


MICHIGAN FINANCE: S&P Assigns 'BB+' Rating on 2010 Revenue Bonds
----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its 'BB+' long-term
rating to Michigan Finance Authority's series 2010 public school
academy limited obligation revenue and revenue refunding bonds
issued on behalf of Woodward Academy.  The outlook is stable.

"The rating reflects S&P's view of the academy's recent history of
steady enrollment declines, as a result of administrative turnover
and poor marketing efforts, lack of an enrollment waiting list,
and rapid executive turnover, which caused a leadership vacuum and
weakened the academy's ability to attract and educate students,"
said Standard and Poor's credit analyst Caroline West.  "Further
pressuring the rating is the lack of a management succession plan,
which S&P believes is crucial given the board's recent difficulty
in identifying and retaining leadership, and potential state aid
reductions, given the financial pressures facing the state of
Michigan."

The academy will use proceeds for two purposes: To refinance an
outstanding 2003 promissory note and extend the maturity; and to
fund capital and energy improvements.  S&P understands that the
academy has no additional debt plans in the near term.
The school is located in downtown Detroit and draws the vast
majority of its students from within city borders.  The school
opened in 1996 with a five-year charter from Central Michigan
University.  The school remains in the same facilities, a former
mental health hospital built in the 1950s.  The site includes
offices, an auditorium, a cafeteria, a small gymnasium, classroom
space, and considerable storage.  On the fall count day of the
2010-2011 academic year, the student count in the K-8 facility
totaled 565.


MICHIGAN STRATEGIC: S&P Downgrades Rating on Revenue Bonds to 'BB'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its long-term rating
and underlying rating to 'BB' from 'BBB-' on Michigan Strategic
Fund's series 2006 and 1998 revenue bonds issued for Clark
Retirement Community Inc., based on decreased liquidity coupled
with continued and accelerating operating deficits.

While operating stress and deficits have persisted over several
years, nonoperating income improved in fiscal 2010, cutting the
bottom-line losses; however, coverage of maximum annual debt
service was in Standard & Poor's view still slim.  Furthermore,
Clark's liquidity levels, which have historically been light,
decreased to levels more reflective of the speculative-grade-
category ratings.

The 'BB' rating reflects Standard & Poor's view of Clark's history
of negative operating performance, partly offset in most years by
contributions and investment income; limited liquidity; and
improved, but still limited adjusted debt coverage.  Also
affecting the rating is the negative pressure on assisted-living
occupancy levels, particularly at the Keller Lake facility.

Offsetting credit factors include Standard & Poor's assessment of
Clark's good competitive position, demonstrated by historically
solid independent-living occupancy rates and an active waiting
list, particularly for the Franklin campus independent-living
units, although there is competition in the market from several
providers; improved and sustained occupancy in the independent-
living and skilled-nursing units, with both remaining fairly
strong despite general economic and housing pressure nationwide;
and a stable management team that is implementing new service
offerings in an effort to diversify revenues and improve operating
results, although operating results over the past few fiscal years
have missed budgeted expectations.

"The stable outlook reflects S&P's view of Clark's continued
effort to implement new service offerings that are expected to
diversify the revenue base and ultimately improve operations,"
said Standard & Poor's credit analyst Stephen Infranco.  "While
operating losses continue, S&P believes there is more stability at
the lower rating level to implement the changes needed to improve
operations over time," said Mr. Infranco.

Standard & Poor's could consider a negative outlook or lower
rating if large operating deficits continue or if liquidity falls
below current levels.  Standard & Poor's does not expect a higher
rating over the outlook period given the current operating stress
and limited liquidity levels.

Securing the bonds is Clark's gross revenue pledge.  As of
April 30, 2010, Clark had approximately $23 million in long-term
debt.


MORGAN STANLEY: Moody's Takes Rating Action on Class A Notes
------------------------------------------------------------
Moody's Investors Service announced this rating action on Morgan
Stanley ACES SPC Series 2007-28, a collateralized debt obligation
transaction referencing a static portfolio of 58 synthetic credit
corporate exposures.

  -- US$15,000,000 Class A Secured Floating Rates Notes due
     2012, Upgraded to B2 (sf); previously on March 11, 2009
     Downgraded to Caa1 (sf)

                         Rating Rationale

Moody's explained that the rating action taken is the result
shortened time to maturity and adequate remaining subordination of
the CSO tranche.  There have been a large number of credit events
since the last rating action, but the credit quality of the
remaining portfolio has improved.

The underlying portfolio of synthetic credit securities references
senior secured loans.  The 10-year weighted average rating factor
of the portfolio, excluding credit events, is 2691, equivalent to
B2.  This compares to a 10-year WARF of 3351 from the last rating
action, also excluding credit events.  Since the last rating
action, there have been credit events on Charter Communications
Operating, LLC., General Growth Properties, Inc., HLI Operating
Company, Inc., Dex Media East, LLC, Dex Media West LLC, Six Flags
Theme Parks, Inc., Lear Corporation, Accuride Corporation, Metro-
Goldwyn-Mayer Inc. The CSO notes have a remaining life of 1.4
years and remaining credit enhancement of approximately 6%, down
from approximately 9% as of the last rating action.

In the process of determining the rating action, Moody's took into
account the results of a number of sensitivity analyses and stress
scenarios:

(1) Removal of forward-looking measures - The notching adjustment
    on each entity's rating due to credit watch or negative
    outlook was removed.  The result of this run was one notch
    better than the base case.

(2) Use of Market Implied Ratings - MIRs were used in place of the
    corporate fundamental ratings to derive the default
    probability of each corporate name in the reference portfolio.
    The gap between an MIR and a Moody's corporate fundamental
    rating is an indicator of the extent of the divergence of
    credit view between Moody's and the market. The result of this
    run was two notches worse than the base case.

(3) Reduction of time to maturity -- Time to maturity was reduced
    by six months, all other things being equal.  The result of
    this run was three notches better than the base case.

(4) Stress on largest industry group -- All entities in the Hotel,
    Gaming, and Leisure sector, the largest sector concentration,
    representing 15% of the portfolio notional, were notched down
    by one.  The result of this run was one notch worse than the
    base case.

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.

Moody's analysis for this transaction is based on CDOROMv2.6.
This model is available on moodys.com under Products and Solutions
- Analytical models, upon return of a signed free license
agreement.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Corporate Synthetic
Obligations", key model inputs used by Moody's in its analysis may
be different from the manager/arranger's reported numbers.  In
particular, rating assumptions for all publicly rated corporate
credits in the underlying portfolio have been adjusted for "Review
for Possible Downgrade", "Review for Possible Upgrade", or
"Negative Outlook".

Moody's did not run a separate loss and cash flow analysis other
than the one already done using the CDOROM model.  For a
description of the analysis, refer to the methodology and the
CDOROM user guide on Moody's website.

Moody's also ran a stress scenario defaulting all entities in the
reference portfolio rated Caa1 and below.  The result of this run
was four notches worse than the base case.

Moody's analysis of corporate CSOs is subject to uncertainties,
the primary sources of which includes complexity, governance and
leverage.  Although the CDOROM model capture many of the dynamics
of the Corporate CSO structure, it remains a simplification of the
complex reality.  Of greatest concern are (a) variations over time
in default rates for instruments with a given rating, (b)
variations in recovery rates for instruments with particular
seniority/security characteristics and (c) uncertainty about the
default and recovery correlations characteristics of the reference
pool.  Similarly on the legal/structural side, the legal analysis
although typically based in part on opinions (and sometimes
interpretations) of legal experts at the time of issuance, is
still subject to potential changes in law, case law and the
interpretations of courts and (in some cases) regulatory
authorities.  The performance of this CSO is also dependent on on-
going decisions made by one or several parties, including the
Manager and the Trustee.  Although the impact of these decisions
is mitigated by structural constraints, anticipating the quality
of these decisions necessarily introduces some level of
uncertainty in Moody's assumptions.  Given the tranched nature of
Corporate CSO liabilities, rating transitions in the reference
pool may have leveraged rating implications for the ratings of the
Corporate CSO liabilities, thus leading to a high degree of
volatility.  All else being equal, the volatility is likely to be
higher for more junior or thinner liabilities.

The base case scenario modeled fits into the central macroeconomic
scenario predicted by Moody's of a sluggish recovery scenario of
the corporate universe.  Should macroeconomic conditions evolve
towards a more severe scenario such as a double dip recession, the
CSO rating will likely be downgraded to an extent depending on the
expected severity of the worsening conditions


MORGAN STANLEY: S&P Withdraws Ratings on Class II 2006-14 Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its rating on the
class II notes issued by Morgan Stanley Managed ACES SPC's series
2006-14, a synthetic corporate investment-grade collateralized
debt obligation transaction.

The rating withdrawal follows the complete redemption and
cancellation of the notes.

                        Rating Withdrawn

                 Morgan Stanley Managed ACES SPC
                          Series 2006-14

                               Rating
                               ------
                  Class      To      From
                  -----      --      ----
                  II         NR      CCC- (sf)

                          NR - Not rated.


MSC 2006-SRR2: Fitch Downgrades Ratings on 10 Classes of Notes
--------------------------------------------------------------
Fitch Ratings has downgraded 10 and affirmed seven classes of
notes issued by MSC 2006-SRR2 as a result of significant negative
credit migration within the reference portfolio.

Since Fitch's last rating action in November 2009, approximately
43.7% of the portfolio has been downgraded, and 23.6% is currently
on Rating Watch Negative.  Approximately, 98% of the portfolio has
a Fitch derived rating below investment grade and 55.5% has a
rating in the 'CCC' rating category or lower, compared to 93.3%
and 8.3% 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.  Based on this analysis, all PCM
rating loss rates exceed the credit enhancement available to all
classes.  For all classes, Fitch assigned the ratings based on the
amount of underlying assets experiencing interest shortfalls
(38.2%), as these assets are likely to ultimately experience
significant losses.  These classes have been assigned a 'C' rating
indicating that default is inevitable.

MSC 2006-SRR2 is a static synthetic collateralized debt obligation
transaction issued in December 2006 that references a
US$1.2 billion portfolio of CMBS securities.  The reference
portfolio is composed of 66.7% CMBS assets from the 2006 vintage
and 33.3% from the 2005 vintage.  The transaction is designed to
provide credit protection for realized losses on a reference
portfolio through a credit default swap between the issuer and the
swap counterparty, Morgan Stanley Capital Services Inc. The swap
counterparty guarantor is Morgan Stanley.

Fitch has downgraded these classes:

  -- $72,000,000 Class A-1 Notes to 'Csf' from 'CCCsf';
  -- $90,000,000 Class A-2 Notes to 'Csf' from 'CCCsf';
  -- $38,400,000 Class B Notes to 'Csf' from 'CCsf';
  -- $28,200,000 Class C Notes to 'Csf' from 'CCsf';
  -- $12,600,000 Class D Notes to 'Csf' from 'CCsf';
  -- $14,800,000 Class E Notes to 'Csf' from 'CCsf';
  -- $12,200,000 Class F Notes to 'Csf' from 'CCsf';
  -- $11,610,000 Class G Notes to 'Csf' from 'CCsf';
  -- $18,750,000 Class H Notes to 'Csf' from 'CCsf';
  -- $9,360,000 Class J Notes to 'Csf' from 'CCsf';

In addition, Fitch has affirmed these classes:

  -- $16,080,000 Class K Notes at 'Csf';
  -- $12,480,000 Class L Notes at 'Csf';
  -- $6,510,000 Class M Notes at 'Csf';
  -- $2,970,000 Class N Notes at 'Csf';
  -- $5,040,000 Class O Notes at 'Csf';
  -- $2,160,000 Class P Notes at 'Csf';
  -- $1,320,000 Class Q Notes at 'Csf'.


MUNIMAE TE: Moody's Downgrades Ratings on Various Shares
--------------------------------------------------------
Moody's Investors Service has downgraded these ratings on the
MuniMae TE Bond Subsidiary, LLC's Preferred and Perpetual
Preferred Shares-- to Ba1 from Baa1 on $147.3 million total Series
A, A-1, A-2, A-3, A-4; to Ba2 from Baa2 on $104 million total
Series B, B-1, B-2, B-3; to Ba3 from Baa3 on $49 million total
Series C, C-1, C-2, C-3; to B1 from Ba1 on $34 million Series D.
Moody's has also downgraded TE Bond Sub's Issuer Rating to Ba1
from A3.  The ratings on the preferred shares are not affected by
the issuer rating.  The ratings are removed from Watchlist and
maintain a negative outlook.

                        Ratings Rationale

The rating downgrade on TE Bond Sub's preferred shares is based on
the change in the structure of the shares since the last review,
continued credit weakness in the multi-family housing sector and
credits associated with this sector, as well as the rollover risk
of the Freddie Mac credit facility on bonds that provide revenues
to TE Bond Sub which expires in 2013.

The Series A shares are on parity with each other.  The Series B
shares, which are on parity with each other, are subordinate to
the Series A shares.  The Series C shares, which are on parity
with each other, are subordinate to the Series A and B shares.
The Series D shares are on parity with each other and are
subordinate to all of the above mentioned shares.  The
differential in the senior and the different subordinate rating
levels reflects the priority of payment in distribution,
liquidation, winding up or dissolution of TE Bond Sub.

                       Recent Developments

Effective June 30 2009, the Series Exhibits for the Series A and
A-1 shares were amended and restated to provide distributions and
redemptions at a combined rate of 12.68% (7.50% distribution &
5.18% amortization) and 20% (6.30% distribution & 13.70%
amortization), respectively.  Since TE Bond Sub receives the
residual cash flow from the payments on their bond portfolio,
after all senior debt obligations have been paid, Moody's believe
that the introduction of Series A and A-1 share redemptions
introduce additional risk to the company's ability to meet its
distribution and redemption obligations.  This additional risk to
meet the quarterly redemption requirement could be exacerbated in
the event of higher spreads on the senior debt obligations,
resulting in reduced available cash flow to the TE Bond Sub for
payment on the preferred shares.

This rating action also incorporates the rollover risk of the
Freddie Mac credit facility which expires in 2013.  While the
rollover risk does not directly affect the preferred shares, the
credit and liquidity risks are tied to the revenue stream
associated with the expiring Freddie Mac facility.  Inability to
rollover the existing Freddie Mac credit facility may have
material negative implications for the revenues available to the
preferred shareholders.

TE Bond Sub is entitled to the residual cash flow from
approximately $1.13 billion of outstanding tax-exempt mortgage
revenue bonds.  Overall performance and composition of the
portfolio has improved as a result of management's asset
management of the pool including their efforts to work out poorly
performing assets and the decision to direct investments into Low
Income Housing Tax Credit bonds.  However, due to the continued
weakness in the multi-family housing sector, the bond portfolio
remains vulnerable to multifamily project risks, such as inability
to maintain rent levels particularly during stressful economic
times, and rising expenses.

Senior debt obligations are limited by an incurrence test to 60%
of the gross asset value of TE Bond Sub.  Based on the June 30,
2010 unaudited consolidated supplemental statements, the leverage
ratio decreased to 60% from 61% in 2008.  TE Bond Sub cannot incur
any additional obligations if the senior debt obligations are
greater than 60% of the gross assets of TE Bond Sub.  TE Bond Sub
further covenants that no additional Series A preferred shares may
be issued unless, after issuance, the liquidation ratio of
outstanding preferred shares to net assets (gross assets less
senior debt obligations) is not greater than 25%, 42% for the
Series A& B preferred shares, 50% for the Series A, B & C shares
and 62.5% for the combined Series A, B, C & D shares.  Based on
the June 30, 2010 unaudited consolidated supplemental statements,
the liquidation ratio for the Series A shares was 32.4%, an
increase from 30.2% in 2008.  The liquidation ratio for the Series
B shares, which incorporate Series A & B shares, was 55.1%, up
from 50.5% in 2008.  The combined Series A, B & C shares had a
liquidation ratio of 65.7%, an increase from 60.1% in 2008, and
the liquidation ratio of all preferred shares (A, B, C & D) was
73.1% up from 66.8% last year.  In 1Q 2010 TE Bond Sub entered
into an amendment to its operating agreement to recapitalize the
company by $25 million by limiting common share distributions
until $25 million has been accumulated.  The cumulative balance
of retained distribution as of 2Q 2010 was approximately
$20.6 million.

                What could make the rating go -- Up

  -- Successful remarketing of the preferred shares

  -- Significant improvements in the multi-family housing sector
     and credits associated with the sector

  -- Successful extension of the Freddie Mac credit facility in
     the near term

               What could make the rating go -- Down

  -- Continued stresses in the multi-family housing sector and
     credits associated with the sector

  -- Continued failed remarketing of the preferred shares

  -- Not extending or replacing the Freddie Mac credit facility
     until 2013

                             Outlook

Moody's outlook for the Series A, B, C and D preferred shares and
the issuer rating is negative.  The negative outlook reflects
Moody's view of continued stress on the preferred shares due to
the introduction of Series A and A-1 share redemptions, rollover
risk affiliated with the expiring Freddie Mac credit facility in
2013, as well as the continued weakness in the multi-family
housing sector and credits associated with this sector.

The last rating action was on September 22, 2010 when Moody's
placed MuniMae TE Bond Subsidiary, LLC's Baa1 rating on Series A,
A-1, A-2, A-3, A-4; Baa2 rating on Series B, B-1, B-2, B-3; Baa3
rating on Series C, C-1, C-2, C-3; Ba1 rating on Series D
preferred shares, and A3 Issuer Rating on watchlist for potential
downgrade.


PALOMAR POMERADO: Fitch Assigns 'BB+' Rating to $160 Mil. Notes
---------------------------------------------------------------
Fitch Ratings assigns a 'BB+' rating to $160 million in series
2010 certificates of participation expected to be issued by
Palomar Pomerado Health.  In addition, Fitch downgrades to 'BB+'
from 'BBB' the rating on these outstanding PPH bonds:

  -- $224,000,000 certificates of participation, series 2009;

  -- $172,000,000 certificates of participation, series 2006A,B &
     C;

  -- $35,475,000 insured revenue refunding bonds, series 1999.

The series 2010 COPs will finance the remaining construction costs
of PPH's master facility plan, fund capitalized interest and a
debt service reserve fund, and pay costs of issuance.  The COPs
are expected to sell the week of Nov. 9, 2010.

The Rating Outlook is stable.

Rating Rationale:

  -- The downgrade to 'BB+' from 'BBB' reflects PPH's heightened
     leverage position, reduced debt service coverage and lowered
     debt-related liquidity metrics as a result of planned
     issuance of the series 2010 COPs.

  -- Though financial projections after completion of PPH's new
     facility show breakeven profitability, PPH's markedly
     increased debt load, reduced coverage, and low debt-related
     liquidity metrics produce a financial profile that is
     inconsistent with an investment grade rating.

Key Rating Driver:

  -- Successful completion of PPH's master facility plan without
     further deterioration of PPH's liquidity and leverage
     positions.

Security:

Debt payments are secured by a pledge of the gross revenues of the
obligated group.  A fully funded debt service fund provides
additional security for the bond issue.

Credit Summary:

The two-notch downgrade to 'BB+' from 'BBB' reflects PPH's
deteriorating leverage, reduced debt service coverage, and lower
debt-related liquidity ratios as a result of a planned new debt
issuance of $160 million.  The series 2010 COPs are being issued
to complete funding needs for PPH's $1.06 billion master facility
plan.  Management informs Fitch that the unanticipated 2010
issuance is related to a need to fund a $77.4 million central
utility plant that was to be financed by a third party, a
$30 million project cost escalation, and a downward revision to
the philanthropy component to $7.1 million from $45 million.  PPH
anticipates using future philanthropy receipts to pay down a
portion of the 2010 COPs.

Palomar Pomerado's pro forma leverage, debt service coverage, and
debt-related liquidity metrics are indicative of a very high debt
burden and are in line with Fitch's 'BB' category medians.  Post
financing, PPH's long-term debt will total $588.5 million.  With
this financing, maximum annual debt service increases to
$41.9 million from $31.9 million.  On a pro forma basis for the
fiscal year ended June 30, 2010, MADS accounts for a very high
7.8% of total operating revenues.  Pro forma MADS coverage by
EBITDA, at 1.3 times, is weak and compares unfavorably to Fitch's
2.5x median for the 'BBB' category.  Lastly, pro forma debt to
capitalization, estimated at 65.2%, is quite high.

The planned financing further exacerbates Palomar Pomerado's
already low liquidity position related to its debt.  Although
PPH's $171.6 million in unrestricted cash and investments equates
to a solid 144 days of expenses, cash-to-debt (40%) and the
cushion ratio (5.4x) are low.  On a pro forma basis, PPH's cash to
debt position and cushion ratio fall to 29.2% and 4.1x,
respectively.  While financial projections provided to Fitch by
management show measured improvements to PPH's financial profile,
Fitch believes that the markedly increased debt load, low MADS
coverage, and decreased debt-related liquidity will remain below
investment grade metrics.

The elevated revenue-secured debt load is mitigated by PPH's good
operational management practices, leading market share in a large
primary service area, and taxing authority (for operations and GO
bond repayment) over a large and diverse tax base.  Profitability
continues to benefit from management actions that focused on cost
containment and revenue enhancement, resulting in two years of
very good and increasing operating margins -- in FY 2009 and 2010,
PPH reported operating margins of 3.4% and 4.7%, respectively.

PPH's operations benefit from its leading (54%) market share in
the large and highly populated north San Diego County area.
Additionally, PPH has entered into a hospital service agreement
with Kaiser Foundation Hospitals (rated 'A+' by Fitch) to provide
inpatient and outpatient hospital services to Kaiser's Health Plan
members, which Fitch views as a positive credit factor.  Further,
as a California Hospital District (i.e., a political subdivision
of the State of California), PPH derives unrestricted property tax
revenues from a fixed share of the 1% property tax levied by the
County of San Diego on all taxable real property in PPH's
boundaries.  In FY 2010, PPH received $12.9 million in
unrestricted property tax revenues.  Fitch notes that these
revenues are in addition to, and are separate from, the ad valorem
tax revenues resulting from the separate voter-approved tax levy
that is pledged solely to the payment of principal and interest on
PPH's series 2005, 2007, 2009, and 2010 GO bonds (rated 'AA').

The Stable Outlook reflects Fitch's expectation that management
will successfully complete its master facility plan without
further deterioration in PPH's liquidity and leverage positions.

Palomar Pomerado operates two acute care hospitals, the 324-bed
Palomar Medical Center (PMC) in Escondido and the 107-bed Pomerado
Hospital in Poway, two skilled nursing facilities, a surgery
center, and an ambulatory care center.  In FY 2010, PPH had
$540.1 million in total health care revenues.  PPH covenants to
provide annual audited financial reports and unaudited quarterly
financial statements to bondholders.  Quarterly information,
including a balance sheet, income statement, and statement of
changes in net assets will be provided within 45 days after the
end of each of the first three fiscal quarters.


PETRA CRE: Moody's Takes Rating Actions on Various Classes
----------------------------------------------------------
Moody's has confirmed one and downgraded ten classes of Notes
issued by Petra CRE CDO 2007-1, Ltd. due to the deterioration in
the credit quality of the underlying portfolio as evidenced by an
increase in the weighted average rating factor, an increase in
Defaulted Securities, and the sensitivity of the transaction to
recovery rates.  The rating action, which concludes Moody's
review, is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation
transactions.

Issuer: Petra CRE CDO 2007-1, Ltd.

  -- Cl. A-1, Confirmed at Aaa (sf); previously on Feb. 26, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-2, Downgraded to Baa1 (sf); previously on Feb. 26, 2010
     A1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Downgraded to B3 (sf); previously on Feb. 26, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Downgraded to Caa3 (sf); previously on Feb. 26, 2010
     Ba3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to Caa3 (sf); previously on Feb. 26, 2010
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to Caa3 (sf); previously on Feb. 26, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to Caa3 (sf); previously on Feb. 26, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to Caa3 (sf); previously on Feb. 26, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. H, Downgraded to Ca (sf); previously on Feb. 26, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. J, Downgraded to Ca (sf); previously on Feb. 26, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. K, Downgraded to Ca (sf); previously on Feb. 26, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

                        Ratings Rationale

Petra CRE CDO 2007-1, Ltd. is a CRE CDO transaction backed by a
portfolio A-Notes and whole loans (57.3% of the pool balance),
mezzanine loans (20.4%), commercial mortgage backed securities
(7.3%), B-Notes (5.8%), CRE CDO (4.6%) and real estate investment
trust debt (4.6%).  As of the October 25, 2010 Trustee report, the
aggregate Note balance of the transaction has decreased to
$930.3 million from $1,000.0 million at issuance, due to partial
cancellation of the senior most class of Notes.

There are ten assets with par balance of $237.1 million (21.7% of
the current pool balance) that are considered Defaulted Securities
as of the October 25, 2010 Trustee report.  While there have been
no realized losses to date, Moody's expects significant losses to
occur once they are realized.

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.  These parameters are typically modeled as actual
parameters for static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's have completed updated credit estimates for the non-
Moody's rated reference obligations.  For non-CUSIP collateral,
Moody's is eliminating the additional default probability stress
applied to corporate debt in CDOROM(R) v2.6 as Moody's expect the
underlying non-CUSIP collateral to experience lower default rates
and higher recovery compared to corporate debt due to the nature
of the secured real estate collateral.  The bottom-dollar WARF is
a measure of the default probability within a collateral pool.
Moody's modeled a bottom-dollar WARF of 9,039 compared to 8,373 at
last review.  The distribution of current ratings and credit
estimates is: Aaa-Aa3 (3.6% compared to 2.8% at last review), A1-
A3 (1.8% compared to 4.5% at last review), Baa1-Baa3 (1.8%
compared to 0.0% at last review), Ba1-Ba3 (2.9% compared to 0.0%
at last review), B1-B3 (0.0% compared to 2.8% at last review), and
Caa1-C (89.9%, the same as that at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of 6.5
years compared to 9.0 years at last review.  The current modeled
WAL incorporates updated assumptions about the remaining
reinvestment period.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool.  Moody's modeled a fixed WARR
of 36%, the same as that 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).  For
non-CUSIP collateral, Moody's is reducing the maximum over
concentration stress applied to correlation factors due to the
diversity of tenants, property types, and geographic locations
inherent in pooled transactions.  Moody's modeled a MAC of 99.9%
compared to 16.9% at last review.  The high MAC is due to higher
default probability collateral concentrated within a small number
of collateral names.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes.  However,
in many instances, a change in key parameter assumptions in
certain stress scenarios may be offset by a change in one or more
of the other key parameters.  Rated notes are particularly
sensitive to changes in recovery rate assumptions.  Holding all
other key parameters static, changing the recovery rate assumption
down from 36% to 26% or up to 46% would result in average rating
movement on the rated tranches of 1 to 9 notches downward and 0 to
6 notches upward, respectively.

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 stressed macroeconomic environment and
continuing weakness in the commercial real estate and lending
markets.  Moody's currently views the commercial real estate
market as stressed with further performance declines expected in a
majority of property sectors.  The availability of debt capital is
improving with terms returning towards market norms.  Job growth
and housing price stability will be necessary precursors to
commercial real estate recovery.  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's largest
economies, returning to trend growth rate with elevated fiscal
deficits and persistent unemployment levels.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.


PNC MORTGAGE: S&P Downgrades Ratings on Three 1999-CM1 Securities
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on three
classes of commercial mortgage-backed securities from PNC Mortgage
Acceptance Corp.'s series 1999-CM1.  S&P affirmed its ratings on
four additional classes from the same transaction.

The downgrades follow S&P's analysis of the remaining collateral
in the pool, the deal structure, and the interest shortfalls that
have affected the trust.  The transaction is currently
collateralized by 18 assets, seven of which are with the special
servicer, Midland Loan Services Inc. S&P projected losses for all
of the specially serviced assets.  In doing so, S&P used the most
recent valuation information from the special servicer.

Furthermore, as of the October 2010 remittance report, the trust
had experienced interest shortfalls of $20,602 during the monthly
remittance period, with cumulative interest shortfalls of
$860,208.  The monthly interest shortfalls were due to appraisal
subordinate entitlement reduction amounts ($14,299) on three of
the specially serviced assets, as well as special servicing fees
($6,303).  The downgrades also reflect a reduction of available
interest to the rated classes caused by these shortfalls,
increasing the risk that they may experience interest shortfalls
in the future given the portion of collateral currently with the
special servicer (58.8% of the pool).  This contributed to the
downgrades of classes B-5, B-6, and B-7.

The affirmations of the class B-3 and B-4 certificates reflect
subordination levels and liquidity that are consistent with the
outstanding ratings.  S&P affirmed its 'D (sf)' ratings on the
class B-8 and C certificates.  S&P lowered its rating on class C
to 'D (sf)' in April 2009 due to interest shortfalls S&P
determined were recurring at that time.  According to the October
2010 remittance report, the class has lost 100% of its original
principal balance.  S&P lowered its rating on class B-8 to 'D
(sf)' in June 2010 due to a principal loss.  Based on the October
2010 remittance report, the class has lost 66.6% of its original
principal balance.

                      Credit Considerations

As of the October 2010 remittance report, seven ($26.8 million,
58.8%) assets in the pool were with the special servicer.  This
includes six of the top 10 real estate exposures, three of which
S&P discuss in detail below.  The status of the loans was
reported: four ($19.3 million, 42.3%) loans are classified as
matured balloon loans, two ($6.0 million, 13.3%) were classified
as being in foreclosure, and one ($1.5 million, 3.2%) is real
estate owned.  Appraisal reduction amounts totaling $2.1 million
are in effect against three of the specially serviced assets.

The Orchard Square Shopping Center loan ($7.6 million total
exposure, 16.7%) is the largest real estate exposure in the pool
and the largest loan with the special servicer.  The loan is
secured by a 92,450-sq.-ft. retail property in Washington
Township, Mich.  The loan was transferred to the special servicer
in September 2009 and is classified as a matured balloon loan.
The borrower is attempting to secure sufficient proceeds to payoff
the loan.  As of June 2010, reported DSC and occupancy were 1.00x
and 82.5%, respectively.  Standard & Poor's expects a moderate
loss upon the eventual resolution of the loan.

The Selma Square Shopping Center loan ($6.3 million total
exposure, 13.8%) is the second-largest real estate exposure in the
pool and the second-largest loan with the special servicer.  The
loan is secured by a 77,383-sq.-ft. retail property in Selma,
Calif.  The loan was transferred to the special servicer in
September 2009 and is classified as a matured balloon loan.  The
borrower is attempting to secure sufficient proceeds to pay off
the loan.  As of June 2010, reported DSC and occupancy were 1.45x
and 96.3%, respectively.  Standard & Poor's expects a moderate
loss upon the eventual resolution of the loan.

The Hurstbourne Office Park loan ($5.6 million total exposure,
12.4%) is the third-largest real estate exposure in the pool and
the third-largest loan with the special servicer.  The loan is
secured by a 105,116-sq.-ft. office property in Louisville, Ky.
The loan was transferred to the special servicer in September 2009
and is in foreclosure.  Reported DSC and occupancy were 0.88x and
94.0% as of December 2008 and March 2009, respectively.  Standard
& Poor's anticipates a moderate loss upon the eventual resolution
of the loan.

The remaining specially serviced assets each have a principal
balance of $4.0 million or less.  S&P estimated losses for all of
these assets.  The weighted average estimated loss severity was
40.5%.

In addition to the specially serviced assets, S&P determined two
other loans to be credit-impaired?the TownePlace Suites by
Marriott ? Brookfield loan ($4.7 million, 10.2%, fourth-largest
real estate exposure) and the TownePlace Suites by Marriott - Eden
Prairie loan ($4.2 million, 9.2%, fifth-largest real estate
exposure).  The former is secured by a 112-room lodging property
in Brookfield, Wis., and the latter is secured by a 103-room
lodging property in Eden Prairie, Minn.  The loans, which were
previously with the special servicer, appear on the master
servicer's watchlist due to low DSC.  As of June 2010, reported
DSC and occupancy for the Brookfield loan were 0.75x and 70.9%,
respectively.  The Eden Prairie loan had DSC and occupancy of
0.79x and 67.8%, respectively, as of the same period.  Given the
low DSC and occupancies, S&P considers these loans to be at an
increased risk of default and loss.

                       Transaction Summary

As of the October 2010 remittance report, the collateral pool
had an aggregate trust balance of $45.6 million, down from
$760.4 million at issuance.  The pool includes 17 loans and one
REO asset, down from 207 loans at issuance.  Two ($2.0 million,
4.4%) loans are defeased.  The master servicer, also Midland,
provided full-year 2008, interim 2009, or full-year 2009 financial
information for 97.0% of the nondefeased assets in the pool.  S&P
calculated a weighted average DSC of 1.13x for the pool based on
the reported figures.

The master servicer reported a watchlist of three ($10.1 million,
22.2%) loans.  Seven ($21.5 million, 47.1%) loans have reported
DSC of less than 1.10x, and six ($20.0 million, 43.9%) loans have
reported DSC of less than 1.00x.  To date, the pool has
experienced principal losses totaling $21.7 million on 22 assets.

                 Summary of Top 10 Loan Exposures

The top 10 exposures secured by real estate have an aggregate
outstanding trust balance of $38.0 million (83.5%).  Using
servicer-reported numbers, S&P calculated a weighted average DSC
of 1.12x for the top 10 real estate assets.  Six ($25.8 million,
56.6%) top 10 exposures are currently with the special servicer,
three of which S&P discussed in detail above.  Three
($10.1 million, 22.2%) of the top 10 loans appear on the master
servicer's watchlist, two of which S&P discussed in detail above.
The Brookwood Apartments loan ($1.3 million, 2.8%) is the third-
largest loan on the watchlist (10th-largest real estate exposure
in the pool).  The loan is secured by an 80-unit multifamily
property in College Station, Texas.  Recent financial and
occupancy information was not available.  The asset appears on
the master servicer's watchlist for low DSC.  As of June 2008, the
property reported negative net cash flow and a 48.8% occupancy
rate.

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

                         Ratings Lowered

                     PNC Mortgage Acceptance Corp.
   Commercial mortgage pass-through certificates series 1999-CM1

                 Rating
                 ------
    Class      To        From           Credit enhancement (%)
    -----      --        ----           ----------------------
    B-5        BB+ (sf)  BBB- (sf)                       43.81
    B-6        CCC- (sf) B+ (sf)                         20.86
    B-7        CCC- (sf) CCC (sf)                         4.18

                        Ratings Affirmed

                   PNC Mortgage Acceptance Corp.
  Commercial mortgage pass-through certificates series 1999-CM1

       Class        Rating          Credit enhancement (%)
       -----        ------          ----------------------
       B-3          BBB+ (sf)                        75.10
       B-4          BBB (sf)                         58.41
       B-8          D (sf)                            0.00
       C            D (sf)                            0.00


POPULAR ABS: Moody's Assigns 'Ba1' Rating to Interest Rate Swap
---------------------------------------------------------------
Moody's Investors Service has assigned a Ba1 (sf) rating on the
Swap to the Popular ABS Mortgage Pass-Through Trust 2007-A
transaction.  Moody's rating addresses the credit risk posed to
the swap counterparty.  This rating only addresses the risk
attributable to the ability of the trust to continue to honor its
obligations under the swap.  The rating does not address market
risk that may be experienced by the party facing the trust under
the swap contract.

Issuer: Popular ABS Mortgage Pass-Through Trust 2007-A

  -- Swap: Swap (Reference Number N615392N)
  * Interest Rate Swap, Assigned Ba1 (sf)

                        Ratings Rationale

The rating takes into account the rating of the swap counterparty,
the transaction's legal structure and the characteristics of the
collateral mortgage pool of the respective trust.  Because there
is relatively limited historical performance data for the types of
instruments, this credit rating may have a greater potential
rating volatility than would ratings for transactions supported by
more historical performance data.

Moody's rating approach for this counterparty instrument rating
rests on three propositions:

* The CIRs are based on an analysis of the payment promise made by
  the trust, the position of the instrument in the payment
  waterfall, the credit quality of the rated payment flows, the
  security arrangements governing the trust's relationship with
  the counterparty, the support mechanisms available to the
  counterparty, the termination date of the swap and other
  structural features of the transaction in question.  In this
  regard, the rating process is similar to that for all other
  ratings assigned by Moody's.

* The credit quality and ratings assigned to counterparty
  instrument obligations of the trust may differ from those of its
  payment obligations to bondholders.  As a result, ratings
  assigned to bonds issued by the trust may diverge from the CIR
  and therefore the bond ratings may offer only a limited guidance
  on the CIR.

* Although counterparty instrument ratings address payments to
  rather than from the counterparty, in certain circumstances the
  credit strength of the counterparty itself may have a bearing on
  the CIR.  For example, where a counterparty's non-performance
  under a swap agreement leads to the trust having to make a
  termination payment to that counterparty, Moody's will take into
  account the likelihood of the counterparty's non-performance
  occurring and the position of termination payments in the cash
  flow waterfall .  Specifically, in the event that the swap
  counterparty causes a termination event, any termination payment
  owed to the swap counterparty may be paid at the bottom of the
  cash flow waterfall.  As a result, a default by the swap
  counterparty, which is currently rated Aa3, makes payment in
  full to the counterparty unlikely.

By way of background, the swap counterparty, Deutsche Bank AG, New
York Branch in this case, receives a fixed rate from, and pays
LIBOR to, the trust on a notional amount that is the lesser of the
aggregate class certificate balance and the amount set forth on
the schedule to the swap agreement.  Per the terms of the deal
documents, the swap counterparty receives payments prior to
bondholders, and is thus in a senior position to all bonds issued
by the trust.  The termination date for the Certificate Swap is
25th April, 2014.  To pay the swap counterparty, the trust also
has access to principal payments, liquidation proceeds and
interest collections.  This provision strengthens the nature of
senior payment right of the swap counterparty.

The primary risks driving the rating on the swap is the risk that
the collateral pool amortizes at a rate that exceeds the
amortization rate of the swap notional and the risk of a
termination event triggered by a default of the swap counterparty.
As the losses are not allocated to the senior certificates, it is
likely, especially in high default scenarios, that the collateral
balance would amortize faster than the swap notional.  The
counterparty in the swap, Deutsche Bank AG, New York Branch, has a
Aa3 long term rating and a P-1 short term rating by Moody's.

Moody's methodology for rating swaps on US RMBS transactions
includes running collateral cashflows and considers the rating of
the swap counterparty.  Moody's stress the cashflows by increasing
defaults and prepayments to determine what level of collateral
stress would cause a shortfall in proceeds owed to the swap
counterparty.  The cashflows are modeled to reflect the waterfall
of the underlying transaction, which results in all swap payments
other than termination payments caused by a counterparty default
coming at the top of the waterfall.  Termination payments owed to
the swap counterparty resulting from a default of the swap
counterparty are paid at the bottom of the waterfall.  The swap in
this transaction passed scenarios consistent with the Ba1
collateral cashflow stresses.  Additional qualitative
considerations that were not modeled, such as the impact of a
decline in the weighted average interest rate of the collateral
pool, interest rate reduction modifications or more conservative
servicer advancing approaches, were also analyzed.

Moody's projected remaining loss on the mortgage pool as a
percentage of the current balance is 51%.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments in this transaction.


RACE POINT: 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 Race Point II CLO, Limited:

  -- US$15,000,000 Class A-2 Senior Secured Floating Rate Notes,
     Due 2015, Upgraded to Aaa (sf); previously on September 27,
     2009 Downgraded to Aa3 (sf);

  -- US$15,000,000 Class B-1 Senior Secured Deferrable Floating
     Rate Notes, Due 2015, Upgraded to Baa1 (sf); previously on
     September 27, 2009 Confirmed at Baa3 (sf);

  -- US$38,000,000 Class B-2 Senior Secured Deferrable Fixed
     Rate Notes, Due 2015, Upgraded to Baa1 (sf); previously on
     September 27, 2009 Confirmed at Baa3 (sf);

  -- US$12,000,000 Class C-1 Senior Secured Deferrable Floating
     Rate Notes, Due 2015, Upgraded to Ba3 (sf); previously on
     September 27, 2009 Downgraded to B1 (sf);

  -- US$5,000,000 Class C-2 Senior Secured Deferrable Fixed Rate
     Notes, Due 2015, Upgraded to Ba3 (sf); previously on
     September 27, 2009 Downgraded to B1 (sf);

  -- US$3,500,000 Class D-1 Senior Secured Deferrable Floating
     Rate Notes, Due 2015, Upgraded to Caa1 (sf); previously on
     September 27, 2009 Downgraded to Caa2 (sf);

  -- US$3,000,000 Class D-2 Senior Secured Deferrable Floating
     Rate Notes, Due 2015, Upgraded to Caa1 (sf); previously on
     September 27, 2009 Downgraded to Caa2 (sf);

  -- US$4,000,000 Class D-3 Senior Secured Deferrable Fixed Rate
     Notes, Due 2015, Upgraded to Caa1 (sf); previously on
     September 27, 2009 Downgraded to Caa2 (sf).

                        Ratings Rationale

According to Moody's, the rating actions taken on the notes result
primarily from the delevering of the Class A-1 Notes, which have
been paid down by approximately 34% or $126.03 million since the
last rating action in September 2009.  As a result of the
delevering, the overcollateralization ratios have increased since
the last rating action in September 2009.  As of the latest
trustee report dated September 30, 2010, the Class A, Class B,
Class D and Class D overcollateralization ratios are reported at
147.9%, 122.6%, 116.2% and 112.6%, respectively, versus August
2009 levels of 128.67%, 113.02%, 108.78% and 106.31%,
respectively.

Moody's noted that the underlying portfolio includes a number of
investments in securities that mature after the maturity date of
the notes.  Based on the September 2010 trustee report, reference
securities that mature after the maturity date of the notes
currently make up approximately 6.4% of the underlying reference
portfolio versus 2.8% in September 2009.  These investments
potentially expose the notes to market risk in the event of
liquidation at the time of the notes' maturity.

Moody's also notes that the deal has benefited from improvement in
the credit quality of the underlying portfolio since the last
rating action.  Based on the September 2010 trustee report, the
weighted average rating factor is 2799 compared to 3007 in August
2009, and securities rated Caa1 and below make up approximately
11% of the underlying portfolio versus 14.8% in August 2009.  The
deal also experienced a decrease in defaults.  In particular, the
dollar amount of defaulted securities has decreased to about
$7 million from approximately $38 million in August 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 its base case, Moody's analyzed the
underlying collateral pool to have a performing par and principal
proceeds of $378 million, defaulted par of $9 million, weighted
average default probability of 24.05% (implying a WARF of 3735, a
weighted average recovery rate upon default of 40.75%, and a
diversity score of 63.  Assets which mature after the maturity of
the transaction have increased since the last rating action in
September 2009 and currently represent 6.42% of the performing
portfolio.  These default and recovery properties of the
collateral pool are incorporated in cash flow model analysis where
they are subject to stresses as a function of the target rating of
each CLO liability being reviewed.  The default probability is
derived from the credit quality of the collateral pool and Moody's
expectation of the remaining life of the collateral pool.  The
average recovery rate to be realized on future defaults is based
primarily on the seniority of the assets in the collateral pool.
In each case, historical and market performance trends, and
collateral manager latitude for trading the collateral are also
factors.

Race Point II CLO, Limited, issued in April 2003, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

Moody's Investors Service did not receive or take into account a
third-party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis described above, Moody's
also performed a number of sensitivity analyses to test the impact
on all rated notes, including these:

1.  Various default probabilities to capture potential defaults in
    the underlying portfolio.

2.  A range of recovery rate assumptions for all assets to capture
    variability in recovery rates.

A summary of the impact of different default probabilities
(expressed in terms of WARF levels) on all rated notes (shown in
terms of the number of notches' difference versus the current
model output, where a positive difference corresponds to lower
expected losses), assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2988)

  -- Class A-1: 0
  -- Class A-2: 0
  -- Class B-1: +2
  -- Class B-2: +2
  -- Class C-1: +2
  -- Class C-2: +2
  -- Class D-1: +2
  -- Class D-2: +2
  -- Class D-3: +2

Moody's Adjusted WARF + 20% (4482)

  -- Class A-1: 0
  -- Class A-2: -2
  -- Class B-1: -2
  -- Class B-2: -2
  -- Class C-1: -2
  -- Class C-2: -2
  -- Class D-1: -4
  -- Class D-2: -4
  -- Class D-3: -4

A summary of the impact of different recovery rate levels on all
rated notes (shown in terms of the number of notches' difference
versus the current model output, where a positive difference
corresponds to lower expected losses), assuming that all other
factors are held equal:

Moody's Adjusted WARR + 2% (42.75%)

  -- Class A-1: 0
  -- Class A-2: 0
  -- Class B-1: 0
  -- Class B-2: 0
  -- Class C-1: 0
  -- Class C-2: 0
  -- Class D-1: +1
  -- Class D-2: +1
  -- Class D-3: +1

Moody's Adjusted WARR - 2% (38.75%)

  -- Class A-1: 0
  -- Class A-2: 0
  -- Class B-1: -1
  -- Class B-2: -1
  -- Class C-1: -1
  -- Class C-2: -1
  -- Class D-1: -2
  -- Class D-2: -2
  -- Class D-3: -2

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the managers'
investment strategies and behaviour and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are described
below [use when applicable]:

1) Delevering: The main source of uncertainty in this transaction
   is whether delevering from unscheduled principal proceeds will
   continue and at what pace.  Delevering may accelerate due to
   high prepayment levels in the loan market and/or collateral
   sales by the manager, which may have significant impact on the
   notes' ratings.

2) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deals'
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus selling defaulted
   assets create additional uncertainties.  Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

3) Long-dated assets: The presence of assets that mature beyond
   the CLO's legal maturity date exposes the deal to liquidation
   risk on those assets. Moody's assumes an asset's terminal value
   upon liquidation at maturity to be equal to the lower of an
   assumed liquidation value (depending on the extent to which the
   asset's maturity lags that of the liabilities) and the asset's
   current market value.


RED RIVER: Moody's Upgrades Ratings on Three Classes of Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Red River CLO Ltd.:

  -- US$657,000,000 Class A Floating Rate Senior Secured
     Extendable Notes Due 2018 (current outstanding balance of
     $610,377,614.40), Upgraded to A3 (sf); previously on June 9,
     2009 Downgraded to Baa2 (sf);

  -- US$45,000,000 Class B Floating Rate Senior Secured
     Extendable Notes Due 2018, Upgraded to Ba1 (sf); previously
     on June 9, 2009 Downgraded to Ba3 (sf);

  -- US$40,500,000 Class C Floating Rate Senior Secured
     Deferrable Interest Extendable Notes Due 2018, Upgraded to
     Caa1 (sf); previously on June 9, 2009 Downgraded to Caa3
     (sf).

                        Ratings Rationale

According to Moody's, the rating actions taken on the notes result
primarily from delevering of the Class A Notes, improvement in the
credit quality of the underlying portfolio and an increase in the
overcollateralization ratios of the notes since the last rating
action in June 2009.

The Class A Notes have been paid down by approximately 5% or
$34 million since the last rating action in June 2009 as a result
of the breach of all overcollateralization tests.  Repayment of
the Class A Notes has come from both principal paydowns as well as
diversion of excess spread.  As a result of the delevering, the
overcollateralization ratios have increased since the last rating
action in June 2009.  Based on the latest trustee report dated
September 30, 2010, the Class A/B, Class C, Class D and Class E
overcollateralization ratios are reported at 114.47%, 107.81%,
101.26% and 97.13% respectively, versus May 2009 levels of
108.36%, 102.35%, 96.40% and 92.64%, respectively.  Additionally,
the deal will continue to benefit from the continued delevering of
the notes as a result of the diversion of excess interest proceeds
due to the failure of the overcollateralization tests.

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 September 30, 2010 trustee report, the weighted
average rating factor is currently 2698 compared to 3354 in the
May 2009 report and is currently in compliance with the trigger
level of 2720, and securities rated Caa1/CCC+ or lower make up
approximately 10.72% of the underlying portfolio versus 19.46% in
May 2009.

Finally, Moody's notes that the portfolio includes a number of
investments in securities that mature after the maturity date of
the notes.  Based on the September 2010 trustee report, securities
that mature after the maturity date of the notes currently make up
approximately 3.55% of the underlying portfolio all of which are
CLO tranches.  These investments potentially expose the notes to
market risk in the event of liquidation at the time of the notes'
maturity.

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 its base case, Moody's analyzed the
underlying collateral pool to have a performing par and principal
proceeds of $727 million, defaulted par of $116 million, weighted
average default probability of 30.30% (implying a WARF of 4316), a
weighted average recovery rate upon default of 42.11%, and a
diversity score of 57.  These default and recovery properties of
the collateral pool are incorporated in cash flow model analysis
where they are subject to stresses as a function of the target
rating of each CLO liability being reviewed.  The default
probability is derived from the credit quality of the collateral
pool and Moody's expectation of the remaining life of the
collateral pool.  The average recovery rate to be realized on
future defaults is based primarily on the seniority of the assets
in the collateral pool.  In each case, historical and market
performance trends, and collateral manager latitude for trading
the collateral are also factors.

Red River CLO Ltd., issued in August 2006, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.  For securities whose
default probabilities are assessed through credit estimates,
Moody's applied additional default probability stresses by
assuming an equivalent of Caa3 for CEs that were not updated
within the last 15 months, a 1.5 notch-equivalent assumed
downgrade for CEs last updated between 12-15 months ago, and a 0.5
notch-equivalent assumed downgrade for CEs last updated between 6-
12 months ago.  For each CE where the related exposure constitutes
more than 3% of the collateral pool, Moody's applied a 2-notch
equivalent assumed downgrade (but only on the CEs representing in
aggregate the largest 30% of the pool) in lieu of the
aforementioned stresses.  Notwithstanding the foregoing, in all
cases the lowest assumed rating equivalent is Caa3.

In addition to the base case analysis described above, Moody's
also performed a number of sensitivity analyses to test the impact
on all rated notes, including these:

1.  Various default probabilities to capture potential defaults in
    the underlying portfolio.

2.  A range of recovery rate assumptions for all assets to capture
    variability in recovery rates.

Below is a summary of the impact of different default
probabilities (expressed in terms of WARF levels) on all rated
notes (shown in terms of the number of notches' difference versus
the current model output, where a positive difference corresponds
to lower expected losses), assuming that all other factors are
held equal:

Moody's Adjusted WARF -- 20% (3453)

  -- Class A: +2
  -- Class B: +1
  -- Class C: +2
  -- Class D: +3
  -- Class E: 0

Moody's Adjusted WARF + 20% (5179)

  -- Class A: -2
  -- Class B: -3
  -- Class C: -3
  -- Class D: 0
  -- Class E: 0

Below is a summary of the impact of different recovery rate levels
on all rated notes (shown in terms of the number of notches'
difference versus the current model output, where a positive
difference corresponds to lower expected losses), assuming that
all other factors are held equal:

Moody's Adjusted WARR + 2% (44.11%)

  -- Class A: 0
  -- Class B: 0
  -- Class C: +1
  -- Class D: +1
  -- Class E: 0

Moody's Adjusted WARR - 2% (40.11%)

  -- Class A: -1
  -- Class B: -2
  -- Class C: 0
  -- Class D: 0
  -- Class E: 0

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the managers'
investment strategies and behaviour and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are described
below:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deals'
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus selling defaulted
   assets create additional uncertainties.  Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2) Long-dated assets: The presence of assets that mature beyond
   the CLO's legal maturity date exposes the deal to liquidation
   risk on those assets. Moody's assumes an asset's terminal value
   upon liquidation at maturity to be equal to the lower of an
   assumed liquidation value (depending on the extent to which the
   asset's maturity lags that of the liabilities) and the asset's
   current market value.

3) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings.  Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

4) The deal is allowed to reinvest and the manager has the ability
   to deteriorate the collateral quality metrics' existing
   cushions against the covenant levels.  Moody's analyzed the
   impact of assuming lower of reported and covenanted values for
   weighted average rating factor, weighted average spread,
   weighted average coupon, and diversity score.

5) The deal is exposed to a large number of securities whose
   default probabilities are assessed through credit estimates. In
   the event that Moody's is not provided the necessary
   information to update the credit estimates in a timely fashion,
   the transaction may be impacted by any default probability
   stresses Moody's may assume in lieu of updated credit
   estimates.


SATURN VENTURE: Moody's Takes Rating Actions on Four Classes
------------------------------------------------------------
Moody's has upgraded two and affirmed two classes of Notes issued
by Saturn Venture I, Ltd. due to the rapid pace of amortization of
the senior class of Notes.  The rating action is the result of
Moody's on-going surveillance of commercial real estate
collateralized debt obligation transactions.

  -- Class A-1 Floating Rate Senior Notes Notes, Upgraded to Aaa
     (sf); previously on Aug 6, 2009 Downgraded to A1 (sf)

  -- Class A-2 Floating Rate Senior Notes Notes, Upgraded to Ba3
     (sf); previously on Aug 6, 2009 Downgraded to B2 (sf)

  -- Class A-3 Floating Rate Senior Notes Notes, Affirmed at Ca
     (sf); previously on Aug 6, 2009 Downgraded to Ca (sf)

  -- Class B Floating Rate Subordinate Notes Notes, Affirmed at C
     (sf); previously on Mar 6, 2009 Downgraded to C (sf)

                        Ratings Rationale

Saturn Ventures I, Ltd., is a CRE CDO transaction backed by a
portfolio of commercial mortgage backed securities (61.2%),
residential mortgage backed securities [(16.6%); subprime (10.7%),
jumbo (4.8%), and second lien (1.1%)], CDO (10.3%), REIT debt
(9.5%), and ABS credit cards (2.4%).  As of the September 30, 2010
Trustee report, the aggregate Note balance of the transaction has
decreased to $162.9 million from $400.0 million at issuance, with
the majority of the paydown (96.3% of the total paydowns) directed
to the Class A Notes.  Saturn Venture I, Ltd. has a turbo feature
that allows for partial paydown of all subordinate classes (95% of
principle to paydown Class A-1, and the remaining 5% to pay down
Classes A-2, A-3, and B on a pro-rata basis).  As of the
September 30, 2010 Trustee report, the deal is undercollateralized
by approximately $36.5 million due to losses on underlying
securities.  As a result, the transaction, if failing its Coverage
Tests, will cause the turbo feature to shut off, and all principle
will then be directed to paydown the Class A-1 Notes.

There are fourteen assets with a par balance of $17.8 million
(14.1% of the current pool balance) that are considered Defaulted
Securities as of the September 30, 2010 Trustee report.  Twelve of
these assets (66.2% of the defaulted balance) are RMBS, and two
are CDO (33.8%).  Of the defaulted RMBS securities, ten are
subprime (41.4% of the defaulted balance) and two are jumbo
(24.8%).  Moody's does expect significant losses on the defaulted
securities to occur once they are realized

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.  These parameters are typically modeled as actual
parameters for static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's have completed updated credit estimates for the non-
Moody's rated reference obligations.  The bottom-dollar WARF is a
measure of the default probability within a collateral pool.
Moody's modeled a bottom-dollar WARF of 1,499 compared to 988 at
last review.  The distribution of current ratings and credit
estimates is: Aaa-Aa3 (28.3% compared to 26.5% at last review),
A1-A3 (14.0% compared to 23.8% at last review), Baa1-Baa3 (29.4%
compared to 28.4% at last review), Ba1-Ba3 (5.8% compared to 7.4%
at last review), B1-B3 (7.8% compared to 4.3% at last review), and
Caa1-C (14.7% compared to 9.6% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of 2.0
years compared to 2.8 at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool.  Moody's modeled a fixed WARR
with a mean of 28.2% compared to a mean of 30.7% 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 11.7% compared to 1.3% at last review.
The greater MAC is due to the shift in the ratings distribution
towards higher risk collateral within a small number of collateral
names.

Moody's review incorporated CDOROM(R) v2.6, one of Moody's CDO
rating models, which was released on May 27, 2010.

The cash flow model, CDOEdge(R) v3.2, was used to analyze the cash
flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes.  However,
in many instances, a change in key parameter assumptions in
certain stress scenarios may be offset by a change in one or more
of the other key parameters.  Rated notes are particularly
sensitive to changes in recovery rate assumptions.  Holding all
other key parameters static, changing the recovery rate assumption
down from 28% to 18% or up to 38% would result in average rating
movement on the rated tranches of 0 to 1 notches downward and 0 to
1 notches upward, respectively.

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 stressed macroeconomic environment and
continuing weakness in the commercial real estate and lending
markets.  Moody's currently views the commercial real estate
market as stressed with further performance declines expected in a
majority of property sectors.  The availability of debt capital is
improving with terms returning towards market norms.  Job growth
and housing price stability will be necessary precursors to
commercial real estate recovery.  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's largest
economies, returning to trend growth rate with elevated fiscal
deficits and persistent unemployment levels.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.


SCHOONER TRUST: DBRS Confirms Class G Rating at 'BB'
----------------------------------------------------
DBRS has confirmed these ratings of all 13 classes of Schooner
Trust Commercial Mortgage Pass-Through Certificates, Series 2004-
CF2:

Class A-1 at AAA
Class A-2 at AAA
Class B at AA (high)
Class C at A (high)
Class D at BBB
Class E at BBB (low)
Class F at BB (high)
Class G at BB
Class H at BB (low)
Class J at B (high)
Class K at B
Class L at B (low)
Class X at AAA

The ratings reflect the increased credit enhancement to the bonds
from a collateral reduction of approximately 17% since issuance,
the healthy weighted-average debt service coverage ration (DSCR)
of 1.58x for the pool and the defeasance of seven loans in the
pool, representing 8.32% of the current transaction balance.

There are currently three loans, representing 7.19% of the
transaction, on the servicer's watchlist; two of these loans are
in the Top Ten, representing a combined 6.51% of the pool.
Prospectus ID#12, Confederation Mall, is on the watchlist for an
unauthorized second mortgage on the property.  DBRS also notes
that the anchor tenant, Wal-Mart, with 47% of the NRA, is
currently dark.  Canadian Tire is said to be taking the empty Wal-
Mart space, however, lease details have yet to be provided by the
servicer.  DBRS has placed that loan on the DBRS HotList.

Prospectus ID#14, 215 St. Jacques Street, is on the servicer's
watchlist due to occupancy declines at the property; as of April
2010, the property was 72% occupied, down from 77% at YE2009 and
98% at issuance.  Altus InSite reports the property to be 88%
occupied.  DBRS has requested confirmation of the current
occupancy from the servicer and will continue to monitor the loan.
Given the healthy DSCR at YE2009 of 1.19x and the property's
relatively strong location in MontrĊ al, this loan will not be
placed on the DBRS HotList.

Two other loans in the Top Ten will be placed on the DBRS HotList.

Prospectus ID#10, Hespeler Road Retail, will be placed on the DBRS
HotList due to occupancy declines since YE2009, when it was at
89%, to 81% as of May 2010.  The property is well-located near
Highway 401 in Cambridge, Ontario with large tenants in PetSmart,
Good Life Fitness, and Winners; however, there is significant
competition for retail tenants in the area, which could impact the
property's ability to fill the vacancy at the property.

Prospectus ID#3, DaimlerChrysler Building, remains on the DBRS
HotList due to occupancy declines since YE2008, when the property
was 100% occupied, the property last reported occupancy at 86% as
of the March 2010 rent roll.  The property's largest tenant,
Chrysler Canada, is currently experiencing difficulty with the
downturn in the auto industry.  The property is located in
Windsor, Ontario, an area heavily impacted by the economic
downturn overall.  Furthermore, the loan matures in September
2011.

DBRS applied a net cash flow stress of 20% across all loans in the
pool and when comparing the DBRS required credit enhancement
levels to the current credit enhancement for all classes, the
confirmations as outlined were appropriate.

The negative trend will be maintained on Class K and Class L to
reflect the exposure for those classes to the above-mentioned
issues with Prospectus ID#3 and the other loans in the Top Ten on
the DBRS HotList.  All other classes remain trend stable.

DBRS continues to monitor this transaction on a monthly basis in
the Global CMBS Monthly Surveillance report, which can provide
more detailed information on the individual loans in the pool.


SCHOONER TRUST: DBRS Upgrades Class F Rating to 'BBB' From 'BB'
---------------------------------------------------------------
DBRS has upgraded these ratings of seven classes of Schooner
Trust, Series 2005-3 Commercial Mortgage Pass-Through
Certificates:

Class B to AA (high) from AA
Class C to AA (low) from A
Class D1 to BBB (high) from BBB
Class D2 to BBB (high) from BBB
Class E to BBB from BBB (low)
Class F to BBB (low) from BB (high)
Class G to BB (high) from BB

Additionally, DBRS has confirmed these ratings of the ten classes:

Class A-1 at AAA
Class A-2 at AAA
Class XC1 at AAA
Class XC2 at AAA
Class XP1 at AAA
Class XP2 at AAA
Class H at BB (low)
Class J at B (high)
Class K at B
Class L at B (low)

The ratings upgrades reflect the increased credit enhancement to
the bonds from a collateral reduction of approximately 17% since
issuance.  Additionally, as of the October 2010 remittance, the
weighted-average debt service coverage ratio remains stable at
1.62x.

There are currently seven loans, representing 2.60% of the
transaction, on the servicer's watchlist; DBRS has added one of
these loans to the DBRS HotList.

Prospectus ID#64, White Oak Industrial, is secured by a
(approximately) 192,000 sf industrial property in London, Ontario,
approximately 1 kilometer north of the intersection of Highway 401
and 402.  The loan is on the servicer's watchlist because a tenant
representing 34,000 sf of the net rentable area (NRA) expired on
August 31, 2010.  The servicer has not received an update on the
status of this tenant or the current occupancy rate at the
property.  DBRS will keep this loan on the HotList to monitor the
leasing updates as the borrower provides them to the servicer.
Despite these concerns, the loan benefits from a low loan per
square foot of $13.

DBRS has applied a net cash flow stress of 20% across all loans in
the pool and when comparing the DBRS required credit enhancement
levels to the current credit enhancement at each bond class, the
ratings upgrades are appropriate.

DBRS continues to monitor this transaction on a monthly basis in
the Global CMBS Monthly Surveillance report, which can provide
more detailed information on the individual loans in the pool.


SIENA MORTGAGES: Moody's Assigns Ratings on Four Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional credit ratings
to this class of notes issued by Siena Mortgages 10-7 S.r.l.:

  -- (P) Aaa (sf) to Euro [598.5] Class A1 Residential Mortgage
     Backed Floating Rate Notes due 2070

  -- (P) Aaa (sf) to Euro [800.2] Class A2 Residential Mortgage
     Backed Floating Rate Notes due 2070

  -- (P) Aaa (sf) to Euro [1,263.0] Class A3 Residential Mortgage
     Backed Floating Rate Notes due 2070

  -- (P) Caa1 (sf) to Euro [817.7] Class B Residential Mortgage
     Backed Floating Rate Notes due 2070

Moody's has not assigned any rating to the subordinated Euro Class
D [104.5] Asset Backed Variable Return Notes due August 2070.

                        Ratings Rationale

The ratings of the notes take into account the credit quality of
the underlying mortgage loan pool, from which Moody's determined
the MILAN Aaa Credit Enhancement and the portfolio expected loss,
as well as the transaction structure and any legal considerations
as assessed in Moody's cash flow analysis.  The above structure
has been provided for the purpose of Moody's analysis, this may
not be reflected in the final issuance level.

The expected portfolio loss of 3.35% of the original balance of
the portfolio and the MILAN Aaa required Credit Enhancement of
12.5% served as input parameters for Moody's cash flow model,
which is based on a probabilistic lognormal distribution as
described in the report "The Lognormal Method Applied to ABS
Analysis", published in September 2000.

The transaction represents the ninth securitization of the Siena's
RMBS series, the seventh rated by Moody's.  The assets supporting
the notes, which amount to around EUR 3,479.5 million, are prime
mortgage loans secured on residential properties located in Italy
originated by Banca Monte dei Paschi di Siena SpA (A2/P-1), Banca
Antonveneta, Banca Toscana, Banca Agricola Mantovana and Banca
121, all part of the Banca Monte dei Paschi di Siena Group (Banca
121, BAM and BT merged in BMPS since 2002, 2008 and 2009
respectively; BAV merged in BMPS in 2008 and partly spun off in
2009).  The portfolio will be serviced by BMPS.

The key drivers for the MILAN Aaa Credit Enhancement number, which
is higher than other comparable prime Italian RMBS transactions,
are (i) the weighted average loan-to-value of 58.84%, which is in
line with other Italian RMBS transactions but with an higher than
average portion of loans with current LTV higher than 70% (39.6%),
(ii) missing data on the current arrear status and, for a portion
of the portfolio (26%), on employment type and (iii) comparison
with the historical default static cohorts volatility.

The key drivers for the portfolio expected loss are (i) defaults
on global BMPS residential mortgage book, which have experienced a
substantial increase in the last periods and show high volatility
among vintages (ii) rolls rate derived from previous transactions
and (iii) benchmarking with comparable transactions in the Italian
market.  Moody's believes the assumed expected loss is appropriate
for this transaction.

The structure will benefit from a swap, provided by Royal Bank of
Scotland plc (Aa3/P-1), which guarantees a margin above notes'
index (135 bps) and from an amortizing cash reserve fully funded
at closing for an amount equal to 3% of the rated notes.
Liquidity in the transaction comes from principal to pay interest
and from the cash reserve, but given the replenishment of the cash
reserve will rank junior to payment of interest and principal on
Class B, if the cash reserve has been fully drawn under extreme
cases (such as servicer disruption) there may not be liquidity
available to cover interests on the rated notes; however, the
transaction documents contain certain mechanisms that mitigate
this weakness.

The rating addresses the expected loss posed to investors by the
legal final maturity of the notes.  In Moody's opinion, the
structure allows for timely payment of interest and ultimate
payment of principal on or before the legal final maturity with
respect of the Class A1, Class A2 and Class A3 notes, and ultimate
payment of interest and principal on or before the legal final
maturity with respect of the Class B notes.  Moody's ratings only
address the credit risk associated with the transaction.  Other
non-credit risks have not been addressed, but may have a
significant effect on yield to investors.

The V-Score for this transaction is Low/Medium, which is in line
with the V-Score assigned for the Italian RMBS sector.  Only two
sub components underlying the V Score deviate from the average for
the Italian RMBS sector: i) the "Quality of historical data for
the Issuer/Sponsor/Originator" which is assessed at Medium, higher
than the Low /Medium sector's average, because the securitized
portfolio has mainly (around 83%) been originated in 2009 and
2010: BMPS's originated volumes during these years have almost
doubled the average origination volumes of the preceding five
years and eventually historical data could not represent the
portfolio future performance and ii) "Issuer/Sponsor/Originator's
Historical Performance Variability" because of the high volatility
among static cohorts performance and steep increase in defaults
during the last market downturn.

V-Scores are a relative assessment of the quality of available
credit information and of the degree of dependence on various
assumptions used in determining the rating.  High variability in
key assumptions could expose a rating to more likelihood of rating
changes.  The V-Score has been assigned accordingly to the report
"V-Scores and Parameter Sensitivities in the Major EMEA RMBS
Sectors" published in April 2009.

Moody's Parameter Sensitivities: the model output indicated that
Class A1, Class A2 and Class A3 would have achieved Aaa even if
expected loss was as high as 10.05% (3.0x base case) assuming
Milan Aaa CE at 12.5% (base case) and all other factors remained
the same.  Classes B would have achieved Caa2 for this same
scenario.  The model output further indicated that the Class A1
and Class A2 would have achieved Aaa with Milan Aaa CE of 20.0%
(1.6x base case), and expected loss of 3.35% (base case); Class A3
would have achieved Aa1 and Class B B3 for this same scenario.

Moody's Parameter Sensitivity provide a quantitative/model-
indicated calculation of the number of rating notches that a
Moody's-rated structured finance security may vary if certain
input parameters used in the initial rating process differed.  The
analysis assumes that the deal has not aged and is not intended to
measure how the rating of the security might migrate over time,
but rather how the initial rating of the security might have
differed if key rating input parameters were varied.  Qualitative
factors are also taken into consideration in the ratings process,
so the actual ratings that would be assigned in each case could
vary from the information presented in the Parameter Sensitivity
analysis.

Moody's Investors Service received and took into account a third
party due diligence report on the underlying assets or financial
instruments in this transaction and the due diligence report had a
neutral impact on the rating.


SILVERADO CLO: 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 Silverado CLO 2006-II Limited:

  -- US$20,750,000 Class B Senior Secured Deferrable Floating
     Rate Notes due 2020, Upgraded to Baa3 (sf); previously on
     July 24, 2009 Confirmed at Ba1 (sf)

  -- US$17,500,000 Class C Senior Secured Deferrable Floating
     Rate Notes due 2020, Upgraded to B1 (sf); previously on
     July 24, 2009 Confirmed at B2 (sf).

                        Ratings Rationale

According to Moody's, the rating actions taken on the notes result
primarily from improvement in credit quality of the underlying
portfolio and an increase in the overcollateralization of the
notes since the rating actions in July 2009.

Improvement in the credit quality 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 October 5, 2010, the weighted average rating
factor was 2336 as compared to 2810 in June 2009.  The dollar
amount of defaulted securities has decreased to about $2 million
from approximately $13 million in June 2009.  Based on the October
2010 report, securities rated Caa1/CCC+ or lower make up
approximately 5% of the underlying portfolio versus 11.7% in June
2009.

Additionally, the overcollateralization ratios have increased
since the rating action in June 2009 and are currently all in
compliance.  The Class A, Class B, Class C, and Class D
Overcollateralization Tests are reported at 123.99%, 115.24%,
108.77, and 104.65%, respectively versus June 2009 levels of
121.24%, 112.68%, 106.35%, and 102.33%.

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 its base case, Moody's analyzed the
underlying collateral pool to have a performing par and principal
proceeds of $336.9 million, defaulted par of $3 million, weighted
average default probability of 26.94% (implying a WARF of 3526), a
weighted average recovery rate upon default of 43.36%, and a
diversity score of 55.  These default and recovery properties of
the collateral pool are incorporated in cash flow model analysis
where they are subject to stresses as a function of the target
rating of each CLO liability being reviewed.  The default
probability is derived from the credit quality of the collateral
pool and Moody's expectation of the remaining life of the
collateral pool.  The average recovery rate to be realized on
future defaults is based primarily on the seniority of the assets
in the collateral pool.  In each case, historical and market
performance trends, and collateral manager latitude for trading
the collateral are also factors.

Silverado CLO 2006-II Limited, issued in October 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis described above, Moody's
also performed a number of sensitivity analyses to test the impact
on all rated notes, including these:

1.  Various default probabilities to capture potential defaults in
    the underlying portfolio.

2.  A range of recovery rate assumptions for all assets to capture
    variability in recovery rates.

A summary of the impact of different default probabilities
(expressed in terms of WARF levels) on all rated notes (shown in
terms of the number of notches' difference versus the current
model output, where a positive difference corresponds to lower
expected losses), assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2821)

  -- Class A-1: +2
  -- Class A-1S: 0
  -- Class A-1J: +2
  -- Class A-2: +2
  -- Class B: +3
  -- Class C: +2
  -- Class D: +3

Moody's Adjusted WARF + 20% (4231)

  -- Class A-1: -2
  -- Class A-1S: -2
  -- Class A-1J: -2
  -- Class A-2: -2
  -- Class B: -1
  -- Class C: -2
  -- Class D: -2

A summary of the impact of different recovery rate levels on all
rated notes (shown in terms of the number of notches' difference
versus the current model output, where a positive difference
corresponds to lower expected losses), assuming that all other
factors are held equal:

Moody's Adjusted WARR + 2% (45.36 %)

  -- Class A-1: 0
  -- Class A-1S: 0
  -- Class A-1J: 0
  -- Class A-2: 0
  -- Class B: +1
  -- Class C: 0
  -- Class D: +1

Moody's Adjusted WARR - 2% (43.36%)

  -- Class A-1: -1
  -- Class A-1S: -1
  -- Class A-1J: -1
  -- Class A-2: -1
  -- Class B: 0
  -- Class C: -1
  -- Class D: -1

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the managers'
investment strategies and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are described
below:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deals'
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus selling defaulted
   assets create additional uncertainties.  Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings.  Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels.  Moody's analyzed the impact of assuming lower
   of reported and covenanted values for weighted average rating
   factor, weighted average spread, weighted average coupon, and
   diversity score.  With respect to the weighted average spread,
   Moody's analyzed the impact assuming a mid-point between the
   reported and the covenanted value to give some credit to the
   deal's higher weighted average spread.


SOLAR TRUST: DBRS Confirms Class F Rating at 'BB'
-------------------------------------------------
DBRS has confirmed the ratings of six classes of Solar Trust
commercial mortgage pass-through certificates, Series 2001-1 and
placed four classes on trend negative.

These classes were confirmed and have a Stable trend:

Class A-2 at AAA
Class B at AAA
Class C at AAA
Class IO at AAA
Class D at A (high)
Class E at A

Classes F through J were also confirmed but placed on trend
Negative.
Class F at BB (high)
Class G at BB
Class H at B
Class J at B (low)

DBRS does not rate the $3.6 million first loss piece, Class K.

The rating confirmations recognize the significant increase in
credit enhancement caused by collateral reduction (amortization
and loan maturities) of approximately 70% since issuance.
Additionally, there are no delinquent or specially serviced loans.

There are six loans on the servicer's watchlist, representing a
combined 28.47% of the current pool balance.  The ratings are
constrained by the poor performance of a number of these loans
and, correspondingly, DBRS has placed Negative trends on the four
lowest rated classes.  DBRS has placed six of these loans on the
DBRS HotList for further review.

The DBRS analysis included an in-depth look at the top ten loans
in the transaction, in addition to the loans on the servicer's
watchlist.  Cumulatively, these loans represent approximately
92.5% of the current pool balance.  DBRS has run a cash flow
stress of 20% across all the loans in the transaction and compared
the DBRS required credit enhancement levels to the current
increased credit enhancement levels and found the ratings
confirmations to be appropriate.

DBRS will continue to monitor this transaction on a monthly basis
and provide further detail on the transaction and the HotListed
loans in the Global Monthly CMBS Surveillance Report.


SOLOSO CDO: Fitch Downgrades Ratings on Two Classes of Notes
------------------------------------------------------------
Fitch Ratings has downgraded two classes of notes from Soloso CDO
2007-1, Ltd. following a payment default on scheduled interest
due:

  -- $254,166,677 class A-1LA notes downgraded to 'Dsf' from
     'BBBsf';

  -- $83,000,000 class A-1LB notes downgraded to 'Dsf' from 'Bsf'.

Fitch's downgrades are based upon the failure to make full
payments of interest due to the class A-1LA and A-1LB (class A-1)
notes, which is considered an event of default according to the
transaction documents.  On the Oct. 7, 2010 payment date, the
class A-1 notes received a payment of $690,479 of its aggregate
$694,506 of scheduled interest, representing 99.4%.

Since Fitch's last rating actions in September 2010, the portfolio
in Soloso II experienced an additional $25.75 million of new
deferrals which reduced interest proceeds by approximately
$315,658.  Additional collateral deterioration further eroded
available credit enhancement to service CDO liabilities.
Subsequently, the Senior Interest Coverage Ratio fell from 188.46%
at the last payment date in July 2010 to 100.71% as of the most
recent payment date in October 2010.

In addition, the Loss Severity Ratings and Negative Outlook have
been removed for the class A-1LA and A-1LB notes.


SOUNDVIEW HOME: Moody's Downgrades Ratings on Three Tranches
------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three
tranches and confirmed the ratings of two tranches from three RMBS
transactions issued by Soundview Home Loan Trusts.  The collateral
backing these deals primarily consists of closed end second lien
loans.

                        Ratings Rationale

The actions are a result of the continued performance
deterioration in second lien pools in conjunction with home price
and unemployment conditions that remain under duress.  The actions
reflect Moody's updated loss expectations on second lien pools.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment remains at high
levels, and weakness persists in the housing market.  Moody's
notes an increasing potential for a double-dip recession, which
could cause a further 20% decline in home prices (versus its
baseline assumption of roughly 5% further decline).  Overall,
Moody's assumes a further 5% decline in home prices with
stabilization in early 2011, accompanied by continued stress in
national employment levels through that timeframe.

If expected losses on the each of the collateral pools were to
increase by 10%, model implied results indicate that most of the
deals' ratings would remain stable, with the exception of Class M-
2 and M-3 from Soundview Home Loan Trust 2005-A for which model
implied results would be one notch lower (for example, Ba2 versus
Ba1, or Ca versus Caa3).  Class M-1 from Soundview Home Loan Trust
2005-B model implied results would be two notches lower.

Moody's Investors Service received and took into account one or
more third party due diligence reports on the underlying assets or
financial instruments in this transaction and the due diligence
reports had a neutral impact on the rating.

Complete rating actions are:

Issuer: Soundview Home Loan Trust 2005-A

  * Expected Losses (as a % of Original Balance): 24%

  -- Cl. M-2, Confirmed at Baa1 (sf); previously on March 18, 2010
     Baa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. M-3, Confirmed at B1 (sf); previously on March 18, 2010
     B1 (sf) Placed Under Review for Possible Downgrade

Issuer: Soundview Home Loan Trust 2005-B

  * Expected Losses (as a % of Original Balance): 31%

  -- Cl. M-1, Downgraded to Baa3 (sf); previously on March 18,
     2010 Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. M-2, Downgraded to Ca (sf); previously on March 18, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

Issuer: Soundview Home Loan Trust 2006-A

  * Expected Losses (as a % of Original Balance): 62%

  -- Cl. A, Downgraded to C (sf); previously on March 18, 2010 Ca
     (sf) Placed Under Review for Possible Downgrade


ST JOSEPH: Moody's Downgrades Rating on $18.6 Mil. Bonds to 'B2'
----------------------------------------------------------------
Moody's Investors Service has downgraded to B2 from Ba3 the long-
term rating assigned to St. Joseph Health Services of Rhode
Island's $18.6 million of outstanding bonds.  The outlook is
negative.  At this time Moody's are removing the rating from
Watchlist where it was placed on September 28, 2010.  The rating
downgrade reflects the material decline in liquidity and financial
performance through the first eleven months of FY 2010, driven
largely by significant declines in admissions.  The negative
outlook reflects the risks of continued admission declines and
operating losses while management implements a turnaround plan.
The outlook also reflects Moody's belief that unrestricted cash
could decline further if cash flow does not improve given cash
needs for capital and debt service.

Legal Security: The Series 1999 bonds are secured by a pledge of
gross receipts of SJHS and a first priority mortgage and security
interest on certain of SJHS's property including land and
buildings.

Interest Rate Derivatives: None

                        Ratings Rationale

                            Challenges

* Weak unrestricted cash and investments with $10.9 million or
  23.8 days cash on hand as of August 31, 2010, down from
  $15.4 million or 31.5 days at the end of fiscal year (FY) 2009;
  ability to maintain and increase liquidity is a key credit
  concern

* Sharp decline in financial performance through the first eleven
  months of FY 2010 ending August 31, 2010, resulting in a
  $12.2 million operating loss; management does not expect to meet
  the rate covenant; consultant call-in required

* Significant 13.6% decline in inpatient medical/surgical
  admissions through August 31, 2010, compared to the prior year
  comparable period and driving most of the financial decline

* Competitive Providence with the presence of large health care
  systems

* Weak economy of Rhode Island with 11.5% unemployment

* Unionized nursing workforce; nursing contract expires in July
  2011

                            Strengths

* Active implementation of the turnaround plan, aided by an
  outside consulting firm engaged earlier this year, should
  provide some financial improvement in FY 2011; goal is to
  breakeven in FY 2011; all areas of revenue, expenses and
  operational processes are under review for improvement

* Anticipated system savings of between $15 million and
  $22 million over a three year period following the January 2010
  affiliation with Roger Williams Medical Center (not rated by
  Moody's) and the creation of CharterCare, the new parent
  corporation of both hospitals; savings to be achieved through
  the consolidation of all back-office functions (already
  completed), upcoming clinical consolidation between the two
  hospitals and other areas of improvement identified by the
  outside consultant

* New management team in place at SJHS following the departure of
  prior senior management; CEO was instrumental in the turnaround
  at Roger Williams Medical Center in the mid-2000 period and
  serves as CEO of SJHS, RWMC and CharterCare; CFO joined in May
  2010 and has worked with the CEO in the past

* All fixed rate debt structure; debt service reserve fund is
  fully funded and untapped; cash conservatively invested

                    Recent Developments/Results

The downgrade to B2 from Ba3 and the maintenance of the negative
outlook reflects SJHS's weakened financial performance and very
thin cash position.  Through the first eleven months of FY 2010
ending August 31, 2010, the operating loss has grown to
$12.2 million (-8.3% operating margin) while operating cash flow
is a negative $5.4 million (-3.7% operating cash flow margin).
Unrestricted cash and investments has declined to a very thin
$10.9 million or 23.8 days.  Cash to debt is below average at
51.6%.

The primary driver to the decline in financial performance is a
precipitous decline in volumes.  Through August 31, 2010,
inpatient medical/surgical admissions declined a material 13.8%
from the prior year period, due to the impact of the economy and a
reduction in patients seeking medical care, as well as some
disruption in volumes following difficult union negotiations in
2008.  As a result, revenues are down 11% from the prior year
period.  The loss is also due to an overvaluation of receivables
identified by the new management team; $3.6 million of the loss in
FY 2010 reflects FY 2009 overvaluations while $1.9 million
reflects the new methodology now being applied in FY 2010.
Management estimates that the true "run rate" of operations will
be an $11 million loss in FY 2010 and does not expect to meet the
rate covenant.  Consultant call-in is required.

Shortly after the affiliation with Roger Williams Medical Center
(discussed further below) in January 2010 management hired an
outside consulting firm to review all areas of operations and
establish productivity benchmarks for both facilities.  Revenue
and expense opportunities totaling between $15 million and
$22 million over a 3-year period have been identified with the
majority at SJHS.  A reduction in force has recently occurred (49
FTEs) and other cost reduction measures including length of stay
reductions, supply chain management, and revenue cycle
improvements.  Moody's note that after many years of planning and
seeking approval, SJHS consolidated all acute care services at its
Fatima campus which will help with cost reductions.  The St.
Joseph's campus is being used for outpatient health clinic
services.  Management is in active negotiations to sell the St.
Joseph's campus to a third-party developer and would lease a small
portion of the space for outpatient health clinic services via an
operating lease.  Moody's have not incorporated the potential sale
into Moody's analysis at this time.

While the FY 2011 budget isn't ready at this time, management's
goal is to reach breakeven performance through this turnaround
plan.  Maintenance of the B2 rating will largely depend on
management's ability to reach breakeven performance and increase
liquidity.  Cash declined to $10.9 million or 23 days, from
$15.4 million or 31.5 days at the end of FY 2009 due to $6 million
in capital expenditures and negative cash flow.  There is no line
of credit at this time.  Management plans to increase liquidity
through improved cash flow, a gain on the sale of the St. Joseph's
campus, and the receipt of federal funds for IT/meaningful use
regulation.  Annual debt service payments have been about
$3.5 million per annum (bonds, notes and leases) and an estimated
capital budget of $4 million in FY 2011 could require the use of
liquidity.  The debt service reserve remains fully funded and
management reports that it is making monthly debt service
payments.

On January 4, 2010, SJHS affiliated with Roger Williams Medical
Center (not rated by Moody's), located about 2.5 miles away.
Roger Williams Medical Center is similarly sized with $185 million
in revenues in FY 2009 and is a teaching hospital for Boston
University School of Medicine.  Both hospitals have similar
service arrays with neither hospital offering obstetrics nor
pediatrics.  Unlike SJHS, RWMC is not unionized and has also
experienced minor volume declines of about 3%; positive operating
margin performance is anticipated for FY 2010.  Moody's note that
both hospitals' debt obligations remain separately secured.

As part of the affiliation, a new parent organization,
CharterCare, was created and serves as the sole member of both
hospitals.  The CharterCare board is comprised of eight
representatives from SJHS and seven from Roger Williams Medical
Center.  The Monsignor is currently Vice Chair of the board.  The
CEO of Roger Williams Medical Center is also the CEO of
CharterCare and SJHS; he was instrumental in RWMC's turnaround a
few years ago.  A new system CFO joined in May from Faulkner
Hospital in Boston, part of Partners Healthcare System.  The CEO
and CFO worked together previously at Faulkner.  Quickly after the
affiliation, management merged all back office functions such as
IT, human resources, finance and legal.  Management is now
planning for some service line consolidations between the two
hospitals.  Despite the weak financial performance and liquidity
position, Moody's are encouraged by management's past experience
and quick reaction to the financial challenges at SJHS.  These
factors are precluding a downgrade to a lower level at this time.

According to Moodyseconomy.com, the Providence-New Bedford-Fall
River economy has hit bottom and is finally starting to show signs
of recovery.  Employment has held level since January, while a
declining labor force participation rate has tightened the labor
market despite the lack of job creation.  After having peaked at
12.7%, the unemployment rate is now at 11.5%.  Manufacturing
employment has stabilized thanks to a resurgence in exports, which
has been underpinned by growing demand for primary metal products
and Sensata electronic sensors.  State-funded building projects,
combined with the stabilization of residential construction, have
enabled construction employment to rise for the first time in
three years.  A glut of office space is tempering the recovery in
commercial construction, however.  Finally, the Rhode Island
government reports that tax revenues are starting to rise,
ameliorating the budget situation.

                             Outlook

The negative outlook reflects the risks of continued admission
declines and operating losses while management implements a
turnaround plan.  The outlook also reflects Moody's belief that
unrestricted cash could decline if cash flow does not improve
given cash needs for capital and debt service.

                What could change the rating -- Up

Unlikely, given the negative outlook.  Over the longer term, an
upgrade would be contingent upon improved financial performance
that is sustainable and a material increase in liquidity

               What could change the rating -- Down

Failure to show financial improvement, bankruptcy filing or
tapping of the reserve fund

Based on financial statements for St. Joseph Health Services of
Rhode Island

  -- First number reflects Audit year ended September 30, 2009

  -- Second number reflects unaudited financial performance
     through eleven months ending August 31, 2010

  -- Investment returns normalized at 6% unless otherwise noted
     and restated as non-operating income

* Inpatient admissions: 6,980; 5,611

* Total operating revenues: $181.4 million; $148.2 million

* Moody's-adjusted net revenue available for debt service:
  $4.7 million; -$4.7 million

* Total debt outstanding (includes notes and leases):
  $23.3 million; $21.3 million

* Maximum annual debt service (MADS): $3.4 million; $3.4 million

* MADS Coverage with reported investment income: 1.21 times; -1.71
  times

* Moody's-adjusted MADS Coverage with normalized investment
  income: 1.37 times; -1.52 times

* Debt-to-cash flow: 6.82 times; -3.28 times

* Days cash on hand: 31.5 days; 23.8 days

* Cash-to-debt: 31.5%; 23.8%

* Operating margin: -1.9%; -8.3%

* Operating cash flow margin: 2.2%; -3.7%

                            Rated Debt

* Series 1999 fixed rate bonds: $18.6

The last rating action with respect to SJHS was on September 28,
2010, when the Ba3 rating was placed on Watchlist for possible
downgrade.


STEDMAN LOAN: Moody's Upgrades Ratings on Various Classes
---------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Stedman Loan Fund II, Ltd.:

  -- US$404,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Notes Due May 15, 2015 (current balance of
     156,337,501), Upgraded to Aaa (sf); previously on August 26,
     2009 Downgraded to Aa3 (sf);

  -- US$21,000,000 Class A-2 Second Priority Senior Secured
     Floating Rate Notes Due May 15, 2015, Upgraded to Aa3 (sf);
     previously on August 26, 2009 Downgraded to Baa2 (sf);

  -- US$22,000,000 Class B Third Priority Mezzanine Secured
     Deferrable Floating Rate Notes Due May 15, 2015, Upgraded to
     Baa2(sf); previously on August 26, 2009 Downgraded to B1
     (sf).

                        Ratings Rationale

According to Moody's, the rating actions taken on the notes result
primarily from the delevering of the Class A-1 Notes, which have
been paid down by approximately 48% or $144 million since the last
rating action in August 2009.  Moody's expects delevering of the
Class A-1 Notes to continue as the transaction is not permitted to
acquire additional collateral obligations after the effective
date.  As a result of the delevering, the overcollateralization
ratios have increased since the last rating action in August 2009.
As of the latest trustee report dated October 5, 2010, the Class A
and Class B overcollateralization ratios are reported at 135.1%
and 122.2%, respectively, versus July 2009 levels of 120.5% and
113.3%, respectively.  The Class A and Class B
overcollateralization ratios are currently in compliance.

Moody's notes that the deal has benefited from improvement in the
credit quality of the underlying portfolio since the last rating
action.  Moody's adjusted WARF has declined since the last rating
action due to a decrease in the percentage of securities with
ratings on "Review for Possible Downgrade" or with a "Negative
Outlook." Furthermore, based on the October 2010 trustee report,
securities rated Caa1 and below make up approximately 5.0% of the
underlying portfolio versus 7.0% in July 2009.  The deal also
experienced a decrease in defaults.  In particular, there are
currently no reported defaulted securities compared to
approximately $15 million reported in 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.  In its base case, Moody's analyzed the
underlying collateral pool to have a performing par and principal
proceeds of $245 million, defaulted par of $6 million, weighted
average default probability of 22.39% (implying a WARF of 3760), a
weighted average recovery rate upon default of 43.50%, and a
diversity score of 44.  These default and recovery properties of
the collateral pool are incorporated in cash flow model analysis
where they are subject to stresses as a function of the target
rating of each CLO liability being reviewed.  The default
probability is derived from the credit quality of the collateral
pool and Moody's expectation of the remaining life of the
collateral pool.  The average recovery rate to be realized on
future defaults is based primarily on the seniority of the assets
in the collateral pool.  In each case, historical and market
performance trends, and collateral manager latitude for trading
the collateral are also factors.

Stedman Loan Fund II, Ltd. issued in March 2008, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis described above, Moody's
also performed a number of sensitivity analyses to test the impact
on all rated notes, including these:

1.  Various default probabilities to capture potential defaults in
    the underlying portfolio.

2.  A range of recovery rate assumptions for all assets to capture
    variability in recovery rates.

Below is a summary of the impact of different default
probabilities (expressed in terms of WARF levels) on all rated
notes (shown in terms of the number of notches' difference versus
the current model output, where a positive difference corresponds
to lower expected losses), assuming that all other factors are
held equal:

Moody's Adjusted WARF - 20% (3008)

  -- Class A-1: 0
  -- Class A-2: +2
  -- Class B: +2

Moody's Adjusted WARF + 20% (4512)

  -- Class A-1: -1
  -- Class A-2: -2
  -- Class B: -2

Below is a summary of the impact of different recovery rate levels
on all rated notes (shown in terms of the number of notches'
difference versus the current model output, where a positive
difference corresponds to lower expected losses), assuming that
all other factors are held equal:

Moody's Adjusted WARR + 2% (45.50)

  -- Class A-1: 0
  -- Class A-2: +1
  -- Class B: 0

Moody's Adjusted WARR - 2% (41.50)

  -- Class A-1: 0
  -- Class A-2: 0
  -- Class B: -1

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the managers'
investment strategies and behavior, and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are described
below:

1) Delevering: The main source of uncertainty in this transaction
   is whether delevering from unscheduled principal proceeds will
   continue and at what pace.  Delevering may accelerate due to
   high prepayment levels in the loan market and/or collateral
   sales by the manager, which may have significant impact on the
   notes' ratings.

2) Long-dated assets: The presence of assets that mature beyond
   the CLO's legal maturity date exposes the deal to liquidation
   risk on those assets. Moody's assumes an asset's terminal value
   upon liquidation at maturity to be equal to the lower of an
   assumed liquidation value (depending on the extent to which the
   asset's maturity lags that of the liabilities) and the asset's
   current market value.


SWISS CHEETAH: Moody's Adjusts Ratings on Bonds to 'B1'
-------------------------------------------------------
Moody's adjusts the rating of US$37.5M Swiss Cheetah 7 B Bond to
B1 (sf) and corrects the title of the PR to Moody's upgrades Swiss
Cheetah LLC Asset Protection Transaction 7 B, a CSO.  The revised
release is:

                 $37.5M of CDS Notional Affected

Moody's Investors Service announced that it has upgraded its
rating on a CDS entered with Swiss Cheetah LLC Asset Protection
Transaction 7 B, a collateralized debt obligation transaction
referencing a static portfolio of corporate entities.

Issuer: Swiss Cheetah LLC Asset Protection Transaction 7

  -- US$37.5 million Swiss Cheetah 7 B Bond, Upgraded to B1 (sf);
     previously on Sept. 18, 2009 Downgraded to Caa2 (sf)

                        Ratings Rationale

Moody's explained that the rating action taken is the result of
the credit improvement of the portfolio and shorter time to
maturity of the deal.  The 10 year weighted average rating factor
of the current portfolio is 919, equivalent to Ba1.  This compares
to a 10-year WARF of 1151 equivalent to Ba2 from the last rating
review.  Since the last rating action, the bucket of assets rated
Caa and below went from 11% to 7% and there have been no credit
events.  The notes have a remaining life of 2.7 years and credit
enhancement of 6.4%.

In the process of determining the rating action, Moody's took into
account the results of a number of sensitivity analyses:

(1) Use of Market Implied Ratings -- MIRs were used in place of
    the corporate fundamental ratings to derive the default
    probability of each corporate name in the reference portfolio.
    The gap between an MIR and a Moody's corporate fundamental
    rating is an indicator of the extent of the divergence of
    credit view between Moody's and the market. This run generated
    a result that was one notch lower than the model result under
    the base case.

(2) Defaulted all Caa Referenced Entities -- To test the deal
    sensitivity to the lowest rated entities of the portfolio, all
    Caa exposures were assumed as defaulted.  This run generated a
    result that was four notches lower than the model result under
    the base case.

(3) Removal of forward-looking measures -- The notching adjustment
    on each entity's rating due to watch for downgrade or negative
    outlook was removed, resulting in no difference from the base
    case.

(4) Reduction of time to maturity -- Time to maturity was reduced
    by a year and by six months, all other things being equal.
    These runs generated a result that were one notch better than
    the base case.

(5) Stress on largest industry group -- All entities in the
    Banking, Insurance, Finance and Real Estate were notched down
    by one, the largest sector concentration representing 27% of
    the portfolio notional. The result of this run was two notches
    worse than the base case.

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.

Moody's analysis for this transaction is based on CDOROMv2.6.
This model is available on moodys.com under Products and Solutions
-- Analytical models, upon return of a signed free license
agreement.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Corporate Synthetic
Obligations", key model inputs used by Moody's in its analysis may
be different from the manager/arranger's reported numbers.  In
particular, rating assumptions for all publicly rated corporate
credits in the underlying portfolio have been adjusted for "Review
for Possible Downgrade", "Review for Possible Upgrade", or
"Negative Outlook".

Moody's did not run a separate loss and cash flow analysis other
than the one already done using the CDOROM model.  For a
description of the analysis, refer to the methodology and the
CDOROM user guide on Moody's website.

Moody's analysis of corporate CSOs is subject to uncertainties,
the primary sources of which includes complexity, governance and
leverage.  Although the CDOROM model capture many of the dynamics
of the Corporate CSO structure, it remains a simplification of
the complex reality.  Of greatest concern are (a) variations
over time in default rates for instruments with a given rating,
(b) variations in recovery rates for instruments with particular
seniority/security characteristics and (c) uncertainty about the
default and recovery correlations characteristics of the reference
pool.  Similarly on the legal/structural side, the legal analysis
although typically based in part on opinions (and sometimes
interpretations) of legal experts at the time of issuance, is
still subject to potential changes in law, case law and the
interpretations of courts and (in some cases) regulatory
authorities.  The performance of this CSO is also dependent on on-
going decisions made by one or several parties, including the
Manager and the Trustee.  Although the impact of these decisions
is mitigated by structural constraints, anticipating the quality
of these decisions necessarily introduces some level of
uncertainty in Moody's assumptions.  Given the tranched nature of
Corporate CSO liabilities, rating transitions in the reference
pool may have leveraged rating implications for the ratings of the
Corporate CSO liabilities, thus leading to a high degree of
volatility.  All else being equal, the volatility is likely to be
higher for more junior or thinner liabilities.

The base case scenario modeled fits into the central macroeconomic
scenario predicted by Moody's of a sluggish recovery scenario of
the corporate universe.  Should macroeconomic conditions evolve
towards a more severe scenario such as a double dip recession, the
CSO rating will likely be downgraded to an extent depending on the
expected severity of the worsening conditions.


TCW SELECT: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, D-1, and D-2 notes, and the composite securities issued by
TCW Select Loan Fund Ltd., a collateralized loan obligation
transaction managed by TCW Asset Management Co. In addition,
Standard & Poor's withdrew its rating on the class A-2 notes.  The
upgrades reflect the improved performance S&P has observed in the
underlying portfolio since March 2010, when S&P lowered the
ratings on all rated notes junior to the A-2 notes in the capital
structure following a review of the transactions under S&P's
updated criteria for rating corporate collateralized debt
obligations published in September 2009.

According to the trustee report dated Jan. 29, 2010, the
transaction was holding approximately $7 million in defaulted
obligations and $24 million in underlying obligors with a rating,
either by Standard & Poor's or another rating agency, in the 'CCC'
range.  Since that time, the transaction has sold a number of
defaulted loans held in the deal for higher than the expected
recovery value as provided by the transaction documents.  As of
Sept. 30, 2010, the transaction was holding just $2 million in
defaulted obligations and $11.7 million in underlying obligors
with ratings in the 'CCC' range.

The reduction in the 'CCC' range assets and the $51 million
paydown on the class A-2 and B notes has reduced the overall
credit risk for the remaining outstanding notes.  However, the
transaction contains some relatively large credit positions, and
S&P based the ratings on the class C, D-1, and D-2, and composite
notes, in part, on the application of the largest-obligor default
test, which is one of the supplemental stress tests S&P introduced
as part of its criteria update published in September 2009.

To date, the TCW Select Loan Fund Ltd. transaction has paid down
the class A-1 and A-2 notes in full and the class B notes to
approximately 78.8% of their original outstanding balance.

Standard & Poor's will continue to review whether, in its view,
the ratings currently assigned to the notes remain consistent with
the credit enhancement available to support them and take rating
actions as S&P deem necessary.

                  Rating And Creditwatch Actions

                     TCW Select Loan Fund Ltd.

     Class                   To           From
     -----                   --           ----
     B                       AAA (sf)     AA+ (sf)/Watch Pos
     C                       A+ (sf)      A (sf)/Watch Pos
     D-1                     B+ (sf)      CCC+ (sf)
     D-2                     B+ (sf)      CCC+ (sf)
     Composite securities    B+ (sf)      CCC+ (sf)

                        Ratings Withdrawn

                    TCW Select Loan Fund Ltd.

          Class                   To           From
          -----                   --           ----
          A-2                     NR           AAA (sf)

                         NR -- Not rated.


TIERS SYNTHETIC: Moody's Downgrades Rating on Certs. to 'C'
-----------------------------------------------------------
Moody's has downgraded one class of Notes issued by TIERS
Synthetic CDO-Linked Variable Coupon Trust, Series 2008-1 due to
deterioration in the credit quality of the underlying portfolio of
reference obligations as evidenced by an increase in the weighted
average rating factor and related decrease in the weighted average
recovery rate.  The rating action is the result of Moody's on-
going surveillance of commercial real estate collateralized debt
obligation transactions.

Issuer: TIERS Synthetic CDO-Linked Variable Coupon Trust, Series
2008-1

  -- US$36,000,000 TIERS Synthetic CDO-Linked Variable Coupon
     Trust Certificates, Series 2008-1 Certificate, Downgraded to
     C (sf); previously on Feb. 10, 2010 Downgraded to Caa3 (sf)

                        Ratings Rationale

TIERS 2008-1 is a synthetic CRE CDO transaction backed by a
portfolio of reference obligations.  The reference obligations are
comprised of commercial mortgage backed securities (95%) and CRE
CDO notes (5%).  All of the CMBS reference obligations were
securitized between 2005 and 2007.  The aggregate collateral par
amount is $1 billion, the same as at securitization.  There have
been no pay-downs or losses to the collateral pool.

The trustee does not list underlying defaulted or impaired assets.
However, as of October 2010, per the underlying trustee reports on
each of the underlying CMBS transactions, there are forty-three
reference obligations with a par balance of $596 million (59.6% of
the current pool balance) that have interest shortfalls.
Additionally, there are thirty-seven reference obliations with a
par balance of $408.1 million (40.8% of the pool balance) that are
either Moody's rated or credit estimated at Ca or C.  While there
have been no realized losses to date, Moody's does expect
significant losses to the underlying reference obligations to
occur once they are realized.

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.  These parameters are typically modeled as actual
parameters for static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's have completed updated credit estimates for the non-
Moody's rated reference obligations.  The bottom-dollar WARF is a
measure of the default probability within a collateral pool.
Moody's modeled a bottom-dollar WARF of 6,132 compared to 4,928 at
last review.  The distribution of current ratings and credit
estimates is: A1-A3 (0.0% compared to 2.0% at last review), Baa1-
Baa3 (3.0% compared to 3.8% at last review), Ba1-Ba3 (11.0%
compared to 12.8% at last review), B1-B3 (33.2% compared to 43.0%
at last review), and Caa1-C (52.8% compared to 38.4% at last
review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of 4.8
years compared to 5.5 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 a variable
WARR with a mean of 4.2% compared to a mean of 5.7% 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 100.0% compared to 24.6% at last review.
The increase in MAC is due to a greater concentration of Ca and C
rated collateral within a small number of names.

Moody's review incorporated CDOROM(R) v2.6, one of Moody's CDO
rating models, which was released on May 27, 2010.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes.  However,
in many instances, a change in key parameter assumptions in
certain stress scenarios may be offset by a change in one or more
of the other key parameters.  Rated notes are particularly
sensitive to changes in recovery rate assumptions.  Holding all
other key parameters static, changing the recovery rate assumption
down from 4.2% to 1.7% or up to 6.7% would result in average
rating movement on the rated tranches of 1 notch downward and 0
notches upward, respectively.

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 stressed macroeconomic environment and
continuing weakness in the commercial real estate and lending
markets.  Moody's currently views the commercial real estate
market as stressed with further performance declines expected in a
majority of property sectors.  The availability of debt capital is
improving with terms returning towards market norms.  Job growth
and housing price stability will be necessary precursors to
commercial real estate recovery.  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's largest
economies, returning to trend growth rate with elevated fiscal
deficits and persistent unemployment levels.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.


TRINITY HIGHER: Fitch Affirms Ratings on Senior Student Loans
-------------------------------------------------------------
Fitch Ratings affirms the senior student loan note and downgrades
the subordinate note issued by Trinity Higher Education Authority,
Inc. - 2004 Indenture.  The Rating Outlook remains Stable for the
senior note, and a Stable Rating Outlook and 'LS3' Loss Severity
rating are assigned to the subordinate note.

Fitch used its 'Global Structured Finance Rating Criteria', 'U.S.
Private SL ABS Criteria' and 'FFELP Student Loan ABS Rating
Criteria, as well as the refined basis risk criteria outlined in
Fitch's Sept. 22, 2010 press release 'Fitch to Gauge Basis Risk in
Auction-Rate U.S. FFELP SLABS Review' to review the ratings.

The rating on the senior note is affirmed based on the sufficient
level of credit enhancement consisting of subordination and
projected minimum excess spread to cover the applicable risk
factor stresses.

The rating on the subordinate note is downgraded to 'B' due to the
trust's very high cost structure that will limit the trust's
ability to generate excess spread and reach parity of 100%.

For the portion of trust that is backed by private student loans,
Fitch conducted a review of the collateral performance that
involved the calculation of loss coverage multiples based on the
most recent data.  A projected net loss amount was compared to
available credit enhancement to determine the loss multiples.
Fitch used a proxy loss timing curve representative of the private
student loan collateral pool.  After giving credit for seasoning
of loans in repayment, Fitch applied the current cumulative gross
loss level to this loss timing curve to derive the expected gross
losses over the remaining life for the trust.  Zero recovery was
applied, which was determined to be appropriate based on the
private loans characteristics in the trust and the latest data
provided by the issuer.  In addition, Fitch assumed excess spread
to be the lesser of the current annualized excess spread; the
average historical excess spread; and the most recent 12-month
average excess spread, and applied that same rate over the
remaining life.

Trinity Higher Education Authority, Inc. - 2004 Indenture consists
of FFELP and private student loans.

Fitch has taken these rating actions:

Trinity Higher Education Authority, Inc. - 2004 Indenture:

Series 2004

  -- Class A-1 affirmed at 'AAA/LS1'; Outlook Stable;
  -- Class B-1 downgraded to 'B/LS3' from 'BB'; Outlook Stable.


UNITED COMMERCIAL: S&P Downgrades Rating on Class A Certificates
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
A certificates from United Commercial Mortgage Securities Trust
2007-1.  At the same time, S&P placed its rating on the class M
certificates on CreditWatch with negative implications.

The downgrade of class A follows the downgrade of Assured Guaranty
Corp. to 'AA+'.  The rating on class A reflects the insurance
policy provided by AGC guaranteeing the scheduled payment of
principal and interest for the class.

S&P placed its rating on class M on CreditWatch negative pending
its review of the transaction in light of deterioration in the
performance of the collateral pool.

As of the remittance report dated Sept. 28, 2010, the collateral
pool consisted of 210 loans with an aggregate principal balance
of $259.3 million, compared with 307 loans with a balance of
$402.5 million at issuance.  All of the properties securing the
loans are in California.

There are 14 loans ($20.4 million, 7.9%) with the special
servicer.  The largest loan with the special servicer has a
balance of $3.1 million (1.2%) and is secured by a 41,890-sq.-ft.
retail property in Ontario, Calif.  The second-largest loan with
the special servicer is secured by a retail property in San
Francisco with an outstanding balance of $2.5 million (1%).  Of
the specially serviced loans, five are real estate owned, three
are 90-plus days delinquent, and two are 60 days delinquent.

S&P will update or resolve its CreditWatch negative placement on
class M following its review of the transaction and the underlying
collateral.

                         Rating Lowered

        United Commercial Mortgage Securities Trust 2007-1

                                Rating
                                ------
        Class         To                          From
        -----         --                          ----
        A             AA+ (sf)                    AAA (sf)

              Rating Placed On Creditwatch Negative

        United Commercial Mortgage Securities Trust 2007-1

                                   Rating
                                   ------
        Class        To                           From
        -----        --                           ----
        M            BB-(sf)/Watch Neg            BB- (sf)


US CAPITAL: Moody's Downgrades Ratings on Five Classes of Notes
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded five
classes of notes issued by U.S. Capital Funding V, Ltd.:

  -- US$193,000,000 Class A-1 Floating Rate Senior Notes Due
     2040 (current balance of $150,857,756), Downgraded to B3
     (sf); previously on March 27, 2009 Downgraded to Ba1 (sf);

  -- US$30,000,000 Class A-2 Floating Rate Senior Notes Due
     2040, Downgraded to Caa3 (sf); previously on March 27, 2009
     Downgraded to Ba3 (sf);

  -- US$42,000,000 Class A-3 Floating Rate Senior Notes Due
     2040, Downgraded to Ca (sf); previously on March 27, 2009
     Downgraded to B2 (sf);

  -- US$48,000,000 Class B-1 Deferrable Floating Rate Senior
     Subordinate Notes Due 2040 (current balance of $49,341,848),
     Downgraded to C (sf); previously on March 27, 2009 Downgraded
     to Caa3 (sf);

  -- US$10,000,000 Class B-2 Deferrable Fixed/Floating Rate
     Senior Subordinate Notes Due 2040 (current balance of
     $11,021,005), Downgraded to C (sf); previously on March 27,
     2009 Downgraded to Caa3 (sf).

                        Ratings Rationale

U.S. Capital Funding V, Ltd., issued on October 3, 2006, is a
collateral debt obligation backed by a portfolio of bank trust
preferred securities and senior secured corporate loans (the 'TRUP
CDO').  The last rating action for this transaction was on
March 27, 2009.  At that time, Moody's downgraded five classes of
notes as a result of the application of revised and updated key
modeling assumptions, as well as the deterioration in the credit
quality of the transaction's underlying portfolio.

Moody's indicated that the rating actions on the notes are
primarily the result of an increase in the assumed defaulted
amount of the pool.  The defaults increased by $103.50M since the
last rating action on March 27, 2009.  Moody's assumed default
amount currently totals $148.97 million (45.6% of the portfolio)
and are almost exclusively comprised of bank trust preferred
assets.  All of the assumed defaulted assets are carried at zero
recovery in Moody's analysis.  The remaining assets in the
portfolio have shown a slight improvement, as indicated by a WARF
decrease to 2496, from 2608 as of the last rating action date.
This current WARF accounts for a credit estimate stress, described
in Moody's Rating Methodology "Updated Approach to the Usage of
Credit Estimates in rated Transactions", October 2009.  Currently,
63.8% of the portfolio is estimated to be Ba1 or below, as
determined by using both the FDIC Q1-2010 financial data in
conjunction with Moody's RiskCalc model to assess non-publicly
rated bank trust preferred securities and public ratings and
credit estimates to assess the middle market loans.

The par loss due to the increase in the assumed defaulted amount
has resulted in loss of overcollateralization for the tranches
affected and an increase of their expected losses since the last
rating action.  In addition, the overcollateralization tests
continue to breach their triggers, resulting in a diversion of
excess spreads to pay down senior notes.  As of the latest trustee
report dated October 5, 2010, the Senior Principal Coverage Test
is 86.4%, the Senior Subordinate Principal Coverage Test is
68.08%, and the Mezzanine Principal Coverage Test is 63.98%,
versus trustee reported levels from the report dated January 6,
2009, of 125.21%, 102.46%, and 97.28% respectively, which were
used during the last rating action.

In Moody's analysis, Moody's assume that there are no prepayments
and the assets amortize at their final maturity.  The weighted
average life of the portfolio is approximately 18.8 years.

The credit deterioration exhibited by TRUP CDO portfolios is a
reflection of the continued pressure in the banking sector as the
number of bank failures and interest deferrals of bank trust
preferred securities has continued to increase.  According to FDIC
data, a total of 307 banks have failed to date since the onset of
the current economic crisis in 2007; 258 have failed since the
date of the last rating action.  In Moody's opinion, the banking
sector outlook continues to remain negative.

This portfolio is composed mainly of trust preferred securities
issued by small to medium sized U.S. community bank that are
generally not publicly rated by Moody's.  To evaluate their credit
quality, Moody's derives credit scores for these non-publicly
rated trust preferred securities.  Moody's evaluation of these
assets relies on financial data received for a majority of
obligors in the pool as of Q1-2010.

The financial data is used by Moody's to assess the credit quality
of obligors in the pool, relying on RiskCalc, an econometric model
developed by Moody's KMV.  The results obtained from the RiskCalc
model have been translated to Moody's rating scale and adjusted by
one notch where necessary in order to compensate for the absence
of credit indicators such as rating reviews, outlooks and
adjustments factoring in cyclical developments in the economy.

Many of the loans corporate loans used defaults probabilities that
were assessed through credit estimates.  Moody's applied
additional default probability stresses on these estimates by
assuming an equivalent of Caa3 for CEs that were not updated
within the last 15 months, a 1.5 notch-equivalent assumed
downgrade for CEs that were last updated between 12-15 months ago,
and a 0.5 notch-equivalent assumed downgrade for CEs last updated
between 6-12 months ago.  Current senior secured corporate loan
estimates account for approximately 12.8% of the performing
collateral balance.

Moody's evaluates the sensitivity of the rated transactions to the
volatility of the credit estimates, as described in Moody's Rating
Methodology "Updated Approach to the Usage of Credit Estimates in
Rated Transactions," October 2009.  For each credit score or
credit estimate where the related exposure constitutes more than
3% of the collateral pool, Moody's applied a 2-notch equivalent
assumed downgrade (but on the CEs representing in aggregate the
largest 30% of the pool) in lieu of the aforementioned stresses.
Notwithstanding the foregoing, in all cases the lowest assumed
rating equivalent is Caa3.  The effect of stress testing of these
credit scores varies between one and three notches, depending on
the total amount and relative size of these securities in the
collateral pool.

Moody's performed a number of sensitivity analyses of the results
to some of the key factors driving the ratings.  The sensitivity
of the model results to the WARF (representing a slight
improvement and a slight deterioration of the credit quality of
the collateral pool) was examined.  If WARF is increased by 20
points from the base case of 2496, the model results in an
expected loss that is one notch worse than the result of the base
case for Class A-1.  If the WARF is decreased by 475 points,
expected losses are one notch better than the base case results.
Additionally, the effects of higher and lower Moody's Asset
Correlation resulted in these: Increasing the MAC by 9 percentage
points yielded an expected loss that was one notch worse than the
base case for Class A-1.  Similarly, decreasing the MAC by 10
percentage points from the base case resulted in an expected loss
that was not enough to move the rating by one notch from the base
case for Class A-1.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  Moody's considers as well the structural
protections in each transaction, risk Event of Default, 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.

Due to the impact of revised and updated key assumptions
referenced in these rating methodologies, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers.  In
particular, rating assumptions for all publicly rated corporate
credits in the underlying portfolio have been adjusted for "Review
for Possible Downgrade", "Review for Possible Upgrade", or
"Negative Outlook".

The transaction's portfolio was modeled, according to Moody's
rating approach, using CDOROMTM v.2.6 to develop the loss
distribution from which the Moody's Asset Correlation parameter
was obtained.  This parameter was then used as an input in a cash
flow model using CDOEdge.  CDOROMTM v.2.6 is available on
moodys.com under Products and Solutions -- Analytical models, upon
return of a signed free license agreement.

Moody's Investors Service did not receive or take into account a
third-party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.


VERICREST FINANCIAL: Moody's Reviews Ratings on Four Tranches
-------------------------------------------------------------
Moody's has placed on review for possible downgrade four tranches
from three transactions backed by recreational vehicle and marine
installment sales contracts serviced by Vericrest Financial, Inc.
Vericrest Financial, Inc., formerly known as CIT Group/Sales
Financing, Inc., was acquired by Lone Star Funds in 2009.

Issuer: CIT RV Trust 1998-A

  -- Class B, Baa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 11, 2006 Confirmed at Baa3 (sf)

  -- Certificates, Ca (sf) Placed Under Review for Possible
     Downgrade; previously on July 11, 2006 Downgraded to Ca (sf)

Issuer: CIT RV Trust 1999-A

  -- Class B, Caa2 (sf) Placed Under Review for Possible
     Downgrade; previously on Nov. 14, 2008 Downgraded to Caa2
     (sf)

Issuer: CIT Marine Trust 1999-A

  -- Certificates, Baa2 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 18, 2009 Downgraded to Baa2
     (sf)

  -- Certificates, Underlying Baa2 (sf) Placed Under Review for
     Possible Downgrade, previously on Feb. 24, 1999 Underlying
     rating assigned Baa2 (sf)

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

                        Ratings Rationale

The reviews were prompted by the impact of continued stress in
macroeconomic conditions on the performance of the affected
transactions.  Unlike other vehicle-backed ABS, the impact here
has been more severe and long lasting due to the non-essential
nature of the underlying collateral, and the longer financing
terms, which on average range between 170 and 185 months.  As a
result, these transactions have experienced more than one economic
downturn during their lives.

Moody's expects CIT RV Trust 1998-A to incur lifetime cumulative
net losses in the range of 8.65% to 8.75% of the original pool
balance, compared to expectations of 2.50% at closing.  Total hard
credit enhancement (excluding excess spread of approximately 2.00%
per annum) for class B notes is approximately 4.43% of the
outstanding collateral pool balance.  The transaction is under-
collateralized by $ 5,703,684 which is equal to almost the entire
amount of the outstanding certificates.

For the CIT RV Trust 1999-A Moody's expects the lifetime CNL to be
in the range of 9.70% to 9.80% of the original pool balance,
compared to expectations of 2.50% at closing.  The transaction is
under-collateralized by $18,618,050 and both the certificates and
the class B notes are accruing losses.

Moody's expects the CIT Marine Trust 1999-A to incur lifetime CNL
in the range of 6.60% to 6.70% of the original pool balance,
compared to expectations of 4.75% at closing.  Total hard credit
enhancement (excluding excess spread of approximately 1.5% per
annum) for the certificates is approximately 12% of the remaining
collateral balance.

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 RV and marine
market.  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.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.


WACHOVIA AUTO: Fitch Corrects Press Release; Upgrades Ratings
-------------------------------------------------------------
Fitch Rating has made a correction for a release issued on
Oct. 29, 2010.  It amends the Outlooks for class D, which is
revised to Positive from Stable, and class E, which remains
Stable.

Fitch has upgraded three classes of the Wachovia Auto Loan Owner
Trust 2006-2 transaction and affirmed one class as part of its on
going surveillance process.

Although the collateral continues to perform outside of Fitch's
expectations, the securities can withstand stress scenarios
consistent with the recommended rating categories and still make
full payments of interest and principal in accordance with the
term of the documents.

The ratings reflect the servicing capabilities of Wachovia Bank
N.A., the high quality of retail auto receivables originated by
WFS Financial Inc., and the sound legal and cash flow structures.

The securities are backed by a pool of new and used automobile and
light-duty truck installment loans originated by WFS, a subsidiary
of Wachovia.

Fitch has taken these rating actions on Wachovia Auto Loan Owner
Trust series 2006-2:

  -- Class B notes upgraded to 'AAAsf' from 'AAsf'; Outlook
     Stable;

  -- Class C notes upgraded to 'AAAsf' from 'Asf'; Outlook Stable;

  -- Class D notes upgraded to 'Asf' from 'BBB+sf'; Outlook to
     Positive from Stable;

  -- Class E affirmed at 'BBsf'; Outlook Stable.


WACHOVIA AUTO: Fitch Upgrades Ratings on Three Classes of Notes
---------------------------------------------------------------
Fitch Ratings has upgraded three classes of the Wachovia Auto Loan
Owner Trust 2006-2 transaction and affirmed one class as part of
its on going surveillance process.

Although the collateral continues to perform outside of Fitch's
expectations, the securities can withstand stress scenarios
consistent with the recommended rating categories and still make
full payments of interest and principal in accordance with the
term of the documents.

The ratings reflect the servicing capabilities of Wachovia Bank
N.A., the high quality of retail auto receivables originated by
WFS Financial Inc., and the sound legal and cash flow structures.

The securities are backed by a pool of new and used automobile and
light-duty truck installment loans originated by WFS, a subsidiary
of Wachovia.

Fitch has taken these rating actions on Wachovia Auto Loan Owner
Trust series 2006-2:

  -- Class B notes upgraded to 'AAAsf' from 'AAsf'; Outlook
     Stable;

  -- Class C notes upgraded to 'AAAsf' from 'Asf'; Outlook Stable;

  -- Class D notes upgraded to 'Asf' from 'BBB+sf'; Outlook
     Stable;

  -- Class E affirmed at 'BBsf'; Outlook to Positive from Stable.


WACHOVIA AUTO: S&P Raises Ratings on Various Classes of Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
C and D notes from Wachovia Auto Loan Owner Trust series 2006-1,
2006-2, 2007-1, and 2008-1; the class B notes from series 2007-1
and 2008-1; and the class E notes from series 2006-2 and 2007-1.
In addition, S&P affirmed its ratings on the seven remaining
classes of notes from these four series.

The rating actions reflect the transactions' collateral
performance to date, S&P's views regarding future collateral
performance, and the credit enhancement available.  Specifically,
the upgrades and affirmations reflect growth in credit support as
a percent of the amortizing pool balances compared with S&P's
expectations for remaining losses.  Although S&P has increased its
initial or most recent lifetime loss expectations for these series
based on higher-than-expected default frequencies and loss
severities, the classes with raised and affirmed ratings were able
to withstand cash flow stress scenarios at their respective rating
levels using S&P's revised loss expectations.

All four transactions have a sequential principal payment
structure with credit enhancement in the form of
overcollateralization, a reserve account, subordination for the
more senior tranches, and excess spread.

                             Table 1

                    Collateral Performance (%)*

                            60-plus Initial   Former    Current
             Pool   Current day     lifetime  lifetime  lifetime
  Series Mo. factor CNL     delinq. CNL exp.  CNL exp.  CNL exp.
  ------ --- ------ ------- ------- --------  --------  --------
  2006-1 48  11.70  5.82    1.26    3.75-4.00 5.30-5.60 5.95-6.15
  2006-2 47  11.98  5.81    1.60    3.75-4.00 5.30-5.70 5.95-6.15
  2007-1 40  18.04  6.65    1.37    3.75-4.00 6.25-6.75 7.00-7.30
  2008-1 32  30.03  5.70    1.21    4.25-4.75 N/A       6.85-7.15

  * Current cumulative net loss expectations are based on current
    performance data.

                             Table 2

                    Hard Credit Support (%) (i)
            (As of the October 2010 distribution date)

                                                 Current
                                    Total hard   total hard
                                    credit       credit
                          Pool      support at   support
    Series       Class    factor    issuance     (% of current)
    ------       -----    ------    ----------   --------------
    2006-1       B        11.70      9.25        74.80
    2006-1       C        11.70      5.25        43.64
    2006-1       D        11.70      2.00        15.82
    2006-2       B        11.98     10.00        89.75
    2006-2       C        11.98      6.00        56.35
    2006-2       D        11.98      2.75        29.22
    2006-2       E        11.98      0.25         8.35
    2007-1       A        18.04     14.50        84.52
    2007-1       B        18.04     10.75        63.74
    2007-1       C        18.04      6.75        41.57
    2007-1       D        18.04      2.75        19.40
    2007-1       E        18.04      0.25         5.54
    2008-1       A        30.03     17.00        58.85
    2008-1       B        30.03     13.25        46.37
    2008-1       C        30.03      8.75        31.38
    2008-1       D        30.03      3.00        12.24
    2008-1       E        30.03      0.50         3.91

(i) Consists of a reserve account, overcollateralization, and
    subordination, and excludes excess spread.  Series 2006-1
    classes C and D also include a secondary reserve fund.

The transaction documents for WALOT 2006-1 specify a reserve
account with a floor of 0.50% of the initial pool balance.  They
also specify an O/C amount with a target of 5.0% of the current
pool balance minus the reserve account balance, and a floor of
1.0% of the initial pool balance.  Both the O/C and the reserve
account are currently at their respective floor levels.  WALOT
2006-1 class C and D also benefit from a secondary reserve
account, which is currently at its target 3.0% of the current pool
balance as a result of a breach of a cumulative net loss
performance trigger.

Series 2006-2 initially started with a 0.25% reserve account
building to a target and floor of 0.50% of the initial pool
balance and an O/C amount building to 1.0% of the current pool
balance with a floor of 0.50% of the initial pool balance.  Both
the reserve account and O/C amount are at their respective floor
levels.

Series 2007-1 also initially started with a 0.25% reserve account
building to a target and floor of 0.50% of the initial pool
balance, but with an O/C amount building to 1.25% of the current
pool balance with a floor of 0.50% of the initial pool balance.
Both the reserve account and O/C amount are at their respective
floor levels.

Series 2008-1 contains a nonamortizing reserve account of 0.50% of
the initial pool balance and an O/C amount that builds to 2.25% of
the current pool balance with a floor of 0.50% of the initial pool
balance.  The reserve account and O/C amount are at their
respective target levels.

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

S&P will continue to monitor the performance of these transactions
to assess whether the credit enhancement remains sufficient, in
S&P's view, to support the ratings on each class under various
stress scenarios.

                          Ratings Raised

                 Wachovia Auto Loan Owners Trust

                                   Rating
                                   ------
              Series   Class   To         From
              ------   -----   --         ----
              2006-1   C       AAA (sf)   AA (sf)
              2006-1   D       AAA (sf)   BBB+ (sf)
              2006-2   C       AAA (sf)   AA (sf)
              2006-2   D       AAA (sf)   BBB+ (sf)
              2006-2   E       AA+ (sf)   BB (sf)
              2007-1   B       AAA (sf)   AA (sf)
              2007-1   C       AAA (sf)   A (sf)
              2007-1   D       AAA (sf)   BBB (sf)
              2007-1   E       A- (sf)    BB (sf)
              2008-1   B       AAA (sf)   AA (sf)
              2008-1   C       AAA (sf)   A (sf)
              2008-1   D       A (sf)     BBB (sf)

                        Ratings Affirmed

                 Wachovia Auto Loan Owners Trust

                    Series   Class   Rating
                    ------   -----   ------
                    2006-1   B       AAA (sf)
                    2006-2   B       AAA (sf)
                    2007-1   A-3a    AAA (sf)
                    2007-1   A-3b    AAA (sf)
                    2008-1   A-3     AAA (sf)
                    2008-1   A-4     AAA (sf)
                    2008-1   E       BB- (sf)


WACHOVIA BANK: Fitch Downgrades Ratings on 10 2005-C20 Certs.
-------------------------------------------------------------
Fitch Ratings has downgraded 10 classes of Wachovia Bank
Commercial Mortgage Trust, series 2005-C20 commercial mortgage
pass-through certificates, due to increased expected losses
corresponding to nine recently transferred specially serviced
loans as well as one top-15 loan expected to see future
performance deterioration.

The downgrades of classes E through G are attributable largely to
the transfer to special servicing of nine relatively small loans
(2.4%) subsequent to the previous Fitch rating action.  In
addition, Fitch assigned modeled losses to one loan (2.0%) that is
expected to lose its single tenant as the loan matures.  The
liquidation of the Macon & Burlington Mall Pool loan triggered the
downgrades of classes H through O to 'D/RR6' from 'C/RR6' as the
classes sustained actual realized losses, but the timing and
relative magnitude of the losses fell within the expected range.
Although there has been a net increase in modeled losses of
approximately 0.4% of the initial pool balance relative to the
previous review, 33 loans (13.2% of the IPB) paid off in 2010.
The increased credit enhancement has provided additional loss
protection, resulting in affirmations of the remaining classes.

As of the October 2010 distribution date, the pool's aggregate
principal balance has been reduced by 26.2% to $2.70 billion from
$3.66 billion at issuance, including paydown of 22.7% and realized
losses of 3.5%.  Six loans (1.4%) are currently defeased.  As of
October 2010, cumulative interest shortfalls affect classes F
through H.

Fitch identified 38 Loans of Concern (17.4%), including three top-
15 loans (7.2%) and 11 specially serviced loans (3.0%).  The
largest specially serviced loan (0.6%) transferred Oct. 1, 2010,
and is 90 days delinquent.  The loan is secured by a 95,870-square
foot industrial flex building located in Brooklyn, NY that has
served as a production studio since its development.  Reportedly
the single-tenant sublessee recently stopped paying rent and
vacated when its television series was cancelled.  Due to the
recent nature of the transfer, the special servicer is in the
process of reviewing the loan file to determine a workout
strategy.

The second largest specially serviced loan (0.5%) is secured by
a 140-room hotel property located in Norfolk, VA.  The loan
transferred in April 2010 as the borrower sought a loan extension
prior to the June 2010 maturity date.  The servicer-reported debt
service coverage ratio was 1.26 times as of year-end 2009.  The
special servicer is dual-tracking a potential modification and
foreclosure.  No other specially serviced loan represents more
than 0.4% of the pool balance.

Subsequent to the previous review, the $55.2 million (pari passu
portion) 101 Avenue of the Americas loan became a Fitch Loan of
Concern.  According to several media sources, the property's
single tenant, Local 32B-32J of the Service Employees
International Union, has elected not to renew its lease that is
coterminous with the loan's December 2011 maturity date.  The
space is currently being marketed for lease.  The loan remained
current and approximately $8.5 million in reserves ($21 per sf)
were available for leasing costs as of the October 2010 remittance
date.

Fitch has downgraded and assigned Recovery Ratings to these
classes as indicated:

  -- $41.2 million class E to 'Bsf/LS5' from 'BBsf/LS5'; Outlook
     Negative;

  -- $41.2 million class F to 'CCCsf/RR1' from 'B-sf/LS5';

  -- $32.1 million class G to 'CCCsf/RR1' from 'B-sf/LS5';

  -- $39.5 million class H to 'Dsf/RR6' from 'Csf/RR6'.

Classes J, K, L, M, N, and O were each downgraded to 'Dsf/RR6'
from 'Csf/RR6' as they were reduced to zero due to losses realized
on loans liquidated from the trust.

Fitch has affirmed and revised the Loss Severity rating and
Outlook on this class:

  -- $68.7 million class D to 'BBsf/LS4' from 'BBsf/LS5'; Outlook
     to Negative from Stable.

In addition, Fitch has affirmed these classes and Outlooks and has
revised LS ratings as indicated:

  -- $11.1 million class A-4 at 'AAAsf/LS1'; Outlook Stable;

  -- $121.1 million class A-5 at 'AAAsf/LS1'; Outlook Stable;

  -- $218.8 million class A-6A at 'AAAsf/LS1'; Outlook Stable;

  -- $50 million class A-6B at 'AAAsf/LS1'; Outlook Stable;

  -- $171.5 million class A-PB at 'AAAsf/LS1'; Outlook Stable;

  -- $861.8 million class A-7 at 'AAAsf/LS1'; Outlook Stable;

  -- $300.1 million class A-1A at 'AAAsf/LS1'; Outlook Stable;

  -- $100 million class A-MFL at 'AAAsf/LS3'; Outlook Stable;

  -- $266.4 million class A-MFX at 'AAAsf/LS3'; Outlook Stable;

  -- $274.8 million class A-J at 'AAsf/LS3'; Outlook Stable;

  -- $77.9 million class B to 'BBBsf/LS4' from 'BBBsf/LS5';
     Outlook Stable;

  -- $27.5 million class C at 'BBBsf/LS5'; Outlook Stable.

The unrated class P was reduced to zero due to realized losses.
Classes A-1, A-2, and A-3SF have paid in full.  Fitch has
withdrawn the ratings on the interest-only classes X-P and X-C.


WACHOVIA BANK: Fitch Downgrades Ratings on 13 2005-C22 Certs.
-------------------------------------------------------------
Fitch Ratings has downgraded 13 classes of Wachovia Bank
Commercial Mortgage Trust, 2005-C22 commercial mortgage pass-
through certificates primarily due to an increase in expected
losses from the loans in special servicing.

As a result of the expected losses on loans currently in special
servicing, Fitch expects classes H through Q to be fully depleted.
Fitch's current expected losses on the pool have increased from
9.2% at the last review to 10.9%.  As of the October 2010
distribution date, the pool's aggregate principal balance has been
paid down by 4.4% to $2.4 billion from $2.5 billion at issuance.
Two loans (0.5%) are currently defeased.  As of October 2010,
cumulative interest shortfalls affect classes H through P.

Fitch has designated 29 loans (27.5%) as Fitch Loans of Concern,
which includes 15 specially serviced loans (17.7%).  Of the
specially serviced loans, three (9.5%, are in the top 15.  The
largest specially serviced loan (6.1%) is secured by the Westin
Casuarina Hotel and Spa, an 826-room full-service hotel located a
quarter of a mile east of the Las Vegas Strip.  The property was
constructed in 1977 and underwent an extensive repositioning and a
$90 million renovation in 2002, when it was reopened under the
Westin flag.  As of the trailing 12 months (TTM) ended September
2009 occupancy was 60% and the debt service coverage ratio (DSCR)
was 0.88x compared to issuance underwriting of 75.5% and 1.66
times, respectively.  The loan transferred in March 2010 due to
imminent default.  The special servicer is pursuing foreclosure
while talks continue with the borrower on a possible modification.

The next largest specially serviced loan (1.9%) is secured by an
87% leased 508,976 square foot regional mall located in Lake
Wales, FL.  The loan was transferred in April 2009 when the
borrower, General Growth Properties, filed for bankruptcy.  As
part of its restructuring, GGP has identified this property as one
that may not be able to service debt in the future and the
borrower has issued a deed in lieu of foreclosure.  The special
servicer is in the process of installing a receiver.

The third largest specially serviced loan is secured by the
Brittania Business Center, a 276,210 sf office property located in
Pleasanton, CA.  The loan transferred to the special servicer in
May 2009 due to imminent default when the largest tenant (51% of
net rentable area) vacated its space at year end 2008 leaving the
property 43% occupied.  A receiver has been put in place and the
property is being marketed for sale.

Fitch stressed the value of the non-defeased loans by applying a
5% haircut to 2009 fiscal year-end net operating income and
applying an adjusted market cap rate between 7.25% and 10% to
determine value.

Similar to Fitch's prospective analysis of recent vintage
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 DSCR of 1.25x or higher were considered to
pay off at maturity.  Of the non-defeased or non-specially
serviced loans, 100 loans (74.2% of the overall pool) were assumed
not to be able to refinance, of which Fitch modeled losses for 36
loans (24.9%) in instances where Fitch's derived value was less
than the outstanding balance.

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

  -- $152 million class A-J to 'BBB-sf/LS4' from 'BBB/LS4';
     Outlook to Negative from Stable;

  -- $25.3 million class D to 'Bsf/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $47.5 million class E to 'B-sf/LS5' from 'B/LS5'; Outlook
     Negative;

  -- $31.7 million class F to 'CCCsf/RR1' from 'B-/LS5';

  -- $28.5 million class G to 'CCCsf/RR3' from 'B-/LS5';

  -- $28.5 million class H to 'CCsf/RR6' from 'B-/LS5';

  -- $34.8 million class J to 'CCsf/RR6' from 'B-/LS5';

  -- $15.8 million class K to 'CCsf/RR6' from 'B-/LS5';

  -- $12.7 million class L to 'CCsf/RR6' from 'CCC/RR6';

  -- $12.7 million class M to 'CCsf/RR6' from 'CCC/RR6';

  -- $6.3 million class N to 'Csf/RR6' from 'CCC/RR6';

  -- $6.3 million class O to 'Csf/RR6' from 'CCC/RR6';

  -- $9.5 million class P to 'Csf/RR6' from 'CCC/RR6'.

Fitch has affirmed and revised the LS ratings of these classes:

  -- $36.9 million class A-2 to 'AAAsf/LS3' from 'AAA/LS2';
     Outlook Stable;

  -- $164.6 million class A-3 to 'AAAsf/LS3' from 'AAA/LS2';
     Outlook Stable;

  -- $148.5 million class A-PB to 'AAAsf/LS3' from 'AAA/LS2';
     Outlook Stable;

  -- $941 million class A-4 to 'AAAsf/LS3' from 'AAA/LS2'; Outlook
     Stable;

  -- $374.3 million class A-1A to 'AAAsf/LS3' from 'AAA/LS2';
     Outlook Stable.

Fitch has affirmed these classes:

  -- $253.4 million class A-M at 'AAAsf/LS4'; Outlook Stable;
  -- $22.2 million class B at 'BBsf/LS5'; Outlook Negative;
  -- $31.7 million class C at 'BBsf/LS5'; Outlook Negative.

The $41.2 million class Q is not rated by Fitch.  Class A-1 has
paid in full.  Fitch has withdrawn the ratings on the interest-
only class IO.


WACHOVIA BANK: Moody's Reviews Ratings on 10 2005-C18 Certs.
------------------------------------------------------------
Moody's Investors Service placed ten classes of Wachovia Bank
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2005-C18 on review for possible downgrade:

  -- Cl. A-J-1, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on June 6, 2005 Definitive Rating
     Assigned Aaa (sf)

  -- Cl. A-J-2, Aa3 (sf) Placed Under Review for Possible
     Downgrade; previously on Oct. 15, 2009 Downgraded to Aa3 (sf)

  -- Cl. B, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 15, 2009 Downgraded to A2 (sf)

  -- Cl. C, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 15, 2009 Downgraded to Baa1 (sf)

  -- Cl. D, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 15, 2009 Downgraded to Baa3 (sf)

  -- Cl. E, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 15, 2009 Downgraded to Ba1 (sf)

  -- Cl. F, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 15, 2009 Downgraded to Ba3 (sf)

  -- Cl. G, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 15, 2009 Downgraded to B2 (sf)

  -- Cl. H, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 15, 2009 Downgraded to Caa2 (sf)

  -- Cl. J, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 15, 2009 Downgraded to Ca (sf)

The classes were placed on review due to higher expected losses
for the pool resulting from anticipated losses from specially
serviced and troubled loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated October 15, 2009.

                   Deal And Performance Summary

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 12% to
$1.23 billion from $1.41 billion at securitization.  The
Certificates are collateralized by 58 mortgage loans ranging in
size from less than 1% to 17% of the pool, with the top ten loans
representing 53% of the pool.

Eight loans, representing 12% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (formerly the 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 pool has realized a $4.4 million loss due to the modification
of one loan.  Nine loans, representing 18% of the pool, are
currently in special servicing.  The specially serviced loans are
secured by a mix of multifamily, office, retail, self storage and
mixed use property types.  The master servicer has recognized
appraisal reductions totaling $14.8 million for four of the
specially serviced loans.

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


WACHOVIA BANK: Moody's Confirms Ratings on Three 2005-C21 Certs.
----------------------------------------------------------------
Moody's Investors Service confirmed the ratings of three classes,
affirmed six classes and downgraded seven classes of Wachovia Bank
Commercial Mortgage Trust Commercial Mortgage Pass-Through
Certificates, Series 2005-C21:

  -- Cl. A-3, Affirmed at Aaa (sf); previously on Nov. 10, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-PB, Affirmed at Aaa (sf); previously on Nov. 10, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed at Aaa (sf); previously on Nov. 10, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-1A, Affirmed at Aaa (sf); previously on Nov. 10, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. IO, Affirmed at Aaa (sf); previously on Nov. 10, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-M, Affirmed at Aaa (sf); previously on Nov. 10, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-J, Confirmed at Aa2 (sf); previously on Sept. 30, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Confirmed at A1 (sf); previously on Sept. 30, 2010 A1
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Confirmed at A3 (sf); previously on Sept. 30, 2010 A3
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to Baa3 (sf); previously on Sept. 30, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to Ba2 (sf); previously on Sept. 30, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to B1 (sf); previously on Sept. 30, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to Caa1 (sf); previously on Sept. 30, 2010
     Ba2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. H, Downgraded to Caa3 (sf); previously on Sept. 30, 2010
     B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. J, Downgraded to Caa3 (sf); previously on Sept. 30, 2010
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. K, Downgraded to Ca (sf); previously on Sept. 30, 2010 B3
     (sf) Placed Under Review for Possible Downgrade

                        Ratings Rationale

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans.  The confirmations and affirmations
are due to key parameters, including Moody's loan to value ratio,
Moody's stressed debt service coverage ratio and the Herfindahl
Index, remaining within acceptable ranges.  Based on Moody's
current base expected loss, the credit enhancement levels for the
affirmed classes are sufficient to maintain their current ratings.

On September 30, 2010, Moody's placed ten classes on review for
possible downgrade.  This action concludes Moody's review.

Moody's rating action reflects a cumulative base expected loss of
6.5% of the current balance compared to 4.4% at Moody's prior
review.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term.  From time
to time, Moody's may, if warranted, change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the current
review.  Even so, deviation from the expected range will not
necessarily result in a rating action.  There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortization and loan payoffs or a decline in subordination due to
realized losses.

Primary sources of assumption uncertainty are the current stressed
macroeconomic environment and continuing weakness in the
commercial real estate and lending markets.  Moody's currently
views the commercial real estate market as stressed with further
performance declines expected in the industrial, office, and
retail sectors.  Hotel performance has begun to rebound, albeit
off a very weak base.  Multifamily has also begun to rebound
reflecting an improved supply / demand relationship.  The
availability of debt capital is improving with terms returning
towards market norms.  Job growth and housing price stability will
be necessary precursors to commercial real estate recovery.
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's largest economies, returning to trend growth rate
with elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl score
, a measure of loan level diversity, is a primary determinant of
pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the credit estimate of the
loan which corresponds to a range of credit enhancement levels.
Actual fusion credit enhancement levels are selected based on loan
level diversity, pool leverage and other concentrations and
correlations within the pool.  Negative pooling, or adding credit
enhancement at the credit estimate level, is incorporated for
loans with similar credit estimates in the same transaction.

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 action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated November 12, 2009.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 27% to
$2.38 billion from $3.25 billion at securitization.  The
Certificates are collateralized by 214 mortgage loans ranging in
size from less than 1% to 8% of the pool, with the top ten loans
representing 41% of the pool.  The pool contains two loans with
investment-grade credit estimates, which represent 6% of the pool.
Four loans, representing 3% of the pool, have defeased and are
collateralized by U.S. Government securities.

Forty-eight 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 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 last review,
resulting in an aggregate $18.0 million loss (39% loss severity on
average).  Currently, 12 loans, representing 5% of the pool, are
in special servicing.  The largest specially serviced loan is the
110 North Wacker Drive Loan ($28.3 million -- 1% of the pool),
which is secured by a 227,000 square foot office property located
in Chicago, Illinois.  The borrower is General Growth Properties
(GGP) and the building serves as GGP's corporate headquarters.
The loan was transferred to special servicing in January 2010 due
to GGP's bankruptcy filing.  The loan has been modified to include
a four year extension, a $16 million principal pay down and
increased amortization over the life of the extension period.
Moody's anticipates no loss for this loan at the moment.  Moody's
LTV and stressed DSCR are 75% and 1.29%, respectively, compared to
119% and 0.94X at last review.

The remaining 11 specially serviced loans are secured by a mix of
property types.  The master servicer has recognized an aggregate
$21.1 million appraisal reduction for five of the specially
serviced loans.  Moody's has estimated an aggregate loss of
$46.0 million (51% expected loss on average) for the specially
serviced loans.

Moody's has also assumed a high default probability for 14 poorly
performing loans representing 11% of the pool.  Moody's has
estimated a $50.5 million loss (20% expected loss based on a 50%
probability default) from the troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 88% and 60% of the pool, respectively.
Moody's weighted average LTV for the conduit component, excluding
specially serviced and troubled loans, is 102% compared to 105% at
Moody's prior review.  Moody's net cash flow reflects a weighted
average haircut of 12.5% to the most recently available net
operating income.  Moody's value reflects a weighted average
capitalization rate of 9.0%.

Moody's actual and stressed DSCRs for the conduit component,
excluding specially serviced and troubled loans, are 1.34X and
1.0X, respectively, compared to 1.32X and 0.98X 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 risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 33 compared to 39 at Moody's prior review.

The largest loan with a credit estimate is the Extra Space
Teamsters Portfolio Loan ($92.1 million -- 3.9% of the pool),
which is secured by a portfolio of 28 self-storage properties
located in 16 states.  As of June 2010, the weighted average
occupancy was 87% compared to 84% at last review.  Despite the
increase in occupancy, the portfolio's performance has declined
due to a 6% drop in base revenues in 2009.  Moody's credit
estimate and stressed DSCR are Baa2 and 1.46X, respectively,
compared to A3 and 1.56X at last review.

The second loan with a credit estimate is the Extra Space VRS
Portfolio Loan ($52.1 million -- 2.2% of the pool), which is
secured by a portfolio of 22 self-storage properties located in 14
states.  As of June 2010, the weighted average occupancy was 86%
compared to 85% at last review.  The portfolio's performance has
been stable.  Moody's credit estimate and stressed DSCR are Aa1
and 2.10X, respectively, compared to Aa1 and 2.13X at last review.

The top three performing conduit loans represent 19% of the pool.
The largest loan is the NGP Rubicon GSA Pool Loan ($194.1 million
-- 8.1% of the pool), which represents a 50% pari passu interest
in a $388.2 million first mortgage loan.  The loan is secured by a
portfolio of 13 office properties and one distribution center
located in ten states and the District of Columbia.  Various
federal government agencies occupy over 94% of the portfolio's
leasable area.  As of December 2009, the portfolio was 97% leased,
the same as at last review.  Moody's LTV and stressed DSCR are
111% and 0.84X, respectively, compared to 111% and 0.87X at last
review.

The second largest conduit loan is the Abbey Pool Loan ($142.6
million -- 6% of the pool), which is secured by a portfolio of 20
properties located in California.  The properties are concentrated
in Riverside County (44%) and Los Angeles County (40%).  As of
December 2009, the portfolio was 85% leased compared to 96% at
last review.  The portfolio's performance has declined due lower
base revenues and higher expenses.  Moody's LTV and stressed DSCR
are 112% and 0.89X, respectively, compared to 104% and 0.96X at
last review.

The third largest conduit loan is the Metropolitan Square Loan
($125.5 million -- 5.3% of the pool), which represents the A-note
of a $151 million first mortgage loan.  The loan is secured by a
987,300 square foot office building located in St.  Louis,
Missouri.  As of September 2010, the property was 70% leased
compared to 76% at last review.  The loan is on the servicer's
watchlist for low occupancy.  The largest tenant is Bryan Cave,
LLP (24% of the net rentable area; lease expiration June 2022).
Armstrong Teasdale, the second largest tenant at last review,
vacated the premises in Juen 2010 at the expiration of its lease.
Moody's analysis of the property reflects a significant downward
adjustment to net operating income due to the weakness of the St.
Louis office market and the increased vacancy of the property.
Moody's considers this loan to be a high default risk and has
identified it as a troubled loan.  Moody's LTV and stressed DSCR
are 140% and 0.69X, respectively, compared to 127% and 0.77X at
last review.


WACHOVIA BANK: Moody's Reviews Ratings on 17 2007-C33 Certs.
------------------------------------------------------------
Moody's Investors Service placed 17 classes of Wachovia Bank
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2007-C33 on review for possible downgrade:

  -- Cl. A-M, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Aa2 (sf)

  -- Cl. A-J, Baa2 (sf) Placed Under Review for Possible
     Downgrade; previously on Dec. 3, 2009 Downgraded to Baa2 (sf)

  -- Cl. B, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Baa3 (sf)

  -- Cl. C, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Ba1 (sf)

  -- Cl. D, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Ba2 (sf)

  -- Cl. E, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Ba3 (sf)

  -- Cl. F, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to B2 (sf)

  -- Cl. G, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to B3 (sf)

  -- Cl. H, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Caa2 (sf)

  -- Cl. J, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Caa3 (sf)

  -- Cl. K, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Ca (sf)

  -- Cl. L, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Ca (sf)

  -- Cl. M, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Ca (sf)

  -- Cl. N, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Ca (sf)

  -- Cl. O, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Ca (sf)

  -- Cl. P, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Ca (sf)

  -- Cl. Q, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Dec. 3, 2009 Downgraded to Ca (sf)

The classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from realized and
anticipated losses from specially serviced and troubled loans.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated December 3, 2009.

                   Deal And Performance Summary

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 0.4% to
$3.584 billion from $3.602 billion at securitization.  The
Certificates are collateralized by 163 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 53% of the pool.  No loans have defeased.

Forty-eight loans, representing 30% 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 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 since
securitization, resulting in an aggregate $4.6 million loss (55%
loss severity on average).  Currently sixteen loans, representing
19% of the pool, are in special servicing.  The master servicer
has recognized an aggregate $80.0 million appraisal reduction for
12 of the specially serviced loans.

Based on the most recent remittance statement, Classes K through
S have experienced cumulative interest shortfalls totaling
$5.4 million.  Moody's anticipates that the pool will continue to
experience future 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 review will focus on potential losses from specially
serviced and troubled loans and the performance of the overall
pool.


WACHOVIA BANK: S&P Downgrades Ratings on Eight 2004-C10 Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
pooled classes of commercial mortgage-backed securities from
Wachovia Bank Commercial Mortgage Trust's series 2004-C10.  In
addition, S&P raised its rating on the class SL raked certificate.
Finally, S&P affirmed its ratings on 10 other pooled classes from
the same transaction.

The downgrades follow S&P's analysis of the transaction using its
U.S. conduit and fusion CMBS criteria and reflect actual and
anticipated credit support erosion.  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 1.80x and a loan-
to-value ratio of 82.9%.  S&P further stressed the loans' cash
flows under S&P's 'AAA' scenario to yield a weighted average DSC
of 1.32x and an LTV ratio of 102.4%.  The implied defaults and
loss severity under the 'AAA' scenario were 31.2% and 28.6%,
respectively.  All of the DSC and LTV calculations S&P noted above
exclude 11 ($318.5 million, 31.4%) defeased loans, one ($5.7
million, 0.6%) of the transaction's two ($7.7 million, 0.8%)
specially serviced loans, and one ($10.7 million, 1.1%) loan that
S&P determined to be credit-impaired.  S&P separately estimated
losses for the two excluded specially serviced and credit-impaired
loans, and included them in S&P's 'AAA' scenario implied default
and loss figures.

The upgrade of the class SL raked certificate follows S&P's
analysis of the Starrett-Lehigh Building loan.  The raked
certificate derives 100% of its cash flow from a subordinate
nonpooled portion of this loan, which S&P describe in detail
below.  The whole loan is secured by an approximately 2,139,634-
sq.-ft. office property in New York City.  As of December 2009,
the reported whole-loan DSC was 2.78x.  Reported occupancy was
92.6% as of June 2010.

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

                      Credit Considerations

As of the October 2010 remittance report, two ($7.7 million, 0.8%)
loans in the pool were with the special servicer, LNR Partners
Inc. The INS Building-Boise, ID loan ($5.8 million total exposure,
0.6%) is the largest loan with the special servicer.  The loan is
classified as late but less than 30-days delinquent in its
payments.  The loan is secured by a 30,421-sq.-ft. office property
in Boise, Idaho.  The loan was transferred to the special servicer
in January 2010.  According to the special servicer, collections
are in process.  Standard & Poor's forecasts a moderate loss upon
the eventual resolution of this loan.

The Hickory Ridge Apartments loan ($2.0 million total exposure,
0.2%) is the second-largest loan with the special servicer.  The
loan is classified as current in its payments.  The loan is
secured by a 90-unit multifamily property in Greenville, S.C.  The
loan was transferred to the special servicer in October 2010.  The
reported DSC was 1.11x as of December 2009.

In addition to the specially serviced loans, S&P determined one
($10.7 million; 1.1%) loan to be credit-impaired.  The Little Palm
Island Resort loan is secured by a 30-room lodging property in
Little Torch Key, Fla.  The loan appears on the master servicer's
watchlist due to low DSC of 0.57x as of June 2010, compared with
the issuance DSC of 1.77x.  Given the property's performance
decline and high leverage, S&P considers this loan to be at an
increased risk of default and loss.

                       Transaction Summary

As of the October 2010 remittance report, the collateral pool
had an aggregate trust balance of $1.01 billion, down from
$1.31 billion at issuance.  The pool includes 69 loans, down from
102 at issuance.  The master servicer, Wells Fargo Bank N.A.,
provided interim-2009, full-year 2009, or interim-2010 financial
information for all of the nondefeased loans in the pool.  S&P
calculated a weighted average DSC of 2.03x for the pool based on
the reported figures.  S&P's adjusted DSC and LTV ratio were
1.80x and 82.9%, respectively.  S&P's adjusted DSC and LTV
figures exclude 11 ($318.5 million, 31.4%) defeased loans, one
($5.7 million, 0.6%) of the transaction's two ($7.7 million, 0.8%)
specially serviced loans, and one ($10.7 million, 1.1%) loan that
S&P determined to be credit-impaired.  S&P separately estimated
losses for the two excluded specially serviced and credit-impaired
loans.  The master servicer reported a watchlist of 10
($71.1 million, 7.0%) loans, including one of the top 10 loan
exposures, which S&P discuss below.  Eight ($33.9 million, 3.3%)
loans in the pool have a reported DSC of less than 1.10x, and six
($28.6 million, 2.8%) loans have a reported DSC of less than
1.00x.

                Summary of Top 10 Loan Exposures

The top 10 exposures secured by real estate have an aggregate
outstanding trust balance of $456.1 million (45.0%).  Using
servicer-reported numbers, S&P calculated a weighted average DSC
of 2.34x for the top 10 real estate loans.  S&P's adjusted DSC and
LTV ratio for the top 10 exposures are 1.95x and 83.7%,
respectively.

The Starrett-Lehigh Building loan is the largest exposure in the
pool, with a trust balance of $113.3 million (11.2%).  The loan's
$168.1 million whole-loan balance consists of a $146.1 million
senior component, which is split into two pari passu notes, one
($91.3 million, 9.0%) of which is included in the subject trust,
and a $21.9 million (2.2%) subordinate note, which is also
included in the subject trust.  The class SL raked certificate
derives 100% of its cash flow from the subordinate note.  The
whole loan is secured by an approximately 2,139,634-sq.-ft. office
property in New York City.  As of December 2009, the reported DSC
was 3.20x/2.78x (senior component only/whole-loan balance), while
reported occupancy was 92.6% as of June 2010.  S&P's updated
valuation for this loan indicates an adjusted LTV ratio of 40.0%
for the whole-loan balance.

The Sunrise Bay Apartments loan is the eighth-largest loan in the
pool, and the largest loan on the master servicer's watchlist.
The loan has a balance of $19.3 million (1.9%) and is secured by a
313-unit multifamily property in Galloway, N.J.  As of December
2009, reported DSC was 1.69x, while occupancy was 94.8% as of July
2010.  According to the master servicer, the loan appears on the
watchlist due to outstanding servicer advances related to
insurance payments that the master servicer covered but the
borrower has yet to repay.

Standard & Poor's analyzed the transaction according to its
current criteria, and the rating actions are consistent with S&P's
analysis.

               Ratings Lowered (Pooled Certificates)

              Wachovia Bank Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2004-C10

                Rating
                ------
   Class      To           From         Credit enhancement (%)
   -----      --           ----         ----------------------
   G          BBB- (sf)    BBB (sf)                       6.06
   H          BB- (sf)     BBB- (sf)                      4.27
   J          B+ (sf)      BB+ (sf)                       2.97
   K          B (sf)       BB (sf)                        2.16
   L          CCC+ (sf)    BB- (sf)                       1.51
   M          CCC (sf)     B+ (sf)                        1.02
   N          CCC- (sf)    B (sf)                         0.53
   O          CCC- (sf)    B- (sf)                        0.05

                Rating Raised (Raked Certificate)

             Wachovia Bank Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2004-C10

                Rating
                ------
   Class      To           From         Credit enhancement (%)
   -----      --           ----         ----------------------
   SL         AA+ (sf)     AA (sf)                         N/A

              Ratings Affirmed (Pooled Certificates)

             Wachovia Bank Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2004-C10

         Class        Rating     Credit enhancement (%)
         -----        ------     ----------------------
         A-3          AAA (sf)                    19.87
         A-4          AAA (sf)                    19.87
         A-1A         AAA (sf)                    19.87
         B            AAA (sf)                    15.97
         C            AA+ (sf)                    14.34
         D            AA- (sf)                    11.09
         E            A (sf)                       9.47
         F            BBB+ (sf)                    7.52
         X-P          AAA (sf)                      N/A
         X-C          AAA (sf)                      N/A

                      N/A -- Not applicable.


* Fitch Affirms Ratings on Two US RMBS Housing Resecuritizations
----------------------------------------------------------------
Fitch Ratings has affirmed two U.S. RMBS Manufactured Housing
Resecuritization Trusts.

The Re-REMIC transactions represent a beneficial ownership
interest in separate underlying RMBS trust funds.  The review
included all Re-REMICs collateralized with underlying MH
transactions, covering two Re-REMIC transactions and seven Re-
REMIC classes.

Fitch's rating actions are:

Asset-Backed Securities Corp. 2004-CNF1

  -- A-1 (00081WAG6) affirmed at 'Asf'; Outlook Positive;
  -- A-2 (00081WAH4) affirmed at 'Csf/RR2'.

Lehman Manufactured Housing Asset-Backed Trust 1998-1

  -- I-A1 (525170BB1) affirmed at 'Asf'; Outlook Stable;
  -- I-IO (525170BC9) affirmed at 'Asf'; Outlook Stable;
  -- II-A1 (525170BD7) affirmed at 'Csf/RR2';
  -- II-A2 (525170BE5) affirmed at 'Csf/RR2';
  -- II-IO (525170BF2) affirmed at 'Csf'.

The Re-REMIC rating actions reflect the recently completed MH
sector rating review in fourth quarter 2010.  Additional
information regarding the MH rating actions is available in
Fitch's Oct. 21, 2010 press release titled 'U.S. MH RMBS Remains
Stable Amid Housing Downturn; Actions on 147 Deals'.

To analyze the Re-REMIC classes for Asset-Backed Securities Corp.
2004-CNF1, Fitch first determines the underlying collateral pool's
projected base-case and rating-stressed loss assumptions.  These
assumptions are derived using the pool's 12-month average
prepayment speed, default frequency, loss severity, and
delinquency trend.  After determining the underlying pool's loss
assumptions, Fitch performs cash flow analysis on the Re-REMIC
classes.  The surveillance methodology is described in the
April 28, 2010 report 'U.S. RMBS Surveillance Criteria' and the
cash flow criteria is described in the report 'U.S RMBS Cash Flow
Analysis Criteria' published June 28, 2010.

The ratings on Lehman Manufactured Housing Asset-Backed Trust
1998-1 directly reflect the ratings on the underlying classes.
This Re-REMIC is a direct pass-through structure and does not
provide additional enhancement to the Re-REMIC classes.

Following a review of the cash flow results, Fitch affirmed the
ratings of the Re-REMIC classes based on criteria described in
Fitch's March 8, 2010 report, 'U.S. Residential Mortgage Re-REMIC
Criteria.'

In addition to the long-term credit rating on each rated class,
Fitch also affirmed three Recovery Ratings of 'RR2' on bonds rated
below 'B' that are expected to incur principal losses.  The 'RR2'
rating implies a discounted projected cash flow of 71%-90% of the
current par amount.  The methodology used to analyze Recovery
Ratings is described in Fitch's Dec. 16, 2009 report, 'U.S. RMBS
Criteria for Recovery Ratings'.

These actions were reviewed by a committee of Fitch analysts.


* Fitch Assigns 'BB' Rating to New York and New Jersey's Bonds
--------------------------------------------------------------
Fitch Ratings assigns a 'BB' rating to the Port Authority of New
York and New Jersey JFK International Air Terminal $825 million
parity special project bonds series 8 for the financing of JFK's
Terminal Four 2010 Expansion Project.  Fitch also downgrades to
'BB' from 'BBB' IAT's $792 million outstanding parity bonds series
6.  The Rating Outlook on all bonds is Stable.

Rating Rationale:

The downgrade reflects the reintroduction of construction risk to
the IAT project, necessitating significant leveraging above
current levels of debt, with inadequate construction risk
mitigation addressing possible cost overruns and construction
delays to achieve investment grade credit quality.  The current
structure relies on draws from modest levels of contingency funds
(10% of project 'hard costs') as well as Delta Air Lines' timely
financial and performance support (Delta; IDR 'B-', Outlook
Stable).  Thus, Fitch views the construction risk and Delta
counterparty risk as near-term rating constraints during the
project's construction phase considering cost estimates are not
currently locked in due to the design-bid-build project management
approach.  Construction will be taking place alongside a live
operation both within the terminal facility and in the surrounding
airfield.  Delta will have a prominent presence at the IAT
facility as the carrier is now a co-owner of the sponsor entity
(JFK IAT) and will be the anchor tenant following completion as
well as serve as the construction manager for the 2010 expansion
and improvement project.

Despite the risks mentioned above, Fitch recognizes the underlying
competitive position of IAT's Terminal Four at JFK, the New York
air service market for international travel, and strong
management, all of which elevate the credit above Delta's current
rating level.  Should the completion of the project meet the
sponsor projected costs and timeframe, and the project's
utilization, economics, and cashflow remain strong enough to
support healthy debt coverage ratios, the rating may migrate
upward.

Credit Strengths Include:

  -- Solid service area with about 73% origination and destination
     traffic and JFK's status as the nation's sixth largest
     airport in total passengers, and the nation's leading airport
     for international traffic.  Terminal Four already acts as the
     primary facility within JFK airport to serve international
     traffic.

  -- Well diversified foreign flag carrier base comprising 38
     carriers with no one carrier holding more than 10% share of
     enplanements at the terminal (prior to Delta becoming an
     anchor tenant).

  -- Modern terminal facility less than 10-years in operation with
     the only 24 hour FIS facility at JFK.  Terminal Four is also
     the largest terminal site at the airport with flexibility for
     additional capacity in the future.

  -- Operator's deep expertise in airport management and
     operations, as well as its long tenure managing Terminal
     Four.

  -- Long-term lease agreement with Delta, as an anchor tenant,
     through the life of the bonds.

  -- Five consecutive years of positive operating performance with
     particularly strong coverage in excess of 1.8 times [x]
     reaching in excess of 2x coverage in 2008 and 2009, and
     expected in the current fiscal year.

  -- The overall limits for international-based terminal capacity
     at the airport based on available facilities due to current
     levels of high demand by carriers at peak periods.

  -- The ability to withstand a combination of stresses that
     includes weaker overall market demand, and a complete loss of
     Delta as a tenant with a phased-in 50% recovery of O&D
     volumes by new tenants in a 3-5 year window.

Credit Concerns Include:

  -- IAT faces competition from other airports in the New York
     area and from other terminals within JFK. Thus, lease renewal
     risk and traffic diversion for existing contract carriers is
     a possibility over the life of the debt.

  -- Carrier concentration risk will be greater in future years
     compared to past operations with Delta expanding its presence
     into the terminal by 2013.  Previously, Terminal Four did not
     have any one carrier accounting for more than 10% of total
     enplanements.  Post construction, Delta is projected to be
     responsible for over 52% of traffic and is projected to
     account for at least 40% of IAT's revenues.

  -- High fixed costs with the doubling of project debt for the
     2010 expansion project.  Debt per enplaned passenger will
     stand at over $300 which may put long term pressure on cost
     competitiveness relative to other options available to
     carriers.

  -- The lack of rate flexibility to reset rates and charges to
     contract carriers serving at the terminal that would
     adequately pass through possible revenue losses in the event
     of a Delta departure during or after the project completion
     period.

Key Rating Drivers:

Future rating actions are likely to be influenced by these:

  -- Substantial cost overruns or delays during construction;

  -- Counterparty risk due to a material weakening or improvement
     in Delta's credit profile;

  -- Changes in traffic volumes that deviate significantly from
     current forecasts;

  -- Upward or downward changes in carrier concentration at the
     terminal.

  -- Material changes in IAT's debt profile.

Security:

The bonds are secured by a facility rental payment made to the
Port Authority, by IAT, in an amount sufficient to cover the
required debt service obligations annually through to maturity,
and by a leasehold mortgage pledged to the Trustee in the leased
premises.

Credit Summary:

The 2010 Expansion Project includes the construction of a linear
extension to Concourse B that comprises nine new aircraft contact
gates, which will be capable of accommodating all aircrafts
currently in service as well as new generation wide-body aircrafts
expected to be introduced for international service; thus
providing Concourse B with a total of 19 aircraft contact gates
and increasing to 25 the total number of aircraft contact gates in
all of Terminal Four.  The project will also include work related
to passenger hold-rooms, baggage systems, airline club and
operational space, and new space for retail concessions.  The
estimated project costs for the 2010 Expansion Project are $661.1
million of which $591 million are hard costs fully funded via the
series 8 bond issue.

Traffic at Terminal Four has been strong from 2002 to 2009 peaking
at 4.5 million enplaned passengers served.  With Virgin America's
expanded service and Delta leasing three gates at Terminal Four,
passenger activity increased 3.1% in 2009 even with the stresses
in the aviation industry.  In 2009, Terminal Four enplaned
passengers represented approximately 19.9% of total airport
enplanements, representing a 6.7% gain in airport market share
from 1999.  Year-to-date enplanements (as of August 2010) are down
1.5% compared to August 2009.  With the increase in passenger
activity and new entrants such as Delta and Virgin America,
coupled with ongoing tight controls of operating and maintenance
costs by management, revenues have significantly improved
translating into strong coverage particularly in 2008 and 2009
where coverage was at least 2x and is expected to remain this way
in 2010.

Sponsor forecasts assume total traffic growth will reach
6.8 million in 2015 and 7.5 million by 2020 reflecting the
expectations of general positive traffic growth for the market in
general as well as the effects of Delta's transfer of traffic to
Terminal Four from its existing Terminal Three operations.
Assuming a no cost overrun scenario with these rising traffic
levels, coverage levels are forecasted to remain at 1.8x or
higher.  Considering the potential for cost overruns or an event
leading to reduced or eliminated service from Delta or other
carriers, Fitch evaluated certain sensitivity and stress
scenarios.  The most conservative scenario assumes compounded
stresses whereby the airport and Terminal Four is subject to a 10%
general decline in enplanements in 2014, cost overruns of 50%
above original estimates that would necessitate a $220 million
parity completion financing, and Delta's service is reduced to 50%
of forecasts in 2016 (making Delta's passenger throughput at
1.5 million versus 3 million under the base case).  Under these
assumptions, IAT could still be able to meet its operating costs
and debt obligations at 1x coverage provided that a passenger
backfill of traffic of at least 500,000 enplanements is realized
within the year Delta defaults.  Fitch notes that IAT's debt
service reserves would provide additional financial flexibility of
about three years if the above mentioned backfill takes longer
than a single year.  Stress cases with less conservative
assumptions would likely not require similar levels of passenger
backfill to generate sufficient net revenues for debt service
payments.  Fitch notes that a Delta backed financing to complete
the project for these sensitivity scenarios, particularly as
parity JFK IAT obligation, is a primary rating constraint.  While
the Port Authority has stepped-in to support cost overruns in the
original project through a subordinate loan, Fitch does not assume
such support would again occur.

JFK IAT is owned by JFK IAT Member LLC which is an indirect
subsidiary of N.V.  Luchthaven Schiphol (a Netherlands company).
JFK IAT subleases or otherwise makes available portions of the
facility for use by airlines and others who wish to operate at
Terminal Four, in exchange for rentals, fees and other charges
payable to JFK IAT.  The original members of JFK IAT were Schiphol
USA LLC (now JFK IAT Member LLC), with a 40% membership interest,
LCOR JFK Airport L.L.C.  with a 40% membership interest, and
Lehman JFK LLC with a 20% membership interest.  In April 2010,
LCOR and Lehman sold their collective 60% membership interest in
JFK IAT to JFK IAT Member LLC and Delta acquired its Class B
membership interest in JFK IAT Member LLC in connection with the
LCOR JFK and LB-JFK buy-out and in anticipation of the 2010
Expansion Project.  Schiphol USA Inc., a New York corporation, is
the Class A managing member of JFK IAT Member LLC with a majority
ownership interest and Delta has a Class B, non-majority and non-
controlling equity membership interest of JFK IAT Member LLC.


* Fitch Upgrades Ratings on New Jersey Health's Bonds to 'B'
------------------------------------------------------------
Fitch Ratings has upgraded to 'B' from 'B-' the outstanding
$21.6 million New Jersey Health Care Facilities Authority's
revenue bonds, Deborah Heart and Lung Center, series 1993.  The
Rating Outlook is revised to Stable.

Rating Rationale:

  -- The financial improvement plan put into effect in response to
     an escalating level of operating losses, which reached its
     peak with an operating loss of $19.2 million in fiscal 2008
     (year-end Dec. 31), resulted in an improvement in operations
     in fiscal 2009 and continues in the current fiscal year
     (nine- month period ended Sept. 30), with operating losses
     reduced to $6.1 million and $3 million, respectively.

  -- Utilization is rebounding, after several years of declining
     admissions, following the March 2010 opening of a satellite
     emergency department on the DHLC campus operated by Our Lady
     of Lourdes Healthcare Services, Inc.

  -- The improvement in operating performance reduced the need for
     contribution transfers from the Deborah Hospital Foundation
     (the Foundation), which is obligated to fund DHLC's cash
     flow requirements, including debt service payments.

  -- Liquidity remains a significant credit negative, with
     combined DHLC and Foundation unrestricted cash and
     investments declining from a combined $47 million in 2006 to
     $14.3 million at Sept. 30, 2010 (37 DCOH).

Key Rating Drivers:

  -- Continuation of reduced operating losses in order to reduce
     the reliance on Foundation transfers, in order to stabilize
     the liquidity decline;

  -- Generation of additional revenues from the newly launched
     satellite emergency department and other planned new
     services;

  -- Maintenance of sufficient level of fundraising through the
     Foundation in support of hospital operations.

Security:

Bonds are secured by a revenue pledge and a mortgage lien on
DHLC's facility and additionally benefit for a Subsidy Agreement
from the Foundation, which is obligated to fund DHLC's cash flow
requirements, including operating costs, capital needs and debt
service payments.

Credit Summary:

The upgrade to 'B' and revision of the Outlook to Stable reflects
the improvement in DHLC's financial operations for the fiscal year
ended Dec. 31, 2009, which has continued for the nine-month
interim period ended Sept. 31, 2010.  The very low liquidity,
however, remains a chief credit concern.  After a number of years
of growing operating losses, which reached its highest point in
2009 with a $19.2 million operating loss (a negative 14.6%
operating margin), management undertook a financial improvement
plan focused both on cost reduction and reversing what had been a
multi-year declining trend in patient revenues.  Actions taken
included a workforce reduction and a temporary scaling back of
capital spending.  The operating loss in 2009 was reduced to $6.1
million (negative operating margin of 4.8%) and for the current
year interim period operating loss is $3 million (negative
operating margin of 3%).

The large operating losses necessitated an ever increasing need
for contributions from the Foundation that together with
investment losses depleted cash reserves of the Foundation, which
is obligated to fund DHLC's cash flow needs.  The combined DHLC
and Foundation unrestricted cash and investments declined from
$47 million in 2006 to $25.3 million at 2009 year end, equal to
70.3 days cash on hand, and further to $14.3 million at Sept. 30,
2010 (37 DCOH).  However, on a year-over-year basis, combined cash
increased; Sept. 2009 combined cash was $10.8 million.  The year
end 2009 liquidity position was distorted as a result of several
factors related to covenant compliance needs, including a
temporary stretching of accounts payable, an advance on 2010 state
charity funding and release of restricted funds held as collateral
against line of credit borrowings, precipitated by the payoff of
the line of credit at year end, which were subsequently returned
to restrictions.  Fitch expects that management will take similar
steps to meet covenant compliance needs for fiscal 2010, though
the financial performance improvement has reduced the level of
draws on lines of credit and eliminated the need for an advance on
charity funding.  Coverage of MADS, based on DHLC alone, but
including the Foundation transfer, was 1.6 times in fiscal 2009,
and based on the combined DHLC and the Foundation, coverage was
2.5x last year.

As part of the effort to increase revenues, in March 2010 DHLC
entered into an agreement with Lourdes (part of Catholic Health
East, rated 'A+' with a Stable Outlook by Fitch) to lease space to
establish a satellite emergency department on DLHC campus.  Under
the agreement, Lourdes constructed the facility in space leased
from DHLC.  DHLC benefits from cardiac, pulmonary and vascular
admissions, while patients needing other services can choose to be
admitted to Lourdes.  The SED is favorably situated in close
proximity to the nearby McGuire-Fort Dix megabase (less than three
miles) and has seen utilization far exceed initial projections.
Management expected approximately 230 additional admissions
annually from the SED, whereas the recent trend has been 90
admissions per month.  Despite the SED being only in operation
since March of this year, admissions as of Sept. 30, 2010 are 10%
ahead of last year, and open heart cases are 4% higher.  Patient
revenues exceed last year's by 8% and management reports that
volumes continue to be very strong.

A further boost to revenues is expected from a recent agreement
with a nationally renowned diabetes program to open two state of
the art diabetes centers, one of which will be on the DHLC campus.
DHLC is also planning to open a wound center in conjunction with
the diabetes service.  Given the significant synergy between
diabetic disease and vascular and wound care, management
anticipates increased utilization from these new services.

Both the support of the Foundation and the continued willingness
of New Jersey to provide charity funding are important factors in
supporting DHLC operations.  In this respect, Fitch considers the
reduction of Foundation reserves a major credit concern.  The
Foundation has made certain changes in its fundraising efforts,
which historically have been based on a large grass roots
organization of volunteers, towards more aggressively pursuing
corporate giving, foundation grants and estate and annuity gifts.
Management reports that fundraising for the current year is
expected to be close to the $7.8 million raised last year
($10.5 million in 2008), but that a large percentage, between 30-
40%, as is typical, will only be received in the last quarter of
the calendar year.  While in the past the Foundation has needed to
make significant transfers to DHLC ($13 million in fiscal 2008),
management expects that in the current fiscal year, the
contribution is expected to be at only $1.5-2 million.  Smaller
transfers to DHLC, together with a change in investment allocation
to 60% fixed income and 40% equities, should help stabilize the
Foundation liquidity position.  DHLC, which has a policy of not
charging balances to patients, is also dependent on the continued
support of the state to fund its charity needs.  The current
administration, despite the state's fiscal difficulties, appears
committed to continuing the support, and has in fact slightly
increased its funding for the current state fiscal year, to
$6.5 million, from $6.1 million last year.

The Stable Outlook is based on Fitch's expectation that DLHC will
be able to continue to stabilize its operating performance at a
lower operating loss level, reducing the need for Foundation
transfers, which will stem the liquidity decline at the
Foundation.  The expectation appears to be supported by the
initial results based on the first several months following the
opening of the SED.

Deborah Heart and Lung Center is a 139-bed tertiary care cardiac,
pulmonary, and vascular care facility, which is located in Browns
Mills, NJ (approximately 20 miles from Trenton).  DHLC had total
revenues of approximately $127 million in fiscal 2009.  DHLC
covenants to disclose only annual audited financial information
(within 120 days) to the Municipal Securities Rulemaking Board's
EMMA system, which Fitch views negatively.  However, Fitch does
note that DHLC's bond covenants date back to documents produced in
1993 when the expectations for disclosure were not as thorough.
Currently, DHLC does provide unaudited interim quarterly and
annual audited information to the trustee and the New Jersey
Health Care Facilities Authority as well as to bondholders upon
request.


* Fitch Withdraws Ratings on Harvey, Illinois' Bonds
----------------------------------------------------
Fitch Ratings withdraws these ratings on Harvey, Illinois, due to
insufficient information provided:

  -- $22.275 million general obligation bonds, series 2007A
     currently rated 'B', Outlook Stable;

  -- $9 million general obligation bonds (taxable), series 2007B
     currently rated 'B', Outlook Stable.


* Moody's Downgrades Ratings on 95 Notes by 56 CDO Transactions
---------------------------------------------------------------
Moody's Investors Service announced that it has downgraded its
ratings of 95 Notes issued by 56 collateralized debt obligation
transactions which consist of significant exposure to one or more
of Alt-A, Option-ARM and subprime RMBS securities, CLOs, or CMBS.
The rating actions are:

888 Tactical Fund, Ltd.

  -- US$39,200,000 Class S Floating Rate Notes due 2015,
     Downgraded to C (sf); previously on September 23, 2008
     Downgraded to Ca (sf).

AArdvark ABS CDO 2007-1

  -- US$1,305,140,296 Class A1 Extended Notes due 2047,
     Downgraded to C (sf); previously on August 26, 2008
     Downgraded to Ca (sf).

ACA ABS 2006-1 Ltd.

  -- Class A-1LA Notes, Downgraded to C (sf); previously on
     August 26, 2008 Downgraded to Ca (sf).

ACA ABS 2007-1, Ltd.

  -- US$930,000,000 Class A1S Variable Funding Senior Secured
     Floating Rate Notes Due 2047, Downgraded to C (sf);
     previously on June 2, 2008 Downgraded to Ca (sf).

ACA ABS 2007-3, Limited

  -- US$7,000,000 Class X Floating Rate Notes Due August 2013,
     Downgraded to C (sf); previously on August 26, 2008
     Downgraded to Ca (sf).

Acacia Option ARM 1 CDO, Ltd.

  -- US$380,000,000 Class A1S First Priority Senior Secured
     Floating Rate Notes Due 2052, Downgraded to C (sf);
     previously on September 23, 2008 Downgraded to Ca (sf).

Adrastea SHG 2007-1, Ltd.

  -- US$1,600,000,000 Class A-1M Variable Funding Floating Rate
     Notes Due 2052, Downgraded to C (sf); previously on April 22,
     2009 Downgraded to Ca (sf).

Broderick CDO III Ltd.

  -- US$750,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Notes due 2050, Downgraded to C (sf);
     previously on September 23, 2008 Downgraded to Ca (sf).

Brookville CDO I, Ltd.

  -- US$200,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Delayed Draw Notes Due 2050, Downgraded to C
     (sf); previously on August 26, 2008 Downgraded to Ca (sf).

CETUS ABS CDO 2006-1, LTD.

  -- US$100,000,000 Class A-1 Floating Rate Senior Secured Notes
     Due 2046, Downgraded to C (sf); previously on August 26, 2008
     Downgraded to Ca (sf).

Cairn Mezz ABS CDO II Limited

  -- US$450,000,000 Class A1-VF Senior Secured Floating Rate
     Notes Due 2047, Downgraded to C (sf); previously on September
     23, 2008 Downgraded to Ca (sf).

Camber 7 plc

  -- US$485,000,000 Class A-1 Floating Rate Secured Notes Due
     2042, Downgraded to C (sf); previously on September 23, 2008
     Downgraded to Ca (sf).

Cetus ABS CDO 2006-2, Ltd.

  -- US$100,000,000 Class A-1 Floating Rate Senior Secured Notes
     Due 2046, Downgraded to C (sf); previously on August 26, 2008
     Downgraded to Ca (sf).

Cetus ABS CDO 2006-4, Ltd.

  -- US$75,000,000 Class A-2 Floating Rate Senior Secured Notes
     Due 2047, Downgraded to C (sf); previously on May 23, 2008
     Downgraded to Ca (sf).

  -- US$82,500,000 Class B Floating Rate Deferrable Subordinate
     Secured Notes Due 2047, Downgraded to C (sf); previously on
     November 12, 2007 Downgraded to Ca (sf).

Class V Funding III, Ltd.

  -- US$39,200,000 Class S Notes due 2015, Downgraded to C (sf);
     previously on May 29, 2008 Downgraded to Ca (sf).

  -- Up to US$500,000,000 Class A1 Floating Rate Notes due 2052,
     Downgraded to C (sf); previously on May 29, 2008 Downgraded
     to Ca (sf).

Diogenes CDO I

  -- Class A-1, Downgraded to C (sf); previously on April 22, 2009
     Downgraded to Ca (sf).

Duke Funding High Grade V, Ltd.

  -- Class A-1 Senior Secured Floating Rate Notes Due 2050,
     Downgraded to C (sf); previously on September 23, 2008
     Downgraded to Ca (sf).

Duke Funding XI, Ltd.

  -- EUR33,000,000 Class X Floating Rate Notes Due 2013,
     Downgraded to C (sf); previously on April 24, 2009 Downgraded
     to Ca (sf).

  -- EUR704,000,000 Senior Swap, Downgraded to C (sf); previously
     on April 24, 2009 Downgraded to Ca (sf).

Duke IX

  -- Senior Swap, Downgraded to C (sf); previously on April 22,
     2009 Downgraded to Ca (sf).

  -- Combo Notes, Downgraded to C (sf); previously on April 22,
     2009 Downgraded to Ca (sf).

Fourth Street Funding, Ltd.

  -- US$200,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Delayed Draw Notes Due 2050, Downgraded to C
      (sf); previously on August 26, 2008 Downgraded to Ca (sf).

GSC ABS CDO 2006-1c, Ltd.

  -- Class A-1, Downgraded to C (sf); previously on October 17,
     2008 Downgraded to Ca (sf).

  -- Class A-2, Downgraded to C (sf); previously on October 17,
     2008 Downgraded to Ca (sf).

GSC ABS CDO 2006-4u, Ltd.

  -- Up to US$502,000,000 Class A-S1VF Senior Secured Floating
     Rate Notes due 2046, Downgraded to C (sf); previously on
     August 26, 2008 Downgraded to Ca (sf).

GSC CDO 2007-1r, Ltd.

  -- US$375,000,000 Class A-1LA VFN Senior Secured Floating
     Rate Notes due 2039, Downgraded to C (sf); previously on
     September 23, 2008 Downgraded to Ca (sf).

Glacier Funding CDO IV Ltd.

  -- US$296,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Notes Due 2045, Downgraded to C (sf);
     previously on September 23, 2008 Downgraded to Ca (sf).

Highridge ABS CDO I, Ltd.

  -- US$321,500,000 Class A-1AD First Priority Senior Secured
     Floating Rate Delayed Draw Notes due 2048, Downgraded to C
      (sf); previously on August 26, 2008 Downgraded to Ca (sf).

  -- US$976,000,000 Class A-1AT First Priority Senior Secured
     Floating Rate Notes due 2048, Downgraded to C (sf);
     previously on August 26, 2008 Downgraded to Ca (sf).

Independence VII CDO, Ltd.

  -- US$360,000,000 Class A-1A First Priority Senior Secured
     Floating Rate Delayed Draw Notes due 2045, Downgraded to C
     (sf); previously on September 23, 2008 Downgraded to Ca
     (sf).

  -- US$60,000,000 Class A-1B First Priority Senior Secured
     Floating Rate Notes due 2045-2, Downgraded to C (sf);
     previously on September 23, 2008 Downgraded to Ca (sf).

Ischus Mezzanine CDO III, Ltd.

  -- US$396,000,000 Class A-1 First Priority Senior Secured
     Floating Rate Notes Due 2046, Downgraded to C (sf);
     previously on September 23, 2008 Downgraded to Ca (sf).

Ivy Lane CDO Ltd.

  -- US$350,000,000 Class A-1 Floating Rate Senior Secured Notes
     Due 2046-1, Downgraded to C (sf); previously on September 23,
     2008 Downgraded to Ca (sf).

Jupiter High-Grade CDO V, Ltd.

  -- US$1,290,000,000 Class A-1 Senior Secured Floating Rate
     Notes Due March 2052, Downgraded to C (sf); previously on
     August 26, 2008 Downgraded to Ca (sf).

Knollwood CDO II Ltd.

  -- Class A-1VF First Priority Senior Secured Floating Rate Notes
     Due 2046, Downgraded to C (sf); previously on April 22, 2009
     Downgraded to Ca (sf).

Laguna Seca Funding I, Ltd.

  -- US$250,000,000 Class A-1 VFN Senior Secured Floating Rate
     Notes due 2047, Downgraded to C (sf); previously on September
     23, 2008 Downgraded to Ca (sf).

Libertas Preferred Funding II, Ltd.

  -- US$6,000,000 Class X Senior Secured Floating Rate Notes Due
     2012, Downgraded to C (sf); previously on August 26, 2008
     Downgraded to Ca (sf).

  -- US$325,000,000 Class A-1 Senior Secured Floating Rate Notes
     Due 2047, Downgraded to C (sf); previously on August 26, 2008
     Downgraded to Ca (sf).

Longstreet CDO I, Ltd.

  -- US$350,000,000 Class A-1 First Priority Senior Secured
     Delayed Draw Floating Rate Notes due November 2046,
     Downgraded to C (sf); previously on August 26, 2008
     Downgraded to Ca (sf).

MKP CBO VI, Ltd.

  -- Class A-1 First Priority Senior Secured Floating Rate Notes
     due 2051, Downgraded to C (sf); previously on August 26, 2008
     Downgraded to Ca (sf).

Maxim High Grade CDO I, Ltd.

  -- US$1,200,000,000 Class A-1 First Priority Senior Secured
     Delayed Draw Floating Rate Notes Due 2048, Downgraded to C
     (sf); previously on September 23, 2008 Downgraded to Ca
     (sf).

Maxim High Grade CDO II, Ltd.

  -- US$1,200,000,000 Class A-1 First Priority Senior Secured
     Delayed Draw Floating Rate Notes Due 2053, Downgraded to C
     (sf); previously on September 23, 2008 Downgraded to Ca
     (sf).

McKinley Funding III, Ltd.

  -- US$1,230,000,000 Class A-1 Senior Secured Floating Rate
     Notes Due 2046, Downgraded to C (sf); previously on
     September 23, 2008 Downgraded to Ca (sf).

Neptune CDO V, Ltd.

  -- US$10,000,000 Class X Floating Rate Notes Due July 2014,
     Downgraded to C (sf); previously on May 16, 2008 Downgraded
     to Ca (sf).

  -- US$190,000,000 Class A-1LA-1 Floating Rate Notes Due
     January 2045, Downgraded to C (sf); previously on May 16,
     2008 Downgraded to Ca (sf).

  -- US$35,000,000 Class A-1LA-2 Floating Rate Notes Due
     January 2045, Downgraded to C (sf); previously on May 16,
     2008 Downgraded to Ca (sf).

  -- US$25,000,000 Class A-1LB Floating Rate Notes Due January
     2045, Downgraded to C (sf); previously on May 16, 2008
     Downgraded to Ca (sf).

  -- US$41,000,000 Class A-2L Floating Rate Notes Due January
     2045, Downgraded to C (sf); previously on May 16, 2008
     Downgraded to Ca (sf).

  -- US$9,000,000 Class A-3L Floating Rate Notes Due January
     2045, Downgraded to C (sf); previously on November 13, 2007
     Downgraded to Ca (sf).

Orion 2006-1 Ltd.

  -- Class A, Downgraded to C (sf); previously on May 9, 2008
     Downgraded to Ca (sf).

  -- Class B, Downgraded to C (sf); previously on May 9, 2008
     Downgraded to Ca (sf).

  -- Class C, Downgraded to C (sf); previously on March 26, 2008
     Downgraded to Ca (sf).

  -- Class D, Downgraded to C (sf); previously on March 26, 2008
     Downgraded to Ca (sf).

  -- Senior Swap, Downgraded to C (sf); previously on December 16,
     2008 Downgraded to Ca (sf).

Palmer ABS CDO 2007-1, Ltd.

  -- US$100,000,000 Class A-1 Floating Rate Senior Secured
     Notes Due 2047, Downgraded to C (sf); previously on March 26,
     2008 Downgraded to Ca (sf).

  -- US$50,000,000 Class A-2 Floating Rate Senior Secured Notes
     Due 2047, Downgraded to C (sf); previously on March 26, 2008
     Downgraded to Ca (sf).

  -- US$55,000,000 Class B Floating Rate Deferrable Subordinate
     Secured Notes Due 2047, Downgraded to C (sf); previously on
     March 26, 2008 Downgraded to Ca (sf).

  -- US$40,000,000 Class C Floating Rate Deferrable Junior
     Subordinate Secured Notes Due 2047, Downgraded to C (sf);
     previously on March 26, 2008 Downgraded to Ca (sf).

  -- US$22,500,000 Class D Floating Rate Deferrable Junior
     Subordinate Secured Notes Due 2047, Downgraded to C (sf);
     previously on November 5, 2007 Downgraded to Ca (sf).

Pine Mountain CDO II Ltd.

  -- $392,750,000 Class A Floating Rate Notes Due November 30,
     2046, Downgraded to C (sf); previously on December 16, 2008
     Downgraded to Ca (sf).

  -- $37,500,000 Class B Floating Rate Notes Due November 30,
     2046, Downgraded to C (sf); previously on May 18, 2008
     Downgraded to Ca (sf).

Pine Mountain CDO III Ltd.

  -- Up to $230,000,000 Class A-1 Floating Rate Notes Due July 7,
     2047, Downgraded to C (sf); previously on April 22, 2009
     Downgraded to Ca (sf).

Port Jackson CDO 2007-1, Ltd.

  -- US$112,500,000 Class A-2 Second Priority Senior Secured
     Floating Rate Notes due 2052, Downgraded to C (sf);
     previously on May 30, 2008 Downgraded to Ca (sf).

  -- US$17,500,000 Class A-3 Third Priority Senior Secured
     Floating Rate Notes due 2052, Downgraded to C (sf);
     previously on May 30, 2008 Downgraded to Ca (sf).

  -- US$60,000,000 Class B Fourth Priority Senior Secured
     Floating Rate Notes due 2052, Downgraded to C (sf);
     previously on May 30, 2008 Downgraded to Ca (sf).

Pyxis ABS CDO 2006-1 Ltd.

  -- Class A-1 Senior Secured Floating Rate Variable Funding Notes
     Due 2046-1, Downgraded to C (sf); previously on May 18, 2008
     Downgraded to Ca (sf).

  -- Class A-2 Senior Secured Floating Rate Notes Due 2046,
     Downgraded to C (sf); previously on May 18, 2008 Downgraded
     to Ca (sf).

  -- Class B Secured Floating Rate Notes Due 2046, Downgraded to C
      (sf); previously on May 18, 2008 Downgraded to Ca (sf).

  -- Class C Secured Deferrable Floating Rate Notes Due 2046,
     Downgraded to C (sf); previously on March 26, 2008 Downgraded
     to Ca (sf).

  -- Class D Mezzanine Secured Deferrable Floating Rate Notes Due
     2046, Downgraded to C (sf); previously on March 26, 2008
     Downgraded to Ca (sf).

  -- Class X Subordinated Notes Due 2046, Downgraded to C (sf);
     previously on March 26, 2008 Downgraded to Ca (sf).

  -- Senior Swap, Downgraded to C (sf); previously on December 16,
     2008 Downgraded to Ca (sf).

RFC CDO IV Ltd.

  -- Super Senior Facility, Downgraded to C (sf); previously on
     April 22, 2009 Downgraded to Ca (sf).

Ridgeway Court Funding II, Ltd.

  -- Up to US$840,000,000 Class A1A Floating Rate Notes Due
     June 2047, Downgraded to C (sf); previously on September 23,
     2008 Downgraded to Ca (sf).

  -- US$660,000,000 Class A1B Floating Rate Notes Due June
     2047, Downgraded to C (sf); previously on September 23, 2008
     Downgraded to Ca (sf).

  -- US$450,000,000 Class A1C Floating Rate Notes Due June
     2047, Downgraded to C (sf); previously on September 23, 2008
     Downgraded to Ca (sf).

STAtic ResidenTial CDO 2005-C

  -- Class A-1, Downgraded to C (sf); previously on April 22, 2009
     Downgraded to Ca (sf).

  -- Class B, Downgraded to C (sf); previously on December 16,
     2008 Downgraded to Ca (sf).

  -- Class C, Downgraded to C (sf); previously on December 16,
     2008 Downgraded to Ca (sf).

  -- Class D, Downgraded to C (sf); previously on December 16,
     2008 Downgraded to Ca (sf).

  -- Class E, Downgraded to C (sf); previously on December 16,
     2008 Downgraded to Ca (sf).

Sorin VI CDO Ltd.

  -- Class A-1LA Floating Rate Notes Due 2052, Downgraded to C
      (sf); previously on September 23, 2008 Downgraded to Ca
     (sf).

Soter 2007-CRN3, Ltd.

  -- US$100,000,000 A1 Variable Notes Due 2047, Downgraded to C
     (sf); previously on December 11, 2008 Downgraded to Ca (sf).

Stockton CDO Ltd.

  -- US$495,000,000 Class A-1 Variable Funding Senior Secured
     Floating Rate Notes Due 2052, Downgraded to C (sf);
     previously on September 23, 2008 Downgraded to Ca (sf).

Tahoma CDO II, Ltd.

  -- Class A-1 Senior Secured Floating Rate Notes due 2047-1,
     Downgraded to C (sf); previously on May 29, 2008 Downgraded
     to Ca (sf).

  -- Class A-2 Senior Secured Floating Rate Notes due 2047,
     Downgraded to C (sf); previously on May 29, 2008 Downgraded
     to Ca (sf).

  -- Class B Senior Secured Floating Rate Notes due 2047,
     Downgraded to C (sf); previously on May 29, 2008 Downgraded
     to Ca (sf).

Tahoma CDO III, Ltd.

  -- US$192,500,000 Class A-1 Senior Secured Floating Rate
     Notes due 2047, Downgraded to C (sf); previously on May 29,
     2008 Downgraded to Ca (sf).

  -- US$97,000,000 Class A-2 Senior Secured Floating Rate Notes
     due 2047, Downgraded to C (sf); previously on May 29, 2008
     Downgraded to Ca (sf).

VOLANS FUNDING 2007-1, LTD.

  -- US$770,000,000 Class A-1 Senior Secured Floating Rate
     Variable Funding Notes Due 2052, Downgraded to C (sf);
     previously on August 26, 2008 Downgraded to Ca (sf).

Vertical ABS CDO 2005-1

  -- Class A-1 SENIOR SECURED FLOATING RATE TERM NOTES-1,
     Downgraded to C (sf); previously on February4, 2009
     Downgraded to Ca (sf).

Vertical ABS CDO 2006-1

  -- A-S1VF, Downgraded to C (sf); previously on April 22, 2009
     Downgraded to Ca (sf).

Vertical CDO 2004-1 Ltd.

  -- Class A Floating Rate Notes, Downgraded to C (sf); previously
     on April 2, 2009 Downgraded to Ca (sf).

                        Ratings Rationale

According to Moody's, the rating downgrade actions are the result
of deterioration in the credit quality of the underlying
portfolios.  Such credit deterioration is observed through
numerous factors, including a decline in the average credit rating
of the portfolio (as measured by an increase in the weighted
average rating factor), an increase in the dollar amount of
defaulted securities, or failure of the coverage tests and further
significant loss of overcollateralization.  Based on trustee
reports, the transactions affected either have all of their
underlying assets defaulted or have extremely low coverage on the
particular tranches.

Moody's notes that in arriving at its ratings of Structured
Finance CDOs, there exist a number of sources of uncertainty,
operating both on a macro level and on a transaction-specific
level.  Among the general macro uncertainties are those
surrounding future housing prices, pace of residential mortgage
foreclosures, loan modification and refinancing, unemployment rate
and interest rates.  However, in light of the performance
indicators noted above, Moody's believes that it is unlikely that
the ratings announced are sensitive to further change.

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.

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.

The approach Moody's takes to defining the default distribution
for the SF CDO collateral depends on the structure of the CDO
itself.

Moody's applied the Monte Carlo simulation framework within
CDOROMv2.6 to model the loss distribution for SF CDOs.  Within
this framework, defaults are generated so that they occur with the
frequency indicated by the adjusted default probability pool (the
default probability associated with the current rating multiplied
by the Resecuritization Stress) for each credit in the reference.
Specifically, correlated defaults are simulated using a normal (or
"Gaussian") copula model that applies the asset correlation
framework.  Recovery rates for defaulted credits are generated by
applying within the simulation the distributional assumptions,
including the correlation between recovery values.  Together, the
simulated defaults and recoveries across each of the Monte Carlo
scenarios define the loss distribution for the reference pool.

Once the loss distribution for the collateral has been calculated,
each collateral loss scenario derived through the CDOROM loss
distribution is associated with the interest and principal
received by the rated liability classes via the CDOEdge cash-flow
model.  The cash flow model takes into account of: collateral cash
flows, the transaction covenants, the priority of payments
(waterfall) for interest and principal proceeds received from
portfolio assets, reinvestment assumptions, the timing of
defaults, interest-rate scenarios and foreign exchange risk (if
present).  The Expected Loss for each tranche is the weighted
average of losses to each tranche across all the scenarios, where
the weight is the likelihood of the scenario occurring.  Moody's
defines the loss as the shortfall in the present value of cash
flows to the tranche relative to the present value of the promised
cash flows.  The present values are calculated using the promised
tranche coupon rate as the discount rate.  For floating rate
tranches, the discount rate is based on the promised spread over
Libor and the assumed Libor scenario.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past 6 months.


* Moody's Reviews Ratings on 149 Prime Jumbo RMBS Transactions
--------------------------------------------------------------
Moody's Investors Service has placed 149 prime jumbo residential
mortgage-backed securities issued by Sequoia Mortgage Trust with
an outstanding balance of $1.3 billion on review for possible
downgrade.

Issuer: Sequoia Mortgage Trust 10

  -- Cl. B-1, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. B-2, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A3 (sf)

  -- Cl. B-3, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba1 (sf)

  -- Cl. B-4, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to B2 (sf)

  -- Cl. B-5, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

Issuer: Sequoia Mortgage Trust 11

  -- Cl. A, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 5, 2002 Assigned Aaa (sf)

  -- Cl. X-1A, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Nov. 5, 2002 Assigned Aaa (sf)

  -- Cl. X-1B, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Nov. 5, 2002 Assigned Aaa (sf)

  -- Cl. X-B, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A1 (sf)

  -- Cl. B-1, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A1 (sf)

  -- Cl. B-2, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba3 (sf)

  -- Cl. B-3, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 23, 2009 Downgraded to Ca (sf)

Issuer: Sequoia Mortgage Trust 2003-1

  -- Cl. 1A, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on March 18, 2003 Assigned Aaa (sf)

  -- Cl. 2A, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on March 18, 2003 Assigned Aaa (sf)

  -- Cl. X-1A, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on March 18, 2003 Assigned Aaa (sf)

  -- Cl. X-1B, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on March 18, 2003 Assigned Aaa (sf)

  -- Cl. X-B, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa2 (sf)

  -- Cl. X-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on March 18, 2003 Assigned Aaa (sf)

  -- Cl. B-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on March 18, 2003 Assigned Aa2 (sf)

  -- Cl. B-2, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on March 18, 2003 Assigned A2 (sf)

  -- Cl. B-3, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba1 (sf)

  -- Cl. B-4, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to B3 (sf)

  -- Cl. B-5, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

Issuer: Sequoia Mortgage Trust 2003-3

  -- Cl. A-1, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. A-2, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. X-1A, Aa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. X-1B, Aa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. X-B, Baa2 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Baa2
     (sf)

  -- Cl. X-2, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. B-1, Baa2 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Baa2
     (sf)

  -- Cl. B-2, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to B1 (sf)

  -- Cl. B-3, Caa2 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa2
     (sf)

  -- Cl. B-4, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

  -- Cl. B-5, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ca (sf)

Issuer: Sequoia Mortgage Trust 2003-5

  -- Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 1, 2003 Assigned Aaa (sf)

  -- Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 1, 2003 Assigned Aaa (sf)

  -- Cl. X-1A, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Oct. 1, 2003 Assigned Aaa (sf)

  -- Cl. X-1B, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Oct. 1, 2003 Assigned Aaa (sf)

  -- Cl. X-B, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa2 (sf)

  -- Cl. X-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 1, 2003 Assigned Aaa (sf)

  -- Cl. B-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 1, 2003 Assigned Aa2 (sf)

  -- Cl. B-2, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 1, 2003 Assigned A2 (sf)

  -- Cl. B-3, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba2 (sf)

  -- Cl. B-4, Caa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa1
     (sf)

  -- Cl. B-5, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

Issuer: Sequoia Mortgage Trust 2003-8

  -- Cl. A-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa2 (sf)

  -- Cl. A-2, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa2 (sf)

  -- Cl. X-2, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa2 (sf)

  -- Cl. X-B, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A2 (sf)

  -- Cl. B-1, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A2 (sf)

  -- Cl. B-2, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba1 (sf)

  -- Cl. B-3, Caa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa1
     (sf)

  -- Cl. B-4, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

  -- Cl. B-5, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ca (sf)

Issuer: Sequoia Mortgage Trust 2004-1

  -- Cl. A1, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A2 (sf)

  -- Cl. X-2, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A2 (sf)

  -- Cl. B-1, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba1 (sf)

  -- Cl. B-2, Caa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa1
     (sf)

  -- Cl. B-3, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

  -- Cl. B-4, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ca (sf)

  -- Cl. B-5, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ca (sf)

Issuer: Sequoia Mortgage Trust 2004-10

  -- Cl. A-1A, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Nov 29, 2004 Assigned Aaa (sf)

  -- Cl. A-1B, Aa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Aa1 (sf)

  -- Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Nov 29, 2004 Assigned Aaa (sf)

  -- Cl. A-3A, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Nov 29, 2004 Assigned Aaa (sf)

  -- Cl. A-3B, Aa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Aa1 (sf)

  -- Cl. A-4, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Nov 29, 2004 Assigned Aaa (sf)

  -- Cl. X-A, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Nov 29, 2004 Assigned Aaa (sf)

  -- Cl. X-B, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A2 (sf)

  -- Cl. B-1, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A2 (sf)

  -- Cl. B-2, Baa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Baa3
     (sf)

  -- Cl. B-3, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to B3 (sf)

Issuer: Sequoia Mortgage Trust 2004-11

  -- Cl. B-2, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba3 (sf)

  -- Cl. B-3, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

  -- Cl. B-4, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ca (sf)

  -- Cl. B-5, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ca (sf)

Issuer: Sequoia Mortgage Trust 2004-12

  -- Cl. A-1, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A1 (sf)

  -- Cl. A-2, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A1 (sf)

  -- Cl. A-3, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A1 (sf)

  -- Cl. X-A1, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A1 (sf)

  -- Cl. X-A2, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A1 (sf)

  -- Cl. X-B, Baa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Baa1
     (sf)

  -- Cl. B-1, Baa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Baa1
     (sf)

  -- Cl. B-2, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to B1 (sf)

  -- Cl. B-3, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

  -- Cl. B-4, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ca (sf)

  -- Cl. B-5, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ca (sf)

Issuer: Sequoia Mortgage Trust 2004-4

  -- Cl. A, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on May 21, 2004 Assigned Aaa (sf)

  -- Cl. X-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on May 21, 2004 Assigned Aaa (sf)

  -- Cl. X-B, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A2 (sf)

  -- Cl. B-1, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A2 (sf)

  -- Cl. B-2, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba2 (sf)

  -- Cl. B-3, Caa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa1
     (sf)

  -- Cl. B-4, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

  -- Cl. B-5, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ca (sf)

Issuer: Sequoia Mortgage Trust 2004-5

  -- Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 30, 2004 Assigned Aaa (sf)

  -- Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 30, 2004 Assigned Aaa (sf)

  -- Cl. A-3, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 30, 2004 Assigned Aaa (sf)

  -- Cl. X-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 30, 2004 Assigned Aaa (sf)

  -- Cl. X-B, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. B-1, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. B-2, Baa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Baa1
     (sf)

  -- Cl. B-3, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba3 (sf)

  -- Cl. B-4, Caa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa1
     (sf)

  -- Cl. B-5, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

Issuer: Sequoia Mortgage Trust 2004-6

  -- Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 30, 2004 Assigned Aaa (sf)

  -- Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 30, 2004 Assigned Aaa (sf)

  -- Cl A-3-A, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on July 30, 2004 Assigned Aaa (sf)

  -- Cl A-3-B, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Dec. 3, 2007 Upgraded to Aaa (sf)

  -- Cl. X-A, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 30, 2004 Assigned Aaa (sf)

  -- Cl. X-B, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A1 (sf)

  -- Cl. B-1, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A1 (sf)

  -- Cl. B-2, Baa2 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Baa2
     (sf)

  -- Cl. B-3, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to B3 (sf)

  -- Cl. B-4, Caa2 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa2
     (sf)

  -- Cl. B-5, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

Issuer: Sequoia Mortgage Trust 2004-7

  -- Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Sep 3, 2004 Assigned Aaa (sf)

  -- Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Sep 3, 2004 Assigned Aaa (sf)

  -- Cl. A-3A, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Sep 3, 2004 Assigned Aaa (sf)

  -- Cl. A-3B, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Dec. 3, 2007 Upgraded to Aaa (sf)

  -- Cl. X-A, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Sep 3, 2004 Assigned Aaa (sf)

  -- Cl. X-B, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. B-1, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. B-2, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A3 (sf)

  -- Cl. B-3, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba2 (sf)

  -- Cl. B-4, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to B3 (sf)

  -- Cl. B-5, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

Issuer: Sequoia Mortgage Trust 2004-8

  -- Cl. A-1, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 26, 2004 Assigned Aaa (sf)

  -- Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 26, 2004 Assigned Aaa (sf)

  -- Cl. X-A, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 26, 2004 Assigned Aaa (sf)

  -- Cl. X-B, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A2 (sf)

  -- Cl. B-1, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A2 (sf)

  -- Cl. B-2, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba2 (sf)

  -- Cl. B-3, Caa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa1
     (sf)

  -- Cl. B-4, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

  -- Cl. B-5, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ca (sf)

Issuer: Sequoia Mortgage Trust 2004-9

  -- Cl. A-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa2 (sf)

  -- Cl. A-2, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa2 (sf)

  -- Cl. X-A, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa2 (sf)

  -- Cl. X-B, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A3 (sf)

  -- Cl. B-1, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A3 (sf)

  -- Cl. B-2, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba2 (sf)

  -- Cl. B-3, Caa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa1
     (sf)

  -- Cl. B-4, Caa2 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa2
     (sf)

  -- Cl. B-5, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa3
     (sf)

Issuer: Sequoia Mortgage Trust 5

  -- Cl. A, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Aa3 (sf)

  -- Cl. B-1, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to A3 (sf)

  -- Cl. B-2, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 23, 2009 Downgraded to Ba2 (sf)

  -- Cl. B-3, Caa1 (sf) Placed Under Review for Possible
     Downgrade; previously on July 23, 2009 Downgraded to Caa1
     (sf)

                        Ratings Rationale

The review action was prompted by continued performance
deterioration of these deals backed by prime jumbo loans
originated before 2005 (seasoned).  Serious delinquencies (loans
greater than 60 or more days delinquent, including loans in
foreclosure and REO) as a percentage of current balance on these
deals have increased from 4.1% as of September 2009 to 5.8% as of
September 2010.

Over the coming months, Moody's expect continued negative
performance on seasoned prime jumbo pools, as the overhang of
impending foreclosures will impact home prices negatively.  The
most important predictor of mortgage default in the past several
years has been the degree to which borrowers have negative equity
in their homes.  Moody's Economy.com expects home prices to fall
by about an additional 5-8%, reaching bottom in the coming year.
Prime jumbo borrowers, who typically had loan-to-value ratios
around 65% at closing, are therefore increasingly subject to
protracted periods of little, and in some cases negative, equity
in their homes.  Although seasoned prime jumbo RMBS pools issued
by Sequoia Mortgage Trust have paid off substantially, with pool
factors averaging below 15%, the remaining loans in these pools
have been under pressure as a result of the sharp decline in home
values.

To determine which tranches to place on review, Moody's compared
the tranches' credit enhancement from subordination to a loss
proxy that was based on a multiple of two times the lifetime
pipeline losses expected from the related pools.  The lifetime
pipeline loss was derived based on lifetime roll rates to default
of 75% for 60-day delinquencies, 85% for 90+ day delinquencies,
97.5% for loans in foreclosure, and 100% for loans where the homes
are held-for-sale, each applied with a severity assumption of
37.5%.  Tranches without enough credit enhancement to maintain
current ratings based on this calculation have been placed on
review for possible downgrade.  Tranches expected to pay off in
full in the coming months were not placed on review.

Although the dollar volume of senior tranches remaining from
seasoned prime jumbo RMBS issued by Sequoia Mortgage Trust is
about 12% of the original dollar volume issued, most of these
deals still have some senior tranches outstanding.  Senior
tranches were placed on review according to the subordination
offered by subordinate/mezzanine tranches.  Certain tranches that
may benefit from super-seniority or first-pay status in the
waterfall may be confirmed as additional transaction-specific
analysis is concluded over the coming months.

           Revision of Loss Methodology for Seasoned RMBS

Moody's will update its loss projection methodology for seasoned
RMBS, and will release a report detailing the updated methodology.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment remains at high
levels, and weakness persists in the housing market.  Moody's
notes an increasing potential for a double-dip recession, which
could cause a further 20% decline in home prices (versus its
baseline assumption of roughly 5% further decline).  Overall,
Moody's assumes a further 5% decline in home prices with
stabilization in early 2011, accompanied by continued stress in
national employment levels through that timeframe.


* S&P Downgrades Ratings on 40 Certs. From Five CMBS Deals
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 40
classes of certificates from five U.S. commercial mortgage-backed
securities transactions.

S&P lowered its ratings due to interest shortfalls.  Fourteen of
these classes experienced shortfalls for four months or less and
are at an increased risk of experiencing shortfalls in the future.
If these shortfalls continue, S&P will likely further downgrade
these classes to 'D (sf)'.  S&P downgraded 26 of these classes to
'D (sf)' because S&P expects these interest shortfalls to
continue.

The 26 classes that S&P downgraded to 'D (sf)' have experienced
interest shortfalls for four or more months.  The recurring
interest shortfalls for the respective certificates are primarily
due to one or more of these factors:

* Appraisal subordinate entitlement reductions in effect for
  specially serviced loans;

* Lack of servicer advances for loans where nonrecoverable advance
  declarations have been made; and

* Special servicing fees.

Standard & Poor's analysis primarily considered the ASERs based on
appraisal reduction amounts calculated using recent Member of the
Appraisal Institute appraisals.  S&P also considered servicer
nonrecoverable advance declarations and special servicing fees
that are likely, in S&P's view, to cause recurring interest
shortfalls.

ARAs and resulting ASERs are implemented in accordance with each
transaction's terms.  Typically, these terms call for the
automatic implementation of an ARA equal to 25% of the stated
principal balance of a loan when a loan is 60 days past due and an
appraisal or other valuation is not available within a specified
timeframe.  S&P primarily considered ASERs based on ARAs
calculated from MAI appraisals when deciding which classes from
the affected transactions to downgrade to 'D (sf)'.  S&P used this
approach because ARAs based on a principal balance haircut are
highly subject to change, or even reversal, once the special
servicer obtains the MAI appraisals.

Servicer nonrecoverable advance declarations can prompt shortfalls
due to a lack of debt service advances, the recovery of previous
advances that the servicer has deemed nonrecoverable, or the
failure to advance trust expenses where nonrecoverable
declarations have been determined.  Trust expenses may include,
but are not limited to, property operating expenses, property
taxes, insurance payments, and legal expenses.

S&P details the 40 downgraded classes from the five CMBS
transactions below.

    Bear Stearns Commercial Mortgage Securities Trust 2007-PWR15

S&P lowered its ratings on the class F, G, H, J, K, L, M, N, and O
certificates from Bear Stearns Commercial Mortgage Securities
Trust 2007-PWR15 due to interest shortfalls resulting from ASERs
related to nine of the 14 loans that are currently with the
special servicer, C-III Asset Management LLC, as well as special
servicing fees.  As of the Oct. 12, 2010, remittance report, ARAs
totaling $126.0 million were in effect for 10 loans.  The total
reported ASER amount was $616,671, and the reported cumulative
ASER amount was $2.3 million.  Standard & Poor's considered eight
ASERs based on MAI appraisals, as well as current special
servicing fees, in determining its rating actions.  The reported
interest shortfalls totaled $716,622 and have affected all of the
classes subordinate to and including class F.  Classes J, K, L, M,
N, and O have experienced interest shortfalls for four (class J),
five (class K), seven (classes L and M), nine (class N), and 12
(class O) months, and S&P expects these shortfalls will recur for
the foreseeable future.  Consequently, S&P downgraded these
classes to 'D (sf)'.

The collateral pool for the BSCMS 2007-PWR15 transaction consists
of 203 loans with an aggregate trust balance of $2.7 billion.  As
of the Oct. 12, 2010, remittance report, 14 loans ($522.9 million;
19.4%) in the pool were with the special servicer.  The payment
status of these loans is: two ($30.6 million, 1.1%) are real
estate owned, seven ($44.4 million, 1.6%) are in foreclosure, four
($443.9 million, 16.2%) are more than 90 days delinquent, and one
($4.0 million, 0.2%) is 30 days delinquent.

               GS Mortgage Securities Trust 2006-GG6

S&P lowered its ratings on the class G, H, J, K, L, M, N, O, P,
and Q certificates from GS Mortgage Securities Trust 2006-GG6
(GSMS 2006-GG6) due to interest shortfalls primarily resulting
from ASERs related to 14 of the 18 loans that are currently with
the special servicer, Torchlight Investors LLC, as well as special
servicing fees.  As of the Oct. 13, 2010, remittance report, ARAs
totaling $192.1 million were in effect for 14 loans.  The total
reported ASER amount was $531,931, and the reported cumulative
ASER amount was $7.4 million.  Standard & Poor's considered 14
ASERs, which totaled $960,829 and were based on MAI appraisals, as
well as current special servicing fees, in determining its rating
actions.  The reported interest shortfalls totaled $704,904 and
have affected all of the classes subordinate to and including
class G.  Classes K, L, M, N, O, P, and Q have experienced
interest shortfalls for seven (class K), 10 (classes L and M), and
12 (classes N, O, P, and Q) months, and S&P expects these
shortfalls to recur in the foreseeable future.  Consequently, S&P
downgraded these classes to 'D (sf)'.

The collateral pool for the GSMS 2006-GG6 transaction consists
of 183 loans with an aggregate trust balance of $3.7 billion.  As
of the Oct. 13, 2010, remittance report, 18 loans ($551.8 million;
15.1%) in the pool were with the special servicer.  The payment
status of the delinquent loans is: one ($15.0 million, 0.4%)
is REO, one ($10.7 million, 0.3%) is in foreclosure, 11
($358.9 million, 9.8%) are more than 90 days delinquent, one
($2.3 million, 0.1%) is 30 days delinquent, one ($7.2 million,
0.2%) is a nonperforming matured balloon loan, and three
($157.9 million, 4.3%) are less than 30 days delinquent.

   JPMorgan Chase Commercial Mortgage Securities Trust 2006-LDP8

S&P lowered its ratings on the class J, K, L, M, N, and P
certificates from JPMorgan Commercial Mortgage Securities Trust
2006-LDP8 due to interest shortfalls resulting from ASERs related
to 13 of the 15 loans that are currently with the special
servicer, J.E. Robert Co. Inc., as well as special servicing fees.
As of the Oct. 15, 2010, remittance report, ARAs totaling
$54.0 million were in effect for 13 loans.  The total reported
ASER amount was $280,027, and the reported cumulative ASER amount
was $3.3 million.  Standard & Poor's considered 13 ASERs based on
MAI appraisals and current special servicing fees in determining
its rating actions.  The reported interest shortfalls totaled
$311,027 and have affected all of the classes subordinate to and
including class J.  Classes M, N, and P have experienced interest
shortfalls for six, 10, and 12 months, respectively, and S&P
expects these shortfalls will recur for the foreseeable future.
Consequently, S&P downgraded these classes to 'D (sf)'.

The collateral pool for the JPMC 2006-LDP8 transaction consists of
151 loans with an aggregate trust balance of $3.0 billion.  As of
the Oct. 15, 2010, remittance report, 15 loans ($319.7 million;
10.6%) in the pool were with the special servicer.  The payment
status of these loans is: one ($3.9 million, 0.1%) is REO, six
($52.8 million, 1.8%) are in foreclosure, six ($84.4 million,
2.8%) are more than 90 days delinquent, one ($171.2 million, 5.7%)
is in its grace period, and one ($7.4 million, 0.3%) is current.

              ML-CFC Commercial Mortgage Trust 2006-1

S&P lowered its ratings on the class H, J, L, and M certificates
from ML-CFC Commercial Mortgage Trust 2006-1 due to interest
shortfalls resulting from ASERs related to 11 of the 17 loans that
are currently with the special servicer, Midland Loan Services
Inc., as well as special servicing fees.  As of the Oct. 12, 2010,
remittance report, ARAs totaling $59.6 million were in effect for
11 loans.  The total reported ASER amount was $284,442, and the
reported cumulative ASER amount was $2.6 million.  Standard &
Poor's considered nine ASERs based on MAI appraisals, as well as
current special servicing fees in determining its rating actions.
The reported interest shortfalls totaled $298,523 and have
affected all of the classes subordinate to and including class H.
Classes L and M have experienced interest shortfalls for four and
12 months, respectively, and S&P expects these shortfalls will
recur for the foreseeable future.  Consequently, S&P downgraded
these classes to 'D (sf)'.

The collateral pool for the ML-CFC 2006-1 transaction consists of
144 loans with an aggregate trust balance of $2.0 billion.  As of
the Oct. 12, 2010, remittance report, 17 loans ($168.4 million;
8.2%) in the pool were with the special servicer.  The payment
status of these loans is: four ($26.2 million, 1.3%) are in
foreclosure, 11 ($115.8 million, 5.7%) are more than 90 days
delinquent, and two ($26.3 million, 1.3%) are in their grace
period.

             Morgan Stanley Capital I Trust 2007-HQ13

S&P lowered its ratings on the class D, E, F, G, H, J, K, L, M, N,
and O certificates from Morgan Stanley Capital I Trust 2007-HQ13
due to interest shortfalls resulting from ASERs related to the
eight loans that are currently with the special servicer, C-III,
as well as special servicing fees.  As of the Oct. 18, 2010,
remittance report, ARAs totaling $69.3 million were in effect for
11 loans.  The total reported ASER amount for eight of the 11
loans was $324,108, and the reported cumulative ASER amount was
$1.6 million.  Standard & Poor's considered eight ASERs based on
MAI appraisals, as well as current special servicing fees, in
determining its rating actions.  The reported interest shortfalls
totaled $346,902 and have affected all of the classes subordinate
to and including class E.  Classes G, H, J, K, L, M, N, and O have
experienced interest shortfalls for five (classes G, H, J, and K),
seven (class L), nine (class M), 10 (class N), and 12 (class O)
months, and S&P expects these shortfalls to recur in the
foreseeable future.  Consequently, S&P downgraded these classes to
'D (sf)'.

The collateral pool for the MSC 2007-HQ13 transaction consists of
79 loans with an aggregate trust balance of $921.2 million.  As of
the Oct. 18, 2010, remittance report, 13 loans ($191.9 million;
20.7%) in the pool were with the special servicer.  The payment
status of these loans is: two ($12.9 million, 1.3%) are REO, four
($119.1 million, 12.9%) are in foreclosure, three
($26.9 million, 2.8%) are more than 90 days delinquent, three
($19.6 million, 2.1%) are nonperforming matured balloons, and one
($13.4 million, 1.4%) is current.

                         Ratings Lowered

   Bear Stearns Commercial Mortgage Securities Trust 2007-PWR15
         Commercial mortgage pass-through certificates

                                                        Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From      Credit enhancement (%)  Current  Accumulated
-----  --        ----      ----------------------  -------  -----------
F      CCC- (sf) B  (sf)        4.63               144,017      321,843
G      CCC- (sf) B- (sf)        3.61               134,421      273,192
H      CCC- (sf) B-(sf)         2.59               134,421      273,192
J      D (sf)    CCC+ (sf)      2.20                44,056      115,163
K      D (sf)    CCC+ (sf)      1.95                29,366      145,786
L      D (sf)    CCC+ (sf)      1.56                44,056      284,343
M      D (sf)    CCC+ (sf)      1.44                14,685      102,796
N      D (sf)    CCC  (sf)      1.18                29,370      223,990
O      D (sf)    CCC- (sf)      0.93                29,370      288,491

              GS Mortgage Securities Trust 2006-GG6
          Commercial mortgage pass-through certificates

                                                        Reported
          Rating                                  interest shortfalls ($)
          ------