TCR_Public/101114.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 14, 2010, Vol. 14, No. 316

                            Headlines

505 CLO: S&P Raises Ratings on Various Classes of Notes
ACE SECURITIES: Moody's Downgrades Ratings on 13 Tranches
AMERICAN GENERAL: Moody's Confirms Ratings on Seven Tranches
AMERICAN HOME: Moody's Downgrades Ratings on Seven Tranches
AMERICREDIT AUTOMOBILE: Moody's Assigns Ratings on Various Classes

AMERICREDIT AUTOMOBILE: S&P Assigns Ratings on Various Notes
ARBOR REALTY: Fitch Downgrades Ratings on Three Classes of Notes
BANC OF AMERICA: Moody's Downgrades Ratings on 16 Certificates
BANC OF AMERICA: Moody's Downgrades Ratings on 195 Tranches
BANC OF AMERICA: S&P Corrects Rating on Class A-2 to 'CC'

BEAR STEARNS: Moody's Cuts Ratings on 15 2001-A Tranches
BEAR STEARNS: Moody's Affirms Ratings on 12 2006-BBA7 Certificates
BERNARD NATIONAL: S&P Withdraws Ratings on Three Classes
CALIFORNIA STATEWIDE: Fitch Cuts Rating on $5,540,000 Bonds to BB
CASTLE HILL: S&P Raises Ratings on Various Classes of Notes

CELERITY CLO: S&P Raises Ratings on Two Classes of Notes
CITY OF ANDERSON: Fitch Cuts Rating on Bonds to 'BB+'
CITY OF GILMER: Moody's Upgrades Rating on Bonds From 'Ba1'
CNL FUNDING: Moody's Reviews Ratings on Four Classes of Certs.
COMM 2004-LNB3: S&P Downgrades Ratings on 10 Classes of Securities

CORSAIR NO 4: Moody's Upgrades Ratings on Notes to 'Ba3'
CREDIT SUISSE: Fitch Downgrades Ratings on 15 2005-C5 Certs.
CREDIT SUISSE: Moody's Downgrades Ratings on Five 2001-CK1 Certs.
CREDIT SUISSE: Moody's Reviews Ratings on 14 2004-C5 Certificates
CREDIT SUISSE: Moody's Downgrades Ratings on Nine 2005-C3 Certs.

CREDIT SUISSE: Moody's Affirms Ratings on 12 2007-C3 Certificates
CRYSTAL RIVER: Fitch Affirms Ratings on Eight Classes of Notes
CWMBS INC: Moody's Downgrades Ratings on 12 Tranches
DILLON READ: Fitch Takes Rating Actions on Various Classes
FEDERAL FAMILY: S&P Takes Various Rating Actions on 11 Loans

FEP RECEIVABLES: Moody's Cuts Ratings on 4 Classes to C (sf)
FFCA SECURED: Moody's Reviews Ratings on Various Classes of Notes
FIRST MARBLEHEAD: Fitch Downgrades Ratings on 2006-A Notes
FLORIDA KEYS: S&P Assigns 'BB+' Rating to Senior Revenue Bonds
GE COMMERCIAL: S&P Raises Ratings on Various Classes of Notes

GE COMMERCIAL: S&P Withdraws Ratings on Various Classes of Notes
GMAC COMMERCIAL: S&P Downgrades Ratings on Five 2000-C2 Notes
GRAYSTON CLO: Moody's Upgrades Ratings on Various Classes
GREENPOINT HOME: Moody's Downgrades Ratings on 11 Tranches
GSC CAPITAL: Moody's Downgrades Ratings on Three Tranches

HSI ASSET: Moody's Downgrades Ratings on Six 2007-WF1 Tranches
JEFFERSON COUNTY: Moody's Affirms 'Ba3' Rating to Housing Bondss
JEFFERIES MILITARY: DBRS Assigns B Rating on Hunter Project Certs.
JOHNSON CITY: Moody's Downgrades Ratings on Revenue Bonds to 'Ba3'
JP MORGAN: Moody's Downgrades Ratings on 17 Tranches

JP MORGAN: Moody's Reviews Ratings on Nine 2003-LN1 Certificates
JP MORGAN: Moody's Reviews Ratings on 15 2004-LN2 Certificates
JP MORGAN: Moody's Reviews Ratings on 15 2005-CIBC12 Certs.
JP MORGAN: Moody's Reviews Ratings on 18 2005-LDP2 Certificates
JP MORGAN: Moody's Reviews Ratings on 2006-CIBC15 Certificates

JP MORGAN: Moody's Reviews Ratings on 15 2006-CIBC17 Certs.
KATONAH IV: S&P Raises Ratings on Various Classes of Notes
KIMBERLITE CDO: Fitch Affirms Ratings on Eight Classes of Notes
KINGSLAND II: Moody's Upgrades Ratings on Three Classes of Notes
LB-UBS COMMERCIAL: Moody's Downgrades Ratings on 2002-C2 Certs.

LCM I: S&P Corrects Press Release; Raises Ratings on Various Notes
LEHMAN BROTHERS: Moody's Confirms Ratings on 14 2006-C3 Certs.
LNR CDO: Fitch Affirms Ratings on 12 Classes of Notes
MAGNOLIA FINANCE: S&P Puts 'CCC-' Rating on CreditWatch Positive
MERRILL LYNCH: DBRS Upgrades Class G Rating to BB (High) From BB

MERRILL LYNCH: DBRS Confirms 'B' Rating on Class K Certs.
MERRILL LYNCH: Moody's Takes Rating Actions on 2004-MKB1 Certs.
MEZZ CAP: S&P Downgrades Ratings on 13 Classes of Certs.
MORGAN STANLEY: Moody's Reviews Ratings on 18 2007-HQ11 Certs.
MORGAN STANLEY: Moody's Reviews Ratings on 15 2007-TOP25 Certs.

MORGAN STANLEY: S&P Raises Rating on Class H 1998-HF1 Certs.
MORGAN STANLEY: S&P Downgrades Ratings on Eight 2002-IQ3 Certs.
MORGAN STANLEY: S&8P Downgrades Ratings on 12 2007-XLF9 Certs.
NEW CENTURY: Moody's Downgrades Ratings on 11 Tranches
NEWGATE FUNDING: Moody's Reviews Ratings on Various Classes

PHH ALTERNATIVE: Moody's Downgrades Ratings on 17 Tranches
PHH WACHOVIA: Moody's Downgrades Ratings on Six Tranches
PHOENIX CLO: S&P Raises Ratings on Various Classes of Notes
PROTECTIVE FINANCE: Moody's Upgrades Ratings on Six Classes
PORTER SQUARE: Fitch Cuts Rating on CDO I Class B Notes to 'Csf'

PORTER SQUARE: Fitch Cuts Rating on CDO II Class A-2 Notes to Csf
PORTER SQUARE: Fitch Cuts Rating on CDO III A-2 & B Notes to 'Dsf'
PRETSL COMBINATION: Moody's Cuts Rating on XXVI-2 Certs. to C (sf)
PRUDENTIAL SECURITIES: Moody's Takes Actions on 1999-NRF1 Notes
SALOMON BROTHERS: Moody's Downgrades Ratings on Five Classes

SCHOONER TRUST: DBRS Confirms B Rating on 2006-6 Class K Certs.
SCHOONER TRUST: DBRS Confirms B Rating on 2007-8 Class K Certs.
SEQUOIA ALTERNATIVE: Moody's Downgrades Ratings on Two Tranches
SOLOSO CDO: S&P Downgrades Ratings on Two Classes to 'D'
SOUNDVIEW HOME: Moody's Downgrades Ratings on Three Tranches

STARM MORTGAGE: Moody's Downgrades Ratings on 10 Tranches
TCW HIGH: Moody's Upgrades Ratings on Four Classes of Notes
TEXAS PUBLIC: Fitch Upgrades Rating on $86.2 Mil. Bonds From 'BB+'
WACHOVIA BANK: Moody's Downgrades Ratings on 17 2006-C24 Certs.
WACHOVIA BANK: Moody's Reviews Ratings on 11 2006-C28 Certs.

WCP WIRELESS: Fitch Rates Class C Notes at 'BB-sf'
WESTERLY HOSPITAL: Moody's Junks Ratings on Series 1994 Bonds
WIREFREE PARTNERS: S&P Withdraws 'BB-' Rating on $138.5 Mil. Notes

* Fitch Downgrades Ratings on 229 Bonds in 155 RMBS Deals
* Moody's Reviews Ratings on Tranches From Three Subprime RMBS
* S&P Downgrades Ratings on 71 Certs. From 10 CMBS Transactions
* S&P Takes Various Rating Actions on Three Market Value CDOs

                            *********

505 CLO: S&P Raises Ratings on Various Classes of Notes
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, D, and E notes issued by 505 CLO III Ltd., a collateralized
loan obligation transaction managed by CIT Asset Management LLC,
and removed them from CreditWatch with positive implications.  At
the same time, S&P affirmed its 'AAA (sf)' ratings on the class A-
1 and A-2 notes.

The raised ratings reflect improvement in the credit enhancement
available to support the notes since S&P affirmed its ratings on
these notes on Feb. 4, 2010.  Since that time, the transaction has
paid down approximately $181.04 million to the class A-1 and A-2
notes, pro rata, including a total payment of $47.6 million on the
Aug. 20, 2010, distribution, thereby increasing the
overcollateralization available to support the rated notes.

The trustee reported these O/C ratios in the Sept. 28, 2010,
monthly report:

* The class A/B O/C ratio was 181.79%, compared with a reported
  ratio of 145.12% in November 2009; and

* The class C O/C ratio was 156.51%, compared with a reported
  ratio of 131.88% in November 2009;

* The transaction has also benefitted from an improvement in
  credit quality.

As of the Sept. 28, 2010, trustee report, the transaction had
$21.8 million in defaulted assets, down from $31 million noted
in the Nov. 25, 2009 trustee report.  Furthermore, assets
from obligors rated in the 'CCC' category were reported at
$165.6 million in September 2010, compared with $253.7 million
in November 2009.

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 And Creditwatch Actions

                         505 CLO III Ltd.

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

                         Ratings Affirmed

                         505 CLO III Ltd.

                       Class       Rating
                       -----       ------
                       A-1         AAA (sf)
                       A-2         AAA (sf)

  Transaction Information
  -----------------------
Issuer:             505 CLO III Ltd.
Collateral manager: CIT Asset Management LLC
Underwriter:        Morgan Stanley & Co. Inc.
Trustee:            U.S. Bank National Association
Transaction type:   Cash flow CLO


ACE SECURITIES: Moody's Downgrades Ratings on 13 Tranches
---------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 13
tranches from 8 RMBS transactions issued by ACE Securities Corp.
Home Equity Loan Trust.  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 all of the
deals' ratings would remain stable.

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: ACE Securities Corp. Home Equity Loan Trust, Series 2005-
SL1

  * Expected Losses (as a % of Original Balance): 29%

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

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2006-
ASL1

  * Expected Losses (as a % of Original Balance): 51%

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

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2006-
SL1

  * Expected Losses (as a % of Original Balance): 46%

  -- Cl. A, Downgraded to C (sf); previously on March 18, 2010 B1
     (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2006-
SL2

  * Expected Losses (as a % of Original Balance): 66%

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

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2006-
SL3

  * Expected Losses (as a % of Original Balance): 57%

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

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

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2006-
SL4

  * Expected Losses (as a % of Original Balance): 51%

  -- Cl. A-1, Downgraded to C (sf); previously on March 18, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-2, Downgraded to C (sf); previously on March 18, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-3, Downgraded to C (sf); previously on March 18, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2007-
ASL1

  * Expected Losses (as a % of Original Balance): Group 1 - 68%,
    Group 2 -- 77%

  -- Cl. A-1, Downgraded to C (sf); previously on March 18, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

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

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2007-
SL1

  * Expected Losses (as a % of Original Balance): Group 1 - 67%,
    Group 2 -- 75%

  -- 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
     Ca (sf) Placed Under Review for Possible Downgrade


AMERICAN GENERAL: Moody's Confirms Ratings on Seven Tranches
------------------------------------------------------------
Moody's Investors Service has confirmed the ratings of 7 tranches
from American General Mortgage Pass-Through Certificates, Series
2006-1.  The collateral backing this deal primarily consists of
first-lien, fixed rate Alt-A residential mortgages.

                        Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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: American General Mortgage Pass-Through Certificates,
Series 2006-1

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

  -- Cl. A-3, Confirmed at Aaa (sf); previously on Jan. 14, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-4, Confirmed at Aaa (sf); previously on Jan. 14, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-5, Confirmed at Aaa (sf); previously on Jan. 14, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. M-1, Confirmed at Aa2 (sf); previously on Jan. 14, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. M-2, Confirmed at A1 (sf); previously on Jan. 14, 2010 A1
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. B-1, Confirmed at A3 (sf); previously on Jan. 14, 2010 A3
      (sf) Placed Under Review for Possible Downgrade


AMERICAN HOME: Moody's Downgrades Ratings on Seven Tranches
-----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of seven
tranches and confirmed the ratings of two tranches from eight RMBS
transactions issued by American Home Mortgage Investment Trust.
The collateral backing these deals primarily consists of closed
end second lien loans and home equity lines of credit.

                        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.  Class IX-A issued by
American Home Mortgage Investment Trust 2005-1, Class VI-A issued
by American Home Mortgage Investment Trust 2005-2, Class II-A
issued by American Home Mortgage Investment Trust 2005-4 are
wrapped by Financial Guaranty Insurance Company (Rating
Withdrawn).  Additionally Class V-A issued by American Home
Mortgage Investment Trust 2006-2 is wrapped by CIFG Assurance
North America, Inc. (Rating Withdrawn).  RMBS securities wrapped
by Financial Guaranty Insurance Company or CIFG Assurance North
America, Inc. are rated at their underlying rating without
consideration of the respective guaranties.

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 all of the
deals' ratings would remain stable.

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: American Home Mortgage Investment Tr 2006-3

  * Expected Losses (as a % of Original Balance): 59%

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

Issuer: American Home Mortgage Investment Trust 2005-1

  * Expected Losses (as a % of Original Balance): 10%

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

  -- Financial Guarantor: Financial Guaranty Insurance Company
     (Insured Rating Withdrawn March 25, 2009)

Issuer: American Home Mortgage Investment Trust 2005-2

  * Expected Losses (as a % of Original Balance): 16%

  -- Cl. VI-A, Downgraded to Ca (sf); previously on March 18, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Financial Guarantor: Financial Guaranty Insurance Company
     (Insured Rating Withdrawn March 25, 2009)

Issuer: American Home Mortgage Investment Trust 2005-4

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

  -- Cl. II-A, Downgraded to Ca (sf); previously on March 18, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Financial Guarantor: Financial Guaranty Insurance Company
      (Insured Rating Withdrawn March 25, 2009)

Issuer: American Home Mortgage Investment Trust 2005-SD1

  * Expected Losses (as a % of Original Balance): 39%

  -- Cl. II-A1, Confirmed at Caa1 (sf); previously on March 18,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

Issuer: American Home Mortgage Investment Trust 2006-2

  * Expected Losses (as a % of Original Balance): Group IV 52%,
    Group V 35%

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

  -- Cl. V-A, Confirmed at Ca (sf); previously on March 18, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Financial Guarantor: CIFG Assurance North America, Inc.
      (Insured Rating Withdrawn Nov 12, 2009)

Issuer: American Home Mortgage Investment Trust 2007-2

  * Expected Losses (as a % of Original Balance): 82%

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

Issuer: American Home Mortgage Investment Trust 2007-A
  * Expected Losses (as a % of Original Balance): 68%

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


AMERICREDIT AUTOMOBILE: Moody's Assigns Ratings on Various Classes
------------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to the
notes to be issued by AmeriCredit Automobile Receivables Trust
2010-4.  This is the sixth overall and fourth senior/subordinated
transaction of the year for AmeriCredit Financial Services, Inc.

The complete rating actions are:

Issuer: AmeriCredit Automobile Receivables Trust 2010-4

  -- Class A-1 Notes, rated (P) Prime-1 (sf);
  -- Class A-2 Notes, rated (P) Aaa (sf);
  -- Class A-3 Notes, rated (P) Aaa (sf);
  -- Class B Notes, rated (P) Aa1 (sf);
  -- Class C Notes, rated (P) Aa3 (sf);
  -- Class D Notes, rated (P) Baa2 (sf);
  -- Class E Notes, rated (P) Ba2 (sf);

                        Ratings Rationale

Moody's said the ratings are based on the quality of the
underlying auto loans and their expected performance, the strength
of the structure, the availability of excess spread over the life
of the transaction, the experience and expertise of AmeriCredit
Financial Services, Inc., as servicer, and the backup servicing
arrangement with Aa2-rated Wells Fargo Bank, N.A.

Moody's median cumulative net loss expectation for the AMCAR 2010-
4 pool is 11.5% and total credit enhancement required to achieve
Aaa rating (i.e. Aaa proxy) is 40.0%.  The loss expectation was
based on an analysis of AmeriCredit's portfolio vintage
performance as well as performance of past securitizations, and
current expectations for future economic conditions.

The Assumption Volatility Score for this transaction is Low/Medium
versus a Medium for the sector.  This is driven by the a
Low/Medium assessment for Governance due to the strong back-up
servicing arrangement present in this transaction in addition to
the size and strength of AmeriCredit's servicing platform.

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 Parameter Sensitivities: If the net loss used in
determining the initial rating were changed to 20%, 25% or 35.0%,
the initial model output for the Class A notes might change from
Aaa to Aa1, Aa2, and A2, respectively; Class B notes might change
from Aa1 to A3, Baa3, and below B2, respectively; Class C notes
might change from Aa3 to Ba1, B3, and below B3, respectively;
Class D notes might change from Baa2 to below B3 in all three
scenarios; and Class D notes might change from Ba2 to below B3 in
all three scenarios.

Parameter Sensitivities are not intended to measure how the rating
of the security might migrate over time, rather they are designed
to provide a quantitative calculation of how the initial rating
might change if key input parameters used in the initial rating
process differed.  The analysis assumes that the deal has not
aged.  Parameter Sensitivities only reflect the ratings impact of
each scenario from a quantitative/model-indicated standpoint.
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 did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments in this transaction.


AMERICREDIT AUTOMOBILE: S&P Assigns Ratings on Various Notes
------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to AmeriCredit Automobile Receivables Trust 2010-4's
$682.546 million automobile receivables-backed notes.

The preliminary ratings are based on information as of Nov. 8,
2010.  Subsequent information may result in the assignment of
final ratings that differ from the preliminary ratings.

The preliminary ratings reflect S&P's view of:

The availability of approximately 43.9%, 38.7%, 31.5%, 25.0%, and
22.5% credit support for the class A, B, C, D, and E notes,
respectively (based on stressed cash flow scenarios, including
excess spread), which provides coverage of more than 3.50x, 3.00x,
2.55x, 1.75x, and 1.50x S&P's 11.75%-12.25% expected cumulative
net loss range for the class A, B, C, D, and E notes,
respectively.  These credit support levels are commensurate with
the assigned preliminary 'AAA (sf)', 'AA (sf)', 'A+ (sf)', 'BBB
(sf)', and 'BB (sf)' ratings on the class A, B, C, D, and E notes,
respectively.

S&P's expectation that under a moderate, or 'BBB (sf)', stress
scenario, the ratings on the class A, B, and C notes would not
decline by more than one rating category (all else being equal).
In the case of the 'AAA' and 'AA' rated securities, this is
consistent with S&P's rating stability criteria.  In the case of
the 'A+' rated notes, this is slightly superior to its minimum
rating stability criteria, which permits a two-category downgrade.

The credit enhancement in the form of subordination,
overcollateralization, a reserve account, and excess spread.

The timely interest and ultimate principal payments made under the
stressed cash flow modeling scenarios, which are consistent with
the assigned preliminary ratings.  The collateral characteristics
of the securitized pool of subprime automobile loans.

AmeriCredit Corp.'s extensive securitization performance history
going back to 1994.

The transaction's payment and legal structures.

                   Preliminary Ratings Assigned

         AmeriCredit Automobile Receivables Trust 2010-4

                                               Interest        Amount
   Class       Rating          Type            rate           (mil. $)*
   -----       ------          ----            --------       ---------
   A-1         A-1+ (sf)       Senior          Fixed           182.800
   A-2         AAA (sf)        Senior          Fixed           223.000
   A-3         AAA (sf)        Senior          Fixed            90.327
   B           AA (sf)         Subordinate     Fixed            53.846
   C           A+ (sf)         Subordinate     Fixed            66.843
   D           BBB (sf)        Subordinate     Fixed            65.730
   E**         BB (sf)         Subordinate     Fixed            17.454

* The actual size of these tranches will be determined on the
  pricing date.

** Class E will be privately placed and is not included in the
   amount of the public offering.


ARBOR REALTY: Fitch Downgrades Ratings on Three Classes of Notes
----------------------------------------------------------------
Fitch Ratings has downgraded three classes and affirmed one class
of Arbor Realty Mortgage Securities Series 2004-1 Ltd/LLC,
reflecting Fitch's increased base case loss expectation of 56.8%.
Fitch's performance expectation incorporates prospective views
regarding commercial real estate market value and cash flow
declines.

The downgrades of the bottom three rated classes are a result of
the increased base case expected loss of 56.8% from 46.3% at last
review.  Since last review, four assets were removed from the
pool, including two payoffs and two investment grade rated CMBS
sold at slight discounts to par; these assets had little to no
base case expected losses at last review.  Further, defaulted
assets have risen slightly to 4.8% from 1.5% while loans of
concern have increased significantly to 35.1% from 13.5% at last
review.

ARMSS 2004-1 is a commercial real estate collateralized debt
obligation managed by Arbor Realty Trust, Inc.  The transaction
had a five-year reinvestment period that ended in April 2009.  As
of the Oct. 15, 2010 trustee report, all over collateralization
and interest coverage ratios were in compliance.  However, the
class A/B OC test had a cushion of only 0.2%; failure of this test
will result in interest proceeds being diverted from lower classes
to pay down the senior class.

Under Fitch's methodology, approximately 74.5% 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 7.6% from, generally, either year end 2009 or trailing
12-month first or second quarter 2010.  Fitch estimates that
average recoveries will be 23.8% as the majority 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 portfolio of six full and limited service
hotels located in Daytona Beach, Florida.  The portfolio was
recently taken out of bankruptcy.  An Arbor affiliate is
anticipated to take title to the properties.  Fitch modeled 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 B-note secured by a multifamily property located in
Ypsilanti, Michigan.  Performance has suffered due to poor market
conditions; and cash flow from the property is not supporting debt
service.  Fitch modeled a substantial loss in its base case
scenario.

The third largest component of Fitch's base case loss expectation
is a B-note secured by a multifamily property located in
Clearwater, Florida.  Property performance has not improved as
expected, and the borrower has requested interest rate relief on
multiple occasions.  Fitch modeled a term default and a full 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 'BB' rating category, and the
class B notes' credit characteristics are generally consistent
with the 'B' rating category.

The ratings for classes C and D 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 C
and D are consistent with the 'CCC' rating category, meaning
default is a real possibility.  Fitch's base case loss expectation
of 56.8% exceeds these classes' respective current credit
enhancement levels.

Classes A and B 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 of 'LS4' and 'LS5', respectively.  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 C and D 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 assignment of 'RR6' to class C and D reflects modeled
recoveries of less than 10% of each classes' outstanding principal
balance.

Fitch has affirmed this class:

  -- $155,171,330 class A at 'BBsf/LS4'; Outlook Negative.

Fitch has downgraded and assigned Recovery Ratings (RR) to these
classes:

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

  -- $27,635,768 class C to 'CCCsf/RR6' from 'Bsf/LS5';

  -- $11,183,232 class D to 'CCCsf/RR6' from 'Bsf/LS5'.


BANC OF AMERICA: Moody's Downgrades Ratings on 16 Certificates
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of 16 classes and
affirmed nine classes of Banc of America Commercial Mortgage Inc.,
Commercial Pass-Through Certificates, Series 2006-1:

  -- Cl. A-1 Certificate, Affirmed at Aaa (sf); previously on
     March 14, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2 Certificate, Affirmed at Aaa (sf); previously on
     March 14, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3A Certificate, Affirmed at Aaa (sf); previously on
     March 14, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3B Certificate, Affirmed at Aaa (sf); previously on
     March 14, 2006 Assigned Aaa (sf)

  -- Cl. A-4 Certificate, Affirmed at Aaa (sf); previously on
     March 14, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-1A Certificate, Affirmed at Aaa (sf); previously on
     March 14, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-SBFL Certificate, Affirmed at Aaa (sf); previously on
     March 14, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. XP Certificate, Affirmed at Aaa (sf); previously on
     March 14, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. XC Certificate, Affirmed at Aaa (sf); previously on
     March 14, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-M Certificate, Downgraded to Aa1 (sf); previously on
     Sept. 29, 2010 Aaa (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. A-J Certificate, Downgraded to Baa1 (sf); previously on
     Sept. 29, 2010 Aa3 (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. B Certificate, Downgraded to Baa2 (sf); previously on
     Sept. 29, 2010 A1 (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. C Certificate, Downgraded to Ba1 (sf); previously on
     Sept. 29, 2010 A2 (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. D Certificate, Downgraded to B3 (sf); previously on
     Sept. 29, 2010 A3 (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. E Certificate, Downgraded to Caa1 (sf); previously on
     Sept. 29, 2010 Baa2 (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. F Certificate, Downgraded to Caa2 (sf); previously on
     Sept. 29, 2010 Baa3 (sf) Placed Under Review for Possible
     Downgrade

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

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

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

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

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

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

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

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

  -- Cl. P Certificate, 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.  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 29, 2010, Moody's placed classes AM through P on
review for possible downgrade.  This action concludes Moody's
review.

Moody's rating action reflects a cumulative base expected loss of
10.1% of the current balance.  At last review, Moody's cumulative
base expected loss was 3.8%.  Moody's stressed scenario loss is
18.8% 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.  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 50, compared to 57 at last review.

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 9, 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 7% to
$1.956 billion from $2.037 billion at securitization.  The
Certificates are collateralized by 192 mortgage loans ranging in
size from less than 1% to 8% of the pool, with the top ten loans
representing 36% of the pool.  No loans have defeased.  The pool
contains two loans, representing 10% of the pool with investment
grade credit estimates.

Forty nine loans, representing 20% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the 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.

No loans have been liquidated from the pool.  Nineteen loans,
representing 8% of the pool, are currently in special servicing.
The largest specially serviced loan is the Marriot Courtyard Grand
Cayman Loan ($28.1 million -- 1.5% of the pool), which is secured
by a 232 room hotel property located in the Grand Cayman Islands.
The loan was transferred to special servicing in January 2009 due
to the hotel's closing as a result of damage from hurricane Paloma
in November 2008.  A August 2010 appraisal valued this property at
$2.0 million.

The remaining specially serviced loans are secured by a mix of
property types.  The master servicer has recognized appraisal
reductions totaling $86.5 million for 17 of the specially serviced
loans.  Moody's has estimated an aggregate $105.9 million loss
(67% expected loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for 24 poorly
performing loans representing 9% of the pool and has estimated a
$50.1 million loss (27% expected loss based on a 58% probability
default) from these troubled loans.

Based on the most recent remittance statement, Classes G through
Q have experienced cumulative interest shortfalls totaling
$6.8 million.  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 82%
of the conduit pool.  Excluding specially serviced and troubled
loans, Moody's weighted average LTV is 104% compared to 137% 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 1.31X and 1.06X, respectively, compared to
1.07X 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 largest loan with a credit estimate is the Kinder Care
Portfolio Loan ($142.8 million -- 7.5% of the pool), which is
secured by 713 childcare facilities located in 37 states.  The
loan represents a pari passu interest in a $632.5 million first
mortgage loan.  The largest state concentration is California,
with 12% of the portfolio.  Moody's current credit estimate and
stressed DSCR are A3 and 1.86X, respectively, compared to A3 and
1.28X at Moody's last full review.

The second largest loan with a credit estimate is the Torre Mayor
Loan ($52.7 million -- 2.8% of the pool), which is secured by an
829,000 square foot Class A office building located in Mexico
City, Mexico.  The loan represents a 50% pari-passu interest in
a $125.4 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.  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 12% of the pool
balance.  The largest loan is the Desert Passage Loan
($128.7 million -- 6.8% of the pool), which secured by a 500,000
square foot specialty retail and entertainment center located on
the ground level of the Planet Hollywood Resort and Casino in Las
Vegas, Nevada.  The loan represents 33% pari passu interest in a
$390 million first mortgage loan.  The property was 91% leased as
of June 2010 compared to 95% at last review.  Moody's LTV and
stressed DSCR are 108% and 0.90X, respectively, compared to 123%
and 0.80X at last review.

The second largest loan is the Waterfront at Port Chester Loan
($105.5 million -- 2.8% of the pool), which is secured by a
295,000 square foot retail center located in Port Chester
(Westchester County), New York.  The center has maintained 100%
occupancy since securitization.  Moody's LTV and stressed DSCR are
113% and 0.81X, respectively, compared to 136% and 0.7X at last
review.

The third largest loan is the Fairmont Sonoma Mission Inn & Spa
Loan ($55.0 million -- 2.9% of the pool), which is secured by a
266 room full service hotel located in Sonoma, California.  The
loan is currently on the watchlist due to a decline in
performance.  Performance has declined as a result of decreased
occupancy.  Moody's LTV and stressed DSCR are 243% and 0.49X,
respectively, compared to 116% and 1.02X at last review.


BANC OF AMERICA: Moody's Downgrades Ratings on 195 Tranches
-----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 195
tranches, confirmed the ratings of 13 tranches and upgraded the
ratings of 6 tranches from 12 RMBS transactions issued by Banc of
America Funding Trust.  The collateral backing these deals
primarily consists of first-lien, fixed and adjustable-rate Alt-A
residential mortgages.

Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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: Banc of America Funding 2006-7 Trust, Mortgage Pass-
Through Certificates, Series 2006-7

  -- Cl. 1-A-1, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-2, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-3, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-4, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-5, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-7, Upgraded to Baa1 (sf); previously on Jan. 14, 2010
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-8, Upgraded to Baa2 (sf); previously on Jan. 14, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-9, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-10, Downgraded to C (sf); previously on Jan. 14, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-11, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-12, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T2-A-1, Downgraded to Caa3 (sf); previously on Aug. 5,
     2010 Downgraded to Caa1 (sf) and Remained On Review for
     Possible Downgrade

  -- Cl. T2-A-2, Downgraded to Caa3 (sf); previously on Aug. 5,
     2010 Downgraded to Caa1 (sf) and Remained On Review for
     Possible Downgrade

  -- Cl. T2-A-3, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T2-A-4, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T2-A-5, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T2-A-6, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T2-A-7, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T2-A-8, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T2-A-A, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. T2-A-B, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 30-IO, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 30-PO, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Funding 2006-G Trust

  -- Cl. 1-A-1, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-1, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-2, Upgraded to Aaa (sf); previously on Jan. 14, 2010
     A2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-3, Upgraded to A2 (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-4, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Ba2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-5, Downgraded to Ca (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A-1, Upgraded to Aa3 (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A-2, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A-3, Downgraded to Ca (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

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

Issuer: Banc of America Funding 2006-H Trust

  -- Cl. 5-A-1, Confirmed at Caa3 (sf); previously on Jan. 14,
     2010 Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 5-A-2, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 6-A-1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 6-A-2, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Funding 2006--8T2 Trust

  -- Cl. A-1, Downgraded to Caa3 (sf); previously on Jul 8, 2010
     Downgraded to Caa1 (sf) and Remained On Review for Possible
     Downgrade

  -- Cl. A-2, Downgraded to Caa3 (sf); previously on Jul 8, 2010
     Downgraded to Caa1 (sf) and Remained On Review for Possible
     Downgrade

  -- Cl. A-3, Downgraded to Caa3 (sf); previously on Jul 8, 2010
     Downgraded to Caa1 (sf) and Remained On Review for Possible
     Downgrade

  -- Cl. A-4, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-5, Downgraded to C (sf); previously on Jan. 14, 2010 Ca
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-6, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-7, Downgraded to C (sf); previously on Jan. 14, 2010 Ca
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-8, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-9, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-10, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-11, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Funding 2007-1 Trust, Mortgage Pass-
Through Certificates, Series 2007-1

  -- Cl. 1-A-1, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-2, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-3, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-4, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-5, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-6, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-7, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-8, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-9, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-10, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-12, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-13, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. 1-A-15, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-16, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-17, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-18, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-19, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-20, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-21, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-22, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-23, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-24, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-25, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-26, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-27, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-28, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-29, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 30-IO, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 30-PO, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. T-A-1B, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-2, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-3A, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-3B, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-4, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-5, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-6, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-7, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-8, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-9, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-10, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-11, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Funding 2007-4 Trust

  -- Cl. 1-A-1, Downgraded to B1 (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-2, Confirmed at Ca (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-PO, Confirmed at Caa1 (sf); previously on Jan. 14, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-1, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. 2-A-3, Confirmed at B2 (sf); previously on Jan. 14, 2010
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-4, Confirmed at B2 (sf); previously on Jan. 14, 2010
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-5, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-6, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-7, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-8, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-9, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-10, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-11, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-13, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-14, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-15, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A-1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A-2, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A-3, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-IO, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A-1, Downgraded to Caa1 (sf); previously on Dec. 17,
     2009 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A-2, Downgraded to Caa1 (sf); previously on Dec. 17,
     2009 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 5-A-1, Downgraded to Caa1 (sf); previously on Dec. 17,
     2009 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 5-A-2, Downgraded to B3 (sf); previously on Dec. 17, 2009
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 5-A-3, Downgraded to Caa1 (sf); previously on Dec. 17,
     2009 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 6-A-1, Upgraded to Baa1 (sf); previously on Dec. 17, 2009
     Ba2 (sf) Placed Under Review for Possible Downgrade


  -- Cl. 7-A-1, Downgraded to B2 (sf); previously on Dec. 17, 2009
     Ba2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 8-A-1, Confirmed at B3 (sf); previously on Dec. 17, 2009
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. S-IO, Downgraded to B3 (sf); previously on Dec. 17, 2009
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. S-PO, Downgraded to Caa1 (sf); previously on Dec. 17,
     2009 B3 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. T-A-1B, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-2, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-3, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-4, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-5, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-6, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-7, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-P1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-P2, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Funding 2007-A Trust

  -- Cl. 1-A-1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-1, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. 2-A-3, Downgraded to Ba2 (sf); previously on Jan. 14,
     2010 A3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-4, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-5, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Funding 2007-B Trust

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

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

Issuer: Banc of America Funding 2007-D Trust

  -- Cl. 1-A-1, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. 1-A-3, Confirmed at B2 (sf); previously on Jan. 14, 2010
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-4, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-5, Downgraded to Ca (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Funding 2007--2 Trust

  -- Cl. 1-A-1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-2, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-3, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-4, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-5, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-6, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-7, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-8, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-9, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-10, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-11, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-12, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-13, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-14, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-15, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-16, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-17, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-18, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-19, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-20, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-22, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-23, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-24, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-25, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-26, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-27, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-28, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-29, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-30, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-31, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-32, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-33, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-34, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-35, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-36, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-37, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-38, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-39, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-40, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-41, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-42, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-1, Downgraded to B1 (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 30-IO, Downgraded to B1 (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 30-PO, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-1A, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-1B, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-2, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-3, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-4, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-5, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. T-A-6, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Funding 2007--5 Trust

  -- Cl. 1-A-1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-3, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-4, Confirmed at Caa3 (sf); previously on Jan. 14,
     2010 Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A-1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A-2, Confirmed at Caa3 (sf); previously on Jan. 14,
     2010 Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A-1, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A-2, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A-5, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 5-A-1, Downgraded to B2 (sf); previously on Jan. 14, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. 6-A-1, Downgraded to B1 (sf); previously on Jan. 14, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. C-A-4, Confirmed at Caa3 (sf); previously on Jan. 14,
     2010 Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C-A-5, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C-A-11, Confirmed at Caa3 (sf); previously on Jan. 14,
     2010 Caa3 (sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Funding Corporation 2007-6

  -- Cl. A-1, Confirmed at Caa2 (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-2, Downgraded to Caa2 (sf); previously on Jan. 14, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

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


BANC OF AMERICA: S&P Corrects Rating on Class A-2 to 'CC'
---------------------------------------------------------
Standard & Poor's Ratings Services corrected its rating to 'CC
(sf)' from 'AAA (sf)'on class A-2, a super-senior, lockout class
from Banc of America Funding 2006-R1 Trust, a residential
mortgage-backed securities resecuritized real estate mortgage
investment conduit transaction.  On April 1, 2010, S&P incorrectly
affirmed its 'AAA (sf)' rating on class A-2.

In addition, S&P lowered its ratings to 'CC (sf)' from 'CCC (sf)'
on two other senior classes: class A-1, a senior, sequential pay
class, and class A-3, a super-senior support, lockout class.

The downgrades on all three classes follow S&P's analysis of the
transaction using the September 2010 performance data, which
reflect what S&P considers significant deterioration in
performance of the mortgage loans backing the underlying
certificates.  As a result of this performance deterioration, the
amount of credit enhancement S&P expects to be available to the
underlying certificates and consequently to the downgraded classes
is insufficient to cover S&P's current projected losses at the
previous rating levels.

Classes A-1, A-2, and A-3 benefit from a certificate insurance
policy provided by CIFG Assurance North America Inc. (not rated).

The transaction is a resecuritization of 41 senior and subordinate
certificates from eight previously issued prime jumbo transactions
and four Alternative-A transactions.  The underlying transactions
were issued by Bank of America N.A.  and Countrywide Home Loans in
2005 and 2006.  The prime jumbo and Alt-A collateral for these
trusts consists of U.S. residential fixed-rate mortgages secured
by first liens on one- to four-family residential properties.

Over the past two years, S&P has revised its RMBS default and loss
assumptions, and consequently its projected losses, to reflect the
continuing decline in mortgage loan performance and the housing
market.  The performance deterioration of most U.S. RMBS has
continued to outpace the market's expectation.

                         Rating Corrected

              Banc of America Funding 2006-R1 Trust

                                    Rating
                                    ------
       Class  CUSIP       To                       From
       -----  -----       --                       ----
       A-2    05950CAB8   CC (sf)                  AAA (sf)

                          Rating Actions

              Banc of America Funding 2006-R1 Trust

                                       Rating
                                       ------
      Class      CUSIP         To                   From
      -----      -----         --                   ----
      A-1        05950CAA0     CC (sf)              CCC (sf)
      A-3        05950CAC6     CC (sf)              CCC (sf)


BEAR STEARNS: Moody's Cuts Ratings on 15 2001-A Tranches
--------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 15
tranches and confirmed the ratings of four tranches from 11 RMBS
transactions issued by Bear Stearns Home Loan Owner Trust, Bear
Stearns Mortgage Funding Trust, and Bear Stearns Second Lien
Trust.  The collateral backing these deals primarily consists of
closed end second lien loans and home equity lines of credit.

                        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   -- Cl.
A-2 of Bear Stearns Second Lien Trust 2007-SV1/ Group 1 for which
model implied results would be one notch lower (for example, Ba2
versus Ba1, or Ca versus Caa3).

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: Bear Stearns Home Loan Owner Trust 2001-A

  * Expected Losses (as a % of Original Balance): 21%

  -- Cl. M-2, Confirmed at Ba3 (sf); previously on March 18, 2010
     Ba3 (sf) Placed Under Review for Possible Downgrade

Issuer: Bear Stearns Mortgage Funding Trust 2006-SL1

  * Expected Losses (as a % of Original Balance): 67%

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

Issuer: Bear Stearns Mortgage Funding Trust 2006-SL2

  * Expected Losses (as a % of Original Balance): 70%

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

Issuer: Bear Stearns Mortgage Funding Trust 2006-SL3

  * Expected Losses (as a % of Original Balance): 74%

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

Issuer: Bear Stearns Mortgage Funding Trust 2006-SL4

  * Expected Losses (as a % of Original Balance): 77%

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

Issuer: Bear Stearns Mortgage Funding Trust 2006-SL5

  * Expected Losses (as a % of Original Balance): Group 1 81%,
    Group 2 80%

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

  -- Cl. II-A, Downgraded to C (sf); previously on March 18, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

Issuer: Bear Stearns Mortgage Funding Trust 2006-SL6

  * Expected Losses (as a % of Original Balance): Group 1 82%,
    Group 2 83%

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

  -- Cl. II-A, Downgraded to C (sf); previously on March 18, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

Issuer: Bear Stearns Mortgage Funding Trust 2007-SL1

  * Expected Losses (as a % of Original Balance): Group 1 85%,
    Group 2 85%

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

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

Issuer: Bear Stearns Mortgage Funding Trust 2007-SL2

  * Expected Losses (as a % of Original Balance): Group 1 86%,
    Group 2 84%

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

  -- Cl. II-A, Downgraded to C (sf); previously on March 18, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

Issuer: Bear Stearns Second Lien Trust 2007-1

  * Expected Losses (as a % of Original Balance): Group 1 76%,
    Group 2 89%, Group 3 76%

  -- Cl. I-A, Downgraded to C (sf); previously on April 16, 2010
     Downgraded to Ca (sf) and Placed Under Review for Possible
     Downgrade

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

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

  -- Cl. II-A, Downgraded to C (sf); previously on April 16, 2010
     Downgraded to Ca (sf) and Placed Under Review for Possible
     Downgrade

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

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

  -- Cl. III-A, Downgraded to C (sf); previously on April 16, 2010
     Downgraded to Ca (sf) and Placed Under Review for Possible
     Downgrade

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

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

Issuer: Bear Stearns Second Lien Trust 2007-SV1

  * Expected Losses (as a % of Original Balance): 38%

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

  -- Cl. A-2, Confirmed at Caa3 (sf); previously on March 18, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Underlying Rating: Confirmed at Caa3 (sf); previously on
     March 18, 2010 Caa3 (sf) Placed Under Review for Possible
     Downgrade

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

  -- Cl. A-3, Confirmed at Caa2 (sf); previously on March 18, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Underlying Rating: Confirmed at Caa2 (sf); previously on
     March 18, 2010 Caa2 (sf) Placed Under Review for Possible
     Downgrade

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


BEAR STEARNS: Moody's Affirms Ratings on 12 2006-BBA7 Certificates
------------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 12 classes of
Bear Stearns Commecial Mortgage Securities Inc. Commercial
Mortgage Pass-Through Certificates, Series 2006-BBA7:

  -- Cl. A-1, Affirmed at Aaa (sf); previously on July 12, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2, Affirmed at Aa2 (sf); previously on Feb. 24, 2009
     Downgraded to Aa2 (sf)

  -- Cl. X-1B, Affirmed at Aaa (sf); previously on July 12, 2006
     Assigned Aaa (sf)

  -- Cl. X-3, Affirmed at Aaa (sf); previously on July 12, 2006
     Assigned Aaa (sf)

  -- Cl. B, Affirmed at A2 (sf); previously on Sept. 3, 2009
     Downgraded to A2 (sf)

  -- Cl. C, Affirmed at A3 (sf); previously on Sept. 3, 2009
     Downgraded to A3 (sf)

  -- Cl. D, Affirmed at Baa1 (sf); previously on Sept. 3, 2009
     Downgraded to Baa1 (sf)

  -- Cl. E, Affirmed at Baa3 (sf); previously on Sept. 3, 2009
     Downgraded to Baa3 (sf)

  -- Cl. F, Affirmed at Ba1 (sf); previously on Sept. 3, 2009
     Downgraded to Ba1 (sf)

  -- Cl. G, Affirmed at B1 (sf); previously on Sept. 3, 2009
     Downgraded to B1 (sf)

  -- Cl. H, Affirmed at B2 (sf); previously on Sept. 3, 2009
     Downgraded to B2 (sf)

  -- Cl. J, Affirmed at B3 (sf); previously on Sept. 3, 2009
     Downgraded to B3 (sf)

The affirmations were based on key rating parameters, including
Moody's loan to value ratio and debt service coverage ratio,
remaining within an acceptable range.  The determination was based
on Moody's valuation of the hotel properties that serve as
collateral for the two remaining loans in the trust, as well as
Moody's positive industry outlook for the U.S. Lodging and Cruise
Sectors.  Moody's positive industry outlook reflects Moody's
expectation that hotel operating profits will increase 5% to 10%
through the end of 2011 and that demand will outpace supply
growth.

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 Large
Loan Model v 8.0 which is used for both large loan and single
borrower transactions.  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.  The model also incorporates a supplementary tool to
allow for the testing of the credit support at various rating
levels.  The scenario or "blow-up" analysis tests the credit
support for a rating assuming that loans in the pool default with
an average loss severity that is commensurate with the rating
level being tested.

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 3, 2009.

                         Deal Performance

As of the October 15, 2010 payment date, the transaction's
certificate balance has decreased by 18% to $573.9 million from
$700 million at securitization due to scheduled amortization and
the payoff of three loans originally in the pool.  Currently the
mortgage pool consists of two portfolio loans secured by hotel
properties.  Both loans are special serviced loans and both had
final maturity dates of October 12, 2010.

Moody's was provided with year-to-date operating statements for
each of the hotel properties that serve as collateral for the two
portfolio loans in the pool.  Mood's weighted average LTV is 81%
compared to 86% at last review.  Moody's stressed DSCR is 1.34X
compared to 1.35X at last review.  Moody's stressed DSCR is based
on Moody's net cash flow and a 9.25% stressed rate applied to the
loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.
Large loan transactions have a Herf of less than 20.  This pool
has a Herf of 1, the same as at Moody's prior review.

The Columbia Sussex Portfolio Loan ($534.5 million -- 93% of the
pooled balance) is secured by 14 full-service hotel properties
located in ten states, Washington, D.C. and Toronto, Canada with a
total of 5,821 rooms.  The portfolio is branded by six Westin
flags, two Sheraton flags, three Hilton flags, two Marriott flags
and one Wyndham flag.  At securitization, ten of the properties in
the portfolio had Wyndham flags.

The Columbia Sussex Portfolio loan was transferred to special
servicing in June 2010 due to a maturity default.  Negotiations
are on-going between the special servicer and the borrower to
address the default.  The loan collateral was appraised in August
2010 for $809.6 million.

Moody's believes that a recent development in October 2010 has
positive implications for the loan.  Blackstone Group LP
purchased, at a discount, approximately $300 million of the
$495 million outstanding mezzanine debt, putting Blackstone in
position to gain control of the 14 hotel properties.  Blackstone
had sold the hotels to Columbia Sussex for $1.4 billion in 2006.
Moody's LTV is 80%, compared to 85% at last review.

The CPI Hilton Portfolio Loan ($39.4 million -- 7%) is secured by
five limited service hotel properties including four Hilton Garden
Inns and one Homewood Suites.  The properties are located in five
states and have a total of 944 rooms.  Moody's LTV is 95% compared
to 97% at last review.

The CPI Hilton Portfolio Loan was transferred to special servicing
in July 2009.  An appraisal, completed in December 2009, indicates
a value of $58.7 million for the portfolio.  A modification has
been approved to extend the loan to December 2011.  The loan
modification and extension is moving towards a closing.


BERNARD NATIONAL: S&P Withdraws Ratings on Three Classes
--------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on three
classes of notes from Bernard National Loan Investors Ltd. and
Liberty Square CDO I Ltd.

The withdrawals on these two cash flow collateralized loan
obligation transactions follow complete paydowns to the rated
notes.

                        Ratings Withdrawn

               Bernard National Loan Investors Ltd.

                                Rating
                                ------
                    Class     To      From
                    -----     --      ----
                    A-2       NR      BB+ (sf)
                    A-3c      NR      BB+ (sf)

                    Liberty Square CDO I Ltd.

                                Rating
                                ------
                    Class     To      From
                    -----     --      ----
                    A         NR      AAA (sf)

                          NR - Not rated.


CALIFORNIA STATEWIDE: Fitch Cuts Rating on $5,540,000 Bonds to BB
-----------------------------------------------------------------
Fitch Ratings has downgraded to 'BB' from 'BBB-' its rating on
$5,540,000 California Statewide Communities Development Authority
certificates of participation, Sonoma County Indian Health
Project.

Rating Rationale:

  -- The downgrade reflects the non-compliance of the Indian
     Health Services with regard to certain provisions of a
     memorandum of understanding agreement between IHS and SCIHP.
     Specifically, the direct transfer to the bond trustee of a
     portion of IHS grant funds to cover debt service, which was
     called for by the original terms of the debt issuance, is not
     occurring.

  -- While IHS is not compelled to make the direct transfer, the
     described payment mechanism was a principal positive factor
     that mitigated credit concern about SCIHP's extremely small
     revenue base and narrow breadth of services, which limit
     SCIHP's ability to withstand adverse economic conditions.

  -- Both operating profitability and debt service coverage of
     maximum annual debt service declined between 2006 and 2009;
     however, in fiscal year 2010, SCIHP generated a 3.3%
     operating margin and a MADS coverage ratio by EBITDA of 4.2
     times.

  -- Balance sheet ratios are solid with very good liquidity
     ratios.  SCIHP has 337.9 days of cash on hand and a 275.4%
     cash to debt ratio.

  -- SCIHP's utilization trends are positive with limited
     competition in the service area.

The Rating Outlook is Stable.

                        Key Rating Drivers

The continuation of stable operating profitability and balance
sheet strength, which mitigates the credit risk inherent to the
entity's small size and narrow market focus.

                            Security

First lien and security interest in certain property subject to
permitted encumbrances; pledge of gross revenues with a lockbox on
a missed loan payment; fully funded debt service reserve fund.

                          Credit Summary

The downgrade reflects the non-compliance of the IHS with regard
to the flow of funds in the memorandum of understanding agreement
between IHS and SCIHP.  At the time of the initial rating, the key
credit strength was the expectation that the structure of the
transaction would include a "lockbox" mechanism that required IHS
to deposit payments directly to the trustee prior to the release
of operating funds to SCIHP.  As part of the annual surveillance
process, and after several discussions with SCIHP's counsel, Fitch
learned that IHS has not been providing payment directly to the
bond trustee since at least 2002.  Fitch notes, however, that
SCIHP has been making regularly scheduled debt service payments to
the trustee, all bond payments are current, and SCIHP's counsel is
endeavoring to correct the situation.

In 2009, SCIHP lost $105,000 on $16.9 million in total revenues,
producing a negative operating margin of 0.6% and coverage of MADS
of 1.7x.  In 2009, SCIHP executed a three-year engagement with a
new auditing firm after several changes in both auditors and
method of presentation.  In May 2010, SCIHP hired a new CFO with
significant experience in healthcare operations.  Fitch has
reviewed several years of audited financial statements and feels
confident in the quality and content of the most recent financial
statements.

SCIHP's operations have improved significantly in 2010.  At fiscal
year end June 30, SCIHP earned $569,000 from operations on total
revenues of $17.2 million, producing an operating margin of 3.3%
and an operating EBITDA margin of 7.7%.  Investment earnings
totaling $784,000 produced an excess margin of 7.6%.  MADS
coverage by operating EBITDA is good at 2.6x and MADS as a
percentage of revenues is moderate at 2.9%.  SCIHP's balance
sheet ratios are solid.  Also at fiscal year end, SCIHP had
$14.9 million in unrestricted cash and investments versus
$5.5 million in long-term debt.  SCIHP has 337 days of cash on
hand, a 29.7x cushion ratio and a 275.4% cash-to-debt ratio.
Utilization trends are positive.  SCIHP registrations have
increased approximately 5% since 2008.  SCIHP's unique market
niche protects it from direct competition in its service area.

The Stable Rating Outlook reflects Fitch's expectation that the
improved operating profitability evidenced in fiscal year 2010
will be maintained.

SCIHP was established in 1971 to provide health care for the
Native American population of Sonoma County.  As a health clinic,
SCIHP provides medical, dental, and other services in a 36,000
square foot ambulatory care center in Santa Rosa, CA.  SCIHP's
covenants to provide, upon request, annual financial statements
(including management discussion and analysis and utilization
statistics) within 120 days of the end of the fiscal year, and
within 45 days of the end of the fiscal year.


CASTLE HILL: S&P Raises Ratings on Various Classes of Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1a, A-1b, and B notes, and the class A-1a senior secured insured
remarketed certificates from Castle Hill III CLO Ltd., a
collateralized loan obligation transaction managed by Sankaty
Advisors LLC.  At the same time, S&P removed its ratings on the
class A-1a, A-1b, and B notes from CreditWatch with positive
implications.

The upgrades of the A-1a, A-1b, and B notes reflect the improved
performance S&P has observed in the transaction's underlying asset
portfolio since October 2009, at which time S&P lowered its
ratings on the A-1a, A-1b, and B notes following a review of the
transactions under S&P's criteria for rating corporate
collateralized debt obligations published in September 2009.

According to the Sept. 30, 2009 trustee report, the transaction
was holding approximately $27.0 million in defaulted obligations
and $26.0 million in underlying obligors with a rating, either by
Standard & Poor's or another rating agency, of 'CCC+' or lower.
As of Sept. 30, 2010, the transaction was holding $6.2 in
defaulted obligations and $7.4 million in underlying obligors with
ratings of 'CCC+' or lower.  To date, the Castle Hill III CLO Ltd.
transaction has paid down the class A-1a and A-1b notes to
approximately 48.5% of their original outstanding balances,
including $81.2 million over the past year.  The reductions in the
defaulted and 'CCC+' or lower rated assets and the $81.2 million
paydown on the class A-1a and A-1b notes has reduced the overall
credit risk for the remaining outstanding notes.

The rating on the A-1a senior secured insured remarketed
certificates reflects the rating on the underlying securities, the
Castle Hill III CLO Ltd.'s class A-1a notes.  These certificates
are insured by Assured Guaranty Municipal Corp. ('AA+/Stable').

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

                     Castle Hill III CLO Ltd.

                                  Rating
                                  ------
     Class                   To           From
     -----                   --           ----
     A-1                     AAA (sf)     AA+ (sf)/Watch Pos
     A-2                     AAA (sf)     AA+ (sf)/Watch Pos
     B                       A- (sf)      BB+ (sf)/Watch Pos
     Rmkd certs              AAA (sf)     AA+ (sf)


CELERITY CLO: S&P Raises Ratings on Two Classes of Notes
--------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
C and class D notes issued by Celerity CLO Ltd., a collateralized
loan obligation transaction managed by TCW Asset Management Co.
and removed its rating on the class C notes from CreditWatch with
positive implications.  At the same time, S&P affirmed its ratings
on the class A funded notes, class B notes, and class E notes.
S&P also withdrew its rating on the class A revolving notes
following a termination of the commitment to fund for those notes.

The upgrades reflect the improved performance S&P has observed in
the deal since December 2009, when S&P lowered the rating on the
class C, D, and E notes following a review of the transaction
under its updated criteria for rating corporate collateralized
debt obligations that S&P published in September 2009.  The
affirmations reflect the availability of the credit support at the
current rating levels.

At the time of S&P's last rating action, according to the
trustee report dated Oct. 9, 2009, the transaction was holding
approximately $14 million in defaulted obligations and more
than $32 million in underlying obligors with a rating, either
by Standard & Poor's or another rating agency, in the 'CCC'
range.  Since that time, a number of defaulted obligors held
in the deal emerged from the bankruptcy process, with some
receiving proceeds that were higher than their carrying value in
the overcollateralization ratio test calculations.  In combination
with a reduction in the 'CCC' range assets and a $51 million
paydown on the class A funded notes, this benefited all O/C ratio
tests in the transaction.  For example, the senior O/C test
increased to 164.13% by Oct. 8, 2010, from 137.3% as of Oct. 9,
2009.  To date, the transaction has paid down the class A funded
notes to approximately 44% of their original outstanding balance.

According to information S&P has received from the deal's trustee
and collateral manager, the purchaser of the class A revolving
notes defaulted on their obligation to fund the class A revolving
notes at the termination of the reinvestment period for the
transaction.  This resulted in a net zero balance on the class A
revolving notes.  Since the class A revolving notes no longer have
the ability to fund, S&P is withdrawing the rating on this note.

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

                        Celerity CLO Ltd.

    Class                   To           From
    -----                   --           ----
    Class A revolving notes NR           AAA (sf)
    Class C notes           AA+ (sf)     BBB+ (sf)/Watch Pos
    Class D notes           BB+ (sf)     CCC- (sf)

                        Ratings Affirmed

                        Celerity CLO Ltd.
                Class                   Rating
                -----                   ------
                Class A funded notes    AAA (sf)
                Class B notes           AAA (sf)
                Class E notes           CCC- (sf)


CITY OF ANDERSON: Fitch Cuts Rating on Bonds to 'BB+'
-----------------------------------------------------
Fitch Ratings has downgraded the rating on these City of Anderson,
Indiana Economic Development Revenue Refunding and Improvement
bonds issued on behalf of Anderson University to 'BB+' from
'BBB-':

  -- $45.1 million city of Anderson, Indiana economic development
     revenue refunding and improvement bonds (Anderson University
     project).

The Rating Outlook is revised to Negative from Stable.

Rating Rationale:

  -- The downgrade to below investment grade reflects AU's
     significantly weakened financial profile as the operating
     margin and available funds have declined considerably in
     recent years.

  -- Due to strong reliance on student-generated revenues, AU's
     multi-year negative enrollment trend has significantly
     pressured fiscal operations.

  -- While the university's senior leadership and the board
     recognize the urgency of the situation and are taking steps
     to try and stabilize performance, an immediate turnaround is
     unlikely.

What Could Trigger A Downgrade:

  -- Further deterioration in financial metrics, driven primarily
     by a failure to stem enrollment losses;

  -- Additional debt issuance, of which none is anticipated,
     without a significant increase in financial resources
     available for repayment.

Security:

The bonds are an unsecured general obligation of the university.
Unlike similarly-rated institutions, the security package does not
include a mortgaged facility.  However, bond proceeds were used
for a debt service fund ($3.6 million at issuance) which remains
fully funded.

Credit Summary:

AU's credit profile deteriorated over the past two years as
operating performance trended negative and available funds
weakened considerably.  Historically AU maintained a positive
operating margin which provided an important measure of financial
flexibility.  However, in fiscal 2009 the university generated a
slight negative 0.4% operating deficit (inclusive of affiliate
operations reported in the university's audited financial
statements) and was virtually breakeven at 0.1% in 2010.  Without
a consistent surplus, AU is dependent on a thin available funds
cushion (cash and investments that are not permanently restricted)
that weakened during recent market declines and has yet to fully
recover.  In fiscal 2009, available funds of $5.6 million (driven
downwards largely through market declines) provided very low
coverage of operating expenses and total debt of 11.1% (37.3% in
2008) and 10.4% (33% in 2008), respectively.  While the liquidity
cushion grew nearly 10% in 2010, coverage of operating expenses
and debt was still very limited (16.5% and 15.4%, respectively).

Multiple years of enrollment declines, primarily in undergraduates
and more recently in graduate students, have pressured AU's fiscal
operations which are heavily dependent on student-generated
sources.  In fall 2010, headcount of 2,565 (2,022 undergraduates)
was down 4.7% from fall 2009 (2,691, with 2,137 undergraduates),
and down 6.1% from five years ago (2,733, with 2,201
undergraduates).  Student-generated revenues (net tuition and
fees, and auxiliary revenues) accounted for the vast majority of
AU's revenue base, providing 79.5% of fiscal 2010 operating
revenues.  Net tuition and fees declined 2.4% in 2010 reflecting
both headcount declines and increased tuition discounting (a high
38.1%).  Management reports that affordability is a chief concern
for students, applicants, and their families.  For the current
school year, annual tuition increased 4.5% to $23,490, while room
and board increased 4.6% to $8,350.  AU's major competitors
(according to data provided by management) are a mix of public and
private institutions which are all priced lower.

The university's leadership team, at both the management and board
level, appear to recognize that AU is at a critical juncture in
terms of long-term financial health.  After falling short of the
fall 2010 enrollment target, the university initiated a 100-day
'turnaround' plan to engage the entire campus in an effort to cut
$600,000 from the current budget to restore balanced operations.
Management reports that AU's board of trustees recently met and
acknowledged the urgency of the situation and advocated rapid
exploration of corrective actions.  Given the price sensitivity of
AU's marketplace and decreased availability of scholarship funding
for state residents because of state budget cuts, a material
turnaround in the short term is unlikely.

Fitch will closely monitor AU's efforts to address its fiscal and
operating issues.  Continuation of current trends of weakening
financial performance and/or declining enrollment would likely
trigger further negative rating action.  Should enrollment fail to
rebound to historical levels, the university will likely have to
make significant adjustments in its expense structure to match a
smaller revenue base and stabilize operations.  The ongoing
budgetary impact of future capital projects including a new
recital hall (donations are in hand, and construction is planned
for next spring) and a new university center (currently under
preliminary consideration, with construction to be funded with
donations), will have to be carefully reviewed.  While no bonds
are planned for these or other projects, Fitch notes that AU does
borrow on a limited scale through bank lines of credit, and
secured and unsecured notes payable.  Given the current financial
pressures, any substantial long-term debt would likely have
negative rating implications.

AU is a Christian university located in the city of Anderson,
Indiana.  The university was founded by the Church of God in 1917
and is the only COG-affiliated school in the Midwest.  COG members
comprise approximately one-third of undergraduate enrollment.  The
university encompasses 166 acres, and is approximately 35 miles
northeast of Indianapolis.


CITY OF GILMER: Moody's Upgrades Rating on Bonds From 'Ba1'
-----------------------------------------------------------
Moody's Investors Service has upgraded the City of Gilmer's
general obligation rating to Baa3 from Ba1.  The rating upgrade
affects $6.6 million in outstanding general obligation limited tax
debt.

                         Rating Rationale

The rating action reflects the city's improved, but still limited
financial position and Moody's expectation that the general fund
balance which has been historically supported by water and sewer
fund transfers will remain positive and in line with other
similarly rated investment grade credits.  The Baa3 rating also
reflects the stable but small tax base and an elevated debt
burden.

Negative Fund Balance Is Corrected; General Fund Continues To Be
              Supported By Water And Sewer Revenues

The city's general fund has historically relied on a transfer from
the water and sewer fund to cover operating expenses.  (The city's
water and sewer revenue debt is rated Baa1 and has recently been
affirmed by Moody's).  Historically, the general fund balance has
been negative as a result of a $1.3 million liability to the water
and sewer fund.  Negative fund balances ranged from a negative
$842,000 in fiscal 2002 to a low of $1.1 million in fiscal 2004.
The liability was a result of an inter-fund loan that the general
fund did not have the liquid resources to repay.  In fiscal 2008
the city removed the liability from the general fund and the
corresponding receivable in the water and sewer fund, resulting in
a positive fund balance for the first time since fiscal 2002.
Although the fund balance has been restored to a positive 8,8% of
revenues at FYE 2009, the city's cash position of $276,000
supports less than one month of general fund operations.
Additionally, the general fund continues to rely on transfers from
the water and sewer fund to support general city operations.  From
fiscal 2005 through 2009, transfers from the water and sewer fund
to the general fund have averaged a significant 18% of general
fund revenues.  City officials report the transfer is done to meet
the needs of the general fund and is not based on a payment-in-
lieu of taxes calculation or internal services cost allocation.
Absent a clearly defined transfer policy, Moody's views the
general fund's reliance on the transfer to be a structural
imbalance in the general fund and notes the city's budgetary
practices are not consistent with prudent financial management.
However, given the recent accounting adjustment, Moody's expects
the fund balance to remain in a positive but limited position in
the near-term.

                 Stable But Limited Local Economy

Gilmer is located in East Texas and is the county seat of Upshur
County and has an estimated population of 5,249.  The rural
economy is based largely on agriculture and a limited amount of
industrial activity.  The tax base has expanded at a five year
average annual pace of 7.1% reaching $263 million in fiscal 2011.
Unemployment in Upshur County of 7.8% (as of August 2010) is
favorably below both the state and nation of 8.4% and 9.5%
respectively.  Per capita income is average at 77.9% of the US.
Moody's expects the tax base to remain stable but limited.

                       Elevated Debt Burden

Both the direct debt burden of 4.5% and the overall debt burden of
6.9% (as a percentage of fiscal 2011 ad valorem values) are
elevated.  The direct debt burden consists of $6 million of debt
issued for water and sewer projects with the remaining $675,000
issued for general government purposes.  The debt burden is not
adjusted for the water and sewer debt as the city's debt service
tax rate supports the debt service payment for the certificates of
obligation.  Amortization is below average with 42.9% retired in
ten years.  The city does not have current plans to issue
additional debt.  Given the slow payout and lack of self-support
for the majority of the city's debt, Moody's expects the debt
burden to remain elevated.

Key Statistics

* Estimated 2008 Population: 5,249
* Per Capita Income: $16,823 (86% of state and 77.9% of US)
* 2011 Full Value: $263 million
* 2011 Full Value per Capita: $50,209
* Direct Debt Burden: 4.5%
* Overall Debt Burden: 6.9%
* Payout in Ten Years: 42.9%
* Fiscal 2009 General Fund Balance: $276,000 (8.8%)
* General Obligation Debt Outstanding: $6.6 million

                 What Could Change The Rating - Up

  -- Self support of general fund that indicates sound financial
     management practices

  -- Trend of improved financial flexibility in general fund

               What Could Change The Rating - Down

  -- Return to negative fund balance

  -- Trend of deficit spending in general fund that results in
     narrowing of cash position


CNL FUNDING: Moody's Reviews Ratings on Four Classes of Certs.
--------------------------------------------------------------
Moody's Investors Service has placed on review for possible
downgrade four classes of certificates issued by CNL Funding 98-1,
LP, and six classes of certificates issued by CNL Funding 99-1,
LP.  The certificates are backed by franchise loans made to fast-
food and casual dining restaurants.

The review actions are prompted by deteriorating performance of
the collateral properties, and potentially insufficient levels of
credit enhancement available for the certificates against future
losses relative to current ratings.

The complete rating action is:

Issuer: CNL Funding 99-1, LP

  -- Class A-2, Aa2 (sf) Placed Under Review for Possible
     Downgrade; previously on June 30, 2009 Downgraded to Aa2 (sf)

  -- Class IO, Aa2 (sf) Placed Under Review for Possible
     Downgrade; previously on June 30, 2009 Downgraded to Aa2 (sf)

  -- Class B, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on June 30, 2009 Downgraded to A2 (sf)

  -- Class C, Baa1 (sf) Placed Under Review for Possible
     Downgrade; previously on June 30, 2009 Downgraded to Baa1
     (sf)

  -- Class D, Baa3 (sf) Placed Under Review for Possible
     Downgrade; previously on June 30, 2009 Downgraded to Baa3
     (sf)

  -- Class E, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on June 30, 2009 Downgraded to B1 (sf)

Issuer: CNL Funding 98-1, LP

  -- Class E-1, B3 (sf) Placed Under Review for Possible
     Downgrade; previously on Dec. 12, 2008 Downgraded to B3 (sf)

  -- Class E-2, B2 (sf) Placed Under Review for Possible
     Downgrade; previously on Dec. 12, 2008 Downgraded to B2 (sf)

  -- Class D-1, Ba2 (sf) Placed Under Review for Possible
     Downgrade; previously on Dec. 12, 2008 Downgraded to Ba2 (sf)

  -- Class D-2, Ba1 (sf) Placed Under Review for Possible
     Downgrade; previously on Dec. 12, 2008 Downgraded to Ba1 (sf)

Considerations for the rating actions:

In CNL Funding 98-1, LP, the fixed (D-1 and E-1) and floating rate
(D-2 and E-2) certificates are backed by fixed and floating rate
loans, respectively.  The fixed and floating rate pools are cross
supported with losses allocated to both subpools in reverse
alphabetical order.  This deal currently has 3 loans in special
servicing which represent 16.4% of the underlying collateral.  The
loans are either being restructured or the associated properties
are being marketed for sale.  In addition, the deal has concept
concentration risks with Burger King (17% of outstanding loan
pool), Taco Bell (32%), and Wendy's (11%).

In CNL Funding 99-1, LP, the credit support for the certificates
consists of subordination and overcollateralization of the bonds
by the loans.  Class B through Class H certificates are
subordinated to Class IO and Class A certificates, providing a
total credit support of 47.2% to Class A certificates as of
October 18, 2010.  The subordinated certificates provide credit
support of 34.3% to Class B certificates; 26.7% to Class C
certificates; 22.8% to Class D certificates; 15.1% to Class E;
11.3%.  There is no overcollateralization at this time.
Significant concept concentration risks in this transaction are
Wendy's (29% of outstanding pool), KFC (14%), and Taco Bell (11%).

During the review period, Moody's will estimate the recovery rates
of foreclosed properties and assess any future stresses on the
rest of the collateral pool.  Moody's will also qualitatively
assess the business challenges currently faced by the restaurant
industry.

In order to estimate losses on the collateral pool, Moody's
calculates the expected loss given default of the obligors that
have become nonperforming, and also estimates future losses on
performing portion of the pool, all as a percentage of the
outstanding pool.  In evaluating the nonperforming loans, key
factors include collateral valuations and expected recovery rates,
volatility around those recovery rates, historical obligor
performance, time until recovery or liquidation on defaulted
obligors, concessions due to restructuring which may negatively
impact the overall cash flow of the trust and/or the collateral,
and future industry expectations.  Net losses are then evaluated
against the available credit enhancement provided by
overcollateralization, subordination, and excess spread.
Sufficiency of coverage is considered in light of remaining
borrower concentrations and concepts, remaining bond maturities,
and economic outlook.


COMM 2004-LNB3: S&P Downgrades Ratings on 10 Classes of Securities
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 10
classes of commercial mortgage-backed securities from COMM 2004-
LNB3.  Concurrently, S&P affirmed its ratings on nine other
classes from the same transaction.

The downgrades reflect S&P's analysis of the remaining collateral
in the pool, the deal structure, and interest shortfalls that have
affected the trust.  The downgrades also reflect several classes'
increased susceptibility to future interest shortfalls and credit
support erosion S&P anticipates will occur upon the resolution of
four of the five specially serviced loans.  As of the October 2010
remittance report, the trust experienced monthly interest
shortfalls totaling $179,945.  The shortfalls were primarily
related to appraisal subordinate entitlement reduction amounts
($164,768) associated with two of the specially serviced loans as
well as special servicing fees ($15,177).  S&P lowered its ratings
on classes K, L, M, and N to 'D (sf)' due to recurring interest
shortfalls that S&P expects will continue.

The affirmations of the ratings on the principal and interest
certificates, of the other nine classes reflect subordination
levels and available liquidity that is consistent with the
outstanding ratings.  The rating on class O was previously lowered
to D '(sf)' due to interest shortfalls.  As of the October
remittance report, the security list was 91.9% of its original
principal balance.   S&P affirmed its rating on the class X
interest-only certificates based on S&P's current criteria.

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
2.01x and a loan-to-value ratio of 75.15%.  S&P further stressed
the loans' cash flows under S&P's 'AAA' scenario to yield a
weighted average DSC of 1.92x and an LTV ratio of 93.88%.  The
implied defaults and loss severity under the 'AAA' scenario were
35.14% and 23.5%, respectively.  The DSC and LTV calculations S&P
noted above exclude all four ($59 million; 5.3%) of the specially
serviced loans and nine defeased loans ($248.3 million; 22.4%).
S&P separately estimated losses for these four specially serviced
loans, which S&P included in its 'AAA' scenario implied default
and loss severity figures.

                      Credit Considerations

As of the Oct. 12, 2010, remittance report, five loans
($64.6 million; 5.8%) in the pool were with the special servicer,
CW Capital Asset Management LLC.  The reported payment status of
the special serviced loans include one 60-plus-days delinquent
($35.2 million; 3.17%) loan, three crossed collateralized and
cross defaulted loans reported as matured balloons ($23.7 million;
2.1%), and one 30-plus-days delinquent ($5.6 million, .5%) loan.
Two of specially serviced loans have appraisal reduction amounts
in effect totaling $16.2 million.

The Beau Terre Office loan ($35.2 million; 3.17%), is secured by
36 office buildings totaling 378,000 sq.-ft. in Bentonville, Ark.,
built in 1984.  The loan was transferred to the special servicer
on May 24, 2010, due to an imminent payment default and is now
reported as 60-plus-days delinquent.  The reported DSC was 1.21x
for year-end 2009, while the reported occupancy was 63% as of
April 1, 2010.  An ARA of $14.6 million is in effect on the loan.
Standard & Poor's expects a moderate loss upon the eventual
resolution of this asset.

The three crossed collateralized and cross defaulted Beyman loans
($23.7 million; 2.1%) are secured by three multifamily properties
with 538 aggregate units in Florida.  The loans were transferred
to the special servicer on June 15, 2009, due to monetary default
and are now reported as matured balloons.  The weighted average
reported DSC was 0.83x for the six months ending June 30, 2009,
while the weighted average reported occupancy was 88% as of June
2009.  Standard & Poor's expects a moderate loss upon the eventual
resolution of this asset.

A modification of the remaining specially serviced loan
($5.6 million, 0.5%) is being negotiated by the special servicer.

Excluding the transaction's defeased and specially serviced loans,
2 loans ($109.1 million, 9.57%) have anticipated repayment dates
or final maturity dates through year-end 2011.  Standard & Poor's
considered this moderate volume of loans with near-term ARDs and
or maturities, in its rating actions.

                      Transaction Summary

As of the Oct. 10, 2010, remittance report, the transaction had an
aggregate trust balance of $1.1 billion (87 loans), compared with
a $1.3 billion trust balance (94 loans) at issuance.  Midland
Commercial Mortgage Servicing, the master servicer, provided
financial information for 95.5% of the nondefeased loans.  All of
the servicer-provided financial information was either full-year
2008, partial-year 2009, or full-year 2009 data.  S&P calculated a
weighted average DSC of 2.01x for the nondefeased loans in the
pool based on the reported figures.  S&P's adjusted DSC was 1.92x
and its adjusted LTV was 75.15%, and both exclude four of the five
specially serviced loans ($59 million; 5.3%) and nine defeased
loans ($248.3 million; 22.4%).  S&P separately estimated losses
for the four of the five specially serviced loans.  Seventeen
loans are on the master servicer's watchlist ($118.6 million;
10.7%).  Five loans ($30.1 million, 2.7%) have a reported DSC
between 1.0x and 1.1x, and eight loans ($72.2 million, 6.5%) have
a reported DSC of less than 1.0x.  The trust has experienced three
principal losses to date totaling $17.1 million.

                     Summary of Top 10 Loans

The top 10 loans secured by real estate have an aggregate
outstanding trust balance of $576 million (51.8%).  Using
servicer-reported information, S&P calculated a weighted average
DSC of 2.31x.  S&P's adjusted DSC and LTV figures for the top 10
loans were 2.16x and 71.16%, respectively.  These figures exclude
the Beau Terre Office loan ($35.3 million; 3.2%), which is with
the special servicer and discussed above.  One of the top 10 loans
appears on the master servicer's watchlist and is discussed below.

The Alexan Mira Vista loan aka Regency Park Apartments,
($32.9 million; 3.0%) is the 10th-largest loan in the pool and is
secured by a 528 unit multifamily property in Austin, Texas, that
was built in 2003.  This loan appears on the master servicer's
watchlist due to a DSC.  The reported DSC was 0.95x for year-end
2009, while the reported occupancy was 89% as of June 2010.
Occupancy has since improved to 91% resulting in an estimated DSC
of 1.07x.

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

                         Ratings Lowered

                          COMM 2004-LNB3
          Commercial mortgage pass-through certificates

                     Rating
                     ------
         Class  To         From     Credit enhancement (%)
         -----  --         ----     ----------------------
         D      BBB+ (sf)  A+ (sf)                    9.13
         E      BB+ (sf)   A- (sf)                    6.87
         F      BB- (sf)   BBB+ (sf)                  5.52
         G      B- (sf)    BBB (sf)                   4.32
         H      CCC (sf)   BBB- (sf)                  3.27
         J      CCC- (sf)  BB+ (sf)                   2.22
         K      D (sf)     BB (sf)                    1.62
         L      D (sf)     BB- (sf)                   1.32
         M      D (sf)     B+ (sf)                    0.87
         N      D (sf)     B (sf)                     0.41

                        Ratings Affirmed

                         COMM 2004-LNB3
          Commercial mortgage pass-through certificates

            Class     Rating   Credit enhancement (%)
            -----     ------   ----------------------
            A-2       AAA (sf)                  16.79
            A-3       AAA (sf)                  16.79
            A-4       AAA (sf)                  16.79
            A-5       AAA (sf)                  16.79
            A-1 A     AAA (sf)                  16.79
            B         AA+ (sf)                  13.19
            C         AA (sf)                   11.68
            O         D (sf)                      N/A
            X         AAA (sf)                    N/A

                       N/A - Not applicable.


CORSAIR NO 4: Moody's Upgrades Ratings on Notes to 'Ba3'
--------------------------------------------------------
Moody's Investors Service announced this rating action on Corsair
(Jersey) No. 4 Limited, a collateralized debt obligation
transaction.

The CSO, closed in 2004, referenced a portfolio of synthetic
corporate senior unsecured bonds.

Issuer: Corsair (Jersey) No. 4 Limited

  -- US$15M US$$15,000,000 Deferrable Fixed Rate Secured Portfolio
     Credit-Linked Notes due 2014 Notes, Upgraded to Ba3 (sf);
     previously on Oct. 16, 2009 Downgraded to B1 (sf)

                         Ratings Rationale

Moody's explained that the rating action taken is the result of
the relative stability of the credit quality of the reference
portfolio, the shortened time to maturity of the CSO and a
substantial level of credit enhancement remaining.

The 10-year weighted average rating factor of the portfolio is
1099, equivalent to Ba2 (excluding settled credit events) compared
to a 1177 WARF, equivalent to a Ba2 rating, as of the last rating
action.  The remaining subordination protecting the rated tranche
from portfolio losses amounts to 7.5% of the portfolio notional.
The portfolio concentration in referenced entities rated Caa1 and
below has slightly improved from 8.3% to 7.5%, and the
concentration in B rated entities has deteriorated from 4.1% to
7.5%.  There are 21 entities with a negative outlook compared to
six with positive outlook, and four entities on watch for
downgrade compared to one on watch for upgrade.

The portfolio has experienced 5 credit events, equivalent to 1.0%
loss of the initial subordination.  Since the last rating action,
CIT Group Inc. has been subject to a credit event.  In addition,
the portfolio is exposed to Clear Channel Communication and
Harrah's Operating Company, which are not credit events, but are
modelled at Ca.  The maturity of the note is 3.9 years.

Moody's rating action factors in the modeling result of a number
of sensitivity analyses and stress scenarios:

* Time to maturity -- The committee has reviewed the impact of a
  scenario consisting of reducing the maturity by one year,
  keeping all other things equal.  Reducing the maturity of the
  transaction generated a result that is one notch worse than the
  model's result generated under the base case.

* MIRs -- Moody's rating action first took 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 one notch better
  than under the base case.

* Potential defaults -- A sensitivity analysis consisting of
  defaulting all entities rated Caa1 and below was done.  This run
  generated an expected loss that is three notches below the one
  modeled under the base case.

* Removing the notch down on all reference entities on negative
  outlook -- This run generated an expected loss that is one notch
  above the one modeled under 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 rating will likely be downgraded to an extent depending on the
expected severity of the worsening conditions.

                     Regulatory Disclosures

Information sources used to prepare the credit rating are these:
parties involved in the rating and parties not involved in the
rating.

Moody's Investors Service considers the quality of information
available on the issuer or obligation satisfactory for the
purposes of maintaining a credit rating.

Moody's adopts all necessary measures so that the information it
uses in assigning a credit rating is of sufficient quality and
from sources Moody's considers to be reliable including, when
appropriate, independent third-party sources.  However, Moody's is
not an auditor and cannot in every instance independently verify
or validate information received in the rating process.


CREDIT SUISSE: Fitch Downgrades Ratings on 15 2005-C5 Certs.
------------------------------------------------------------
Fitch Ratings downgrades 15 classes of Credit Suisse First Boston
Mortgage Securities http://www.facebook.com/notifications.phpCorp.
2005-C5, commercial mortgage pass-through certificates, due to
further deterioration of performance primarily due to increased
losses on the specially serviced loans.

As a result of the expected losses on loans currently in special
servicing, Fitch expects classes O thru Q to be fully depleted and
class N to be significantly impacted.  Fitch expects losses of
4.6% (4.7% cumulative transaction losses) based on expected losses
on the specially serviced loans and loans that could not refinance
at maturity.  As of the October 2010 distribution date, the pool's
aggregate principal balance has decreased 5.3% to $2.8 billion
from $2.9 billion at issuance.  Nine loans (3.5%) are currently
defeased.  As of October 2010, there are cumulative interest
shortfalls in the amount of $1.1 million, currently affecting
classes Q and S.

Fitch has designated 74 loans (21.4%) as Fitch Loans of Concern,
which includes 23 specially serviced loans (6.5%).  The largest
specially serviced loan (1.6%) is secured by a 258,345 square foot
office property located in Wayne, PA, approximately 20 miles
northwest of Philadelphia.  The loan transferred to special
servicing in June 2010 due to imminent maturity default.  The loan
matured on Sept. 1, 2010.  As of June 30, 2010, the property is
99% leased (85% dark) as a result of two of the largest tenants at
the property vacating.

The next largest specially serviced loan (0.7%) is secured by a
576 unit multifamily property located in Comstock Park, MI.  The
loan transferred to special servicing in September 2010 due to
imminent monetary default as a result of insufficient property
cash flow.  The borrower is unable to continue to fund the monthly
property shortfalls and requested a loan modification.  The
special servicer is pursuing a dual track of foreclosure and
workout strategy.

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 debt service coverage ratio of 1.25 times or
higher were considered to pay off at maturity.  Of the non-
defeased or non-specially serviced loans, 148 loans (58.2% of the
overall pool) were assumed not to be able to refinance, of which
Fitch modeled losses for 50 loans (18.3%) in instances where
Fitch's derived value was less than the outstanding balance.

Fitch has downgraded these classes, Revised Outlooks, and assigned
Recovery Ratings as indicated:

  -- $224.8 million class A-J to 'AA/LS3' from 'AAA/LS3'; Outlook
     Stable;

  -- $24.9 million class B to 'A/LS5' from 'AA/LS5'; Outlook
     Stable.

  -- $47.6 million class C to 'BBB/LS5' from 'A/LS4'; Outlook
     Stable;

  -- $21.8 million class D to 'BBB/LS5' from 'A/LS5'; Outlook
     Stable;

  -- $18.1 million class E to 'BBB-/LS5' from 'A/LS5'; Outlook to
     Stable from Negative;

  -- $29 million class F to 'BB/LS5' from 'BBB/LS5'; Outlook to
     Stable from Negative;

  -- $36.3 million class G to 'BB/LS5' from 'BBB-/LS5'; Outlook
     Negative;

  -- $21.8 million class H to 'B/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $32.6 million class J to 'B-/LS5' from 'BB/LS5'; Outlook
     Negative;

  -- $32.6 million class K to 'B-/LS5' from 'B/LS5'; Outlook
     Negative;

  -- $14.5 million class M to 'CCC/RR1' from 'B-/LS5';

  -- $10.9 million class N to 'C/RR6' from 'B-/LS5';

  -- $3.6 million class O to 'C/RR6' from 'B-/LS5';

  -- $7.3 million class P to'C/RR6' from 'B-/LS5';

  -- $10.9 million class Q to 'C/RR6' from 'CCC/RR3'.

In addition, Fitch has affirmed and Revised Rating Outlooks as
indicated:

  -- $486.8 million class A-1A at 'AAA/LS1'; Outlook Stable;

  -- $95 million class A-2 at 'AAA/LS1'; Outlook Stable;

  -- $149 million class A-3 at 'AAA/LS1'; Outlook Stable;

  -- $1 billion class A-4 at 'AAA/LS1'; Outlook Stable;

  -- $136.2 million class A-AB at 'AAA/LS1'; Outlook Stable;

  -- $290.2 million class A-M at 'AAA/LS3'; Outlook Stable;

  -- $7.3 million class L at 'B-/LS5'; Outlook Negative;

  -- $5.4 million class 375-A at 'BBB+'; Outlook to Stable from
     Negative;

  -- $9.4 million class 375-B at 'BBB'; Outlook to Stable from
     Negative;

  -- $20.6 million class 375-C at 'BBB-'; Outlook to Stable from
     Negative.

Fitch does not rate the $24 million class S.  Class A-1 has been
paid in full.  Fitch withdraws the ratings on the interest-only
classes A-X, A-SP, and A-Y.


CREDIT SUISSE: Moody's Downgrades Ratings on Five 2001-CK1 Certs.
-----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five classes
and affirmed 11 classes of Credit Suisse First Boston Mortgage
Securities Corp., Commercial Mortgage Pass-Through Certificates,
Series 2001-CK1:

  -- Cl. A-3, Affirmed at Aaa (sf); previously on March 16, 2001
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-X, Affirmed at Aaa (sf); previously on March 16, 2001
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-Y, Affirmed at Aaa (sf); previously on March 16, 2001
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-CP, Affirmed at Aaa (sf); previously on March 16, 2001
     Assigned Aaa (sf)

  -- Cl. B, Affirmed at Aaa (sf); previously on May 19, 2005
     Upgraded to Aaa (sf)

  -- Cl. C, Affirmed at Aaa (sf); previously on Jan. 16, 2008
     Upgraded to Aaa (sf)

  -- Cl. D, Affirmed at Aaa (sf); previously on Jan. 16, 2008
     Upgraded to Aaa (sf)

  -- Cl. E, Affirmed at Aaa (sf); previously on Jan. 16, 2008
     Upgraded to Aaa (sf)

  -- Cl. F, Affirmed at Aa2 (sf); previously on Jan. 16, 2008
     Upgraded to Aa2 (sf)

  -- Cl. G, Affirmed at A2 (sf); previously on Jan. 16, 2008
     Upgraded to A2 (sf)

  -- Cl. H, Affirmed at Baa2 (sf); previously on Jan. 16, 2008
     Upgraded to Baa2 (sf)

  -- Cl. J, Downgraded to Ca (sf); previously on March 16, 2001
     Definitive Rating Assigned Ba2 (sf)

  -- Cl. K, Downgraded to C (sf); previously on March 16, 2001
     Definitive Rating Assigned Ba3 (sf)

  -- Cl. L, Downgraded to C (sf); previously on May 19, 2005
     Downgraded to B2 (sf)

  -- Cl. M, Downgraded to C (sf); previously on Nov. 2, 2006
     Downgraded to Caa2 (sf)

  -- Cl. N, Downgraded to C (sf); previously on Nov. 2, 2006
     Downgraded to Caa3 (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.  Twenty-eight loans, representing 70% of the pool,
mature within the next 24 months.  Ten of these loans,
representing 25% 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
12.9% of the current balance.  At last review, Moody's cumulative
base expected loss was 1.8%.  Moody's stressed scenario loss is
15% 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 4 compared to 27 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 16, 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 six months.

                         Deal Performance

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 73% to
$270.8 million from $997 million at securitization.  The
Certificates are collateralized by 41 mortgage loans ranging in
size from less than 1% to 26% of the pool, with the top ten loans
representing 51% of the pool.  Eleven loans, representing 29% of
the pool, have defeased and are collateralized with U.S.
Government securities.  There are no loans with investment grade
credit estimates.

Twenty one loans, representing 51% 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.

Fourteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $23.0 million (41% loss severity).
Eight loans, representing 20% of the pool, are currently in
special servicing.  The largest specially serviced loan is the
College Park Medical Office Building Portfolio ($17.9 million --
6.6% of the pool) which are two loans secured by a office building
and retail center, both located in Detroit, Michigan.  The loans
were transferred to special servicing on March 18, 2008 due to
imminent default and are real estate owned.

The second largest specially serviced loan is the Reflections
Apartments Loan ($11.4 million -- 4.2% of the pool), which is
secured by 282 unit multifamily property located in Fort Meyers,
Florida.  The loan was transferred to special servicing on
December 11, 2008 due to monetary default.  A modification
agreement has been recently executed and the loan is expected to
be returned to the master servicer shortly.

The remaining specially serviced loans are secured by a mix of
property types.  The master servicer has recognized appraisal
reductions totaling $7.8 million for two of the specially serviced
loans.  Moody's has estimated an aggregate $24.9 million loss (47%
expected loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for nine poorly
performing loans representing 14% of the pool and has estimated a
$7.9 million loss (22% expected loss based on a 52% probability
default) from these troubled loans.

Based on the most recent remittance statement, Classes K through M
have experienced cumulative interest shortfalls totaling $447,592.
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
100% of the conduit pool.  Excluding specially serviced and
troubled loans, Moody's weighted average LTV is 55% compared to
81% at Moody's prior review.  Moody's net cash flow reflects a
weighted average haircut of 16% 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 1.91X and 1.97X, respectively, compared to
1.39X and 1.38X 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 37% of the pool
balance.  The largest loan is the Stonewood Center Mall Loan
($71.2 million -- 26.3% of the pool), which is secured by the
borrower's interest in a 931,000 square foot regional mall
(collateral is 630,000 square feet) located approximately 13 miles
southeast of Los Angeles in Downey, California.  The mall is
anchored by J.C. Penney, Macy's and Sears.  The loan sponsors are
Macerich Co. and the Ontario Teachers Pension Fund.  The center
was 98% leased as of June 2010, the same as at last review.  The
loan matures in December 2010 and the borrower has requested a
payoff statement.  Moody's LTV and stressed DSCR are 45% and
2.19X, respectively, compared to 55% and 1.80X at last review.

The second largest loan is the One Renaissance Center Loan
($17.2 million -- 6.3% of the pool), which is secured by a 160,000
square foot office building located in Raleigh, North Carolina.
The property was 75% leased as of June 2010.  The loan matures in
January 2011.  Moody's LTV and stressed DSCR are 125% and 0.86X,
respectively, compared to 106% and 1.01X at last review.

The third largest loan is the Trendwest Office Building Loan
($10.6 million -- 3.9% of the pool), which is secured by a 76,300
square foot office property located in Redmond, Washington.  The
loan matures in December 2010.  Moody's LTV and stressed DSCR are
89% and 1.21X, respectively, compared to 94% and 1.15X at last
review.


CREDIT SUISSE: Moody's Reviews Ratings on 14 2004-C5 Certificates
-----------------------------------------------------------------
Moody's Investors Service placed 14 classes of Credit Suisse First
Boston Mortgage Securities Corp., Commercial Mortgage Pass-Through
Certificates, Series 2004-C5, on review for possible downgrade:

  -- Cl. A-J, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on May 25, 2005 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. B, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on May 25, 2005 Definitive Rating Assigned Aa2
     (sf)

  -- Cl. C, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on May 25, 2005 Definitive Rating Assigned Aa3
     (sf)

  -- Cl. D, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on May 25, 2005 Definitive Rating Assigned A2 (sf)

  -- Cl. E, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on May 25, 2005 Definitive Rating Assigned A3 (sf)

  -- Cl. F, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on June 4, 2009 Downgraded to Baa2 (sf)

  -- Cl. G, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on June 4, 2009 Downgraded to Ba1 (sf)

  -- Cl. H, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on June 4, 2009 Downgraded to B1 (sf)

  -- Cl. J, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on June 4, 2009 Downgraded to B2 (sf)

  -- Cl. K, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on June 4, 2009 Downgraded to B3 (sf)

  -- Cl. L, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on June 4, 2009 Downgraded to Caa1 (sf)

  -- Cl. M, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on June 4, 2009 Downgraded to Caa2 (sf)

  -- Cl. N, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on June 4, 2009 Downgraded to Caa3 (sf)

  -- Cl. O, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on June 4, 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 June 4, 2009.

                   Deal And Performance Summary

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 15% to $1.6 billion
from $1.9 billion at securitization.  The Certificates are
collateralized by 204 mortgage loans ranging in size from less
than 1% to 20% of the pool.

Forty-six loans, representing 39% 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.

Ten loans have been liquidated from the trust since
securitization, resulting in a $11.9 million loss (27% loss
severity).  Currently 10 loans, representing 4% of the pool, are
in special servicing.  The largest specially serviced loan is the
Kingwood Lakes Apartments loan ($15.5 million -- 1.0%), which was
transferred to special servicing in June 2010.  The master
servicer has recognized an appraisal reduction of $3.9 million for
this loan and an aggregate $14.8 million appraisal reduction for
all 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 Nine 2005-C3 Certs.
----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of nine classes
and affirmed 14 classes of Credit Suisse First Boston Commercial
Mortgage Securities Corp., Commercial Mortgage Pass-Through
Certificates, Series 2005-C3:

  -- Cl. A-2, Affirmed at Aaa (sf); previously on July 11, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on July 11, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-AB, Affirmed at Aaa (sf); previously on July 11, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed at Aaa (sf); previously on July 11, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-1-A, Affirmed at Aaa (sf); previously on July 11, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-X, Affirmed at Aaa (sf); previously on July 11, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-SP, Affirmed at Aaa (sf); previously on July 11, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-Y, Affirmed at Aaa (sf); previously on July 11, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-M, Downgraded to Aa1 (sf); previously on Oct. 13, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-J, Downgraded to Baa1 (sf); previously on Oct. 13, 2010
     A1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Downgraded to B2 (sf); previously on Oct. 13, 2010 A3
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Downgraded to Caa2 (sf); previously on Oct. 13, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to Caa3 (sf); previously on Oct. 13, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to Ca (sf); previously on Oct. 13, 2010 Ba3
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to Ca (sf); previously on Oct. 13, 2010 B3
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to C (sf); previously on Oct. 13, 2010 Caa2
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. H, Downgraded to C (sf); previously on Oct. 13, 2010 Ca
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. J, Affirmed at C (sf); previously on Nov 12, 2009
     Downgraded to C (sf)

  -- Cl. K, Affirmed at C (sf); previously on Nov 12, 2009
     Downgraded to C (sf)

  -- Cl. L, Affirmed at C (sf); previously on Nov 12, 2009
     Downgraded to C (sf)

  -- Cl. M, Affirmed at C (sf); previously on Nov 12, 2009
     Downgraded to C (sf)

  -- Cl. N, Affirmed at C (sf); previously on Nov 12, 2009
     Downgraded to C (sf)

  -- Cl. O, Affirmed at C (sf); previously on Nov 12, 2009
     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 loans approaching
maturity in an adverse environment.  Twelve loans, representing
15% of the pool, mature within the next 24 months and have a
Moody's stressed debt service coverage ratio less than 1.0X.

The affirmations are due to key 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 October 13, 2010, Moody's placed classes AM through P on review
for possible downgrade.  This action concludes Moody's review.

Moody's rating action reflects a cumulative base expected loss of
10.1% of the current balance.  At last review, Moody's cumulative
base expected loss was 6.5%.  Moody's stressed scenario loss is
20.2% 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.

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 25, the same at last review.

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 13, 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 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 9% to
$1.488 billion from $1.636 billion at securitization.  The
Certificates are collateralized by 189 mortgage loans ranging in
size from less than 1% to 8% of the pool, with the top ten loans
representing 38% of the pool.  The pool includes 53 loans,
representing 14% of the outstanding loan balance, which are
secured by residential co-ops located throughout New York City.
These loans have credit estimates of Aaa.  Seven loans,
representing 7% of the pool, have defeased and are collateralized
with U.S. Government securities.  Defeasance at last review
represented 5% of the pool.

Twenty five 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.

Five loans have been liquidated from the pool, resulting in an
aggregate realized loss of $12.6 million (62% loss severity).
Seventeen loans, representing 15% of the pool, are currently in
special servicing.

The largest specially serviced loan is the Southland Center Mall
($105.7 million -- 7.0% of the pool), which is secured by a
639,575 square foot mall located in Taylor, Michigan.  The
property is owned by an affiliate of General Growth Properties,
Inc. (GGP).  The loan was transferred to special servicing due to
GGP's bankruptcy filing on April 16, 2009.  The loan maturity was
not extended as part of the bankruptcy plan and the borrower has
the option to offer the property to the lender via a deed in lieu.

The remaining specially serviced loans are secured by a mix of
property types.  The master servicer has recognized appraisal
reductions totaling $75.1 million for ten of the specially
serviced loans.  Moody's has estimated an aggregate $92.4 million
loss (40% expected loss on average) for the specially serviced
loans.

Moody's has assumed a high default probability for ten poorly
performing loans representing 3% of the pool and has estimated a
$16.9 million loss (40% expected loss based on a 50% probability
default) from these troubled loans.

Based on the most recent remittance statement, Classes E through
P have experienced cumulative interest shortfalls totaling
$3.7 million.  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 88%
of the conduit pool.  Excluding specially serviced and troubled
loans, Moody's weighted average LTV is 102%, the same as 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 9.1%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.31X and 1.02X, respectively, compared to
1.29X 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.

The top three performing conduit loans represent 17% of the pool
balance.  The largest loan is the San Diego Office Park Loan
($113.0 million -- 7.5% of the pool), which is secured by an 11-
building 645,000 square foot Class A office complex located in San
Diego, California.  The loan sponsor is Maguire Properties.  The
property was 75% leased as of June 2010 compared to 100% at last
review.  The loan matures in April 2015 and is interest only
during the entire loan term.  Moody's LTV and stressed DSCR are
127% and 0.77X, respectively, compared to 110% and 0.73X at last
review.

The second largest loan is the 80-90 Maiden Lane Loan
($88.5 million -- 5.9% of the pool), which is secured by two Class
B office buildings totaling 545,000 square feet located in New
York City.  The property was 96% leased as of December 2009
compared to 99% at last review.  The loan matures in April 2015.
Moody's LTV and stressed DSCR are 105% and 0.93X, respectively,
compared to 103% and 0.94X at last review.

The third largest loan is Och Ziff Portfolio Loan ($52.5 million -
- 3.5% of the pool), which is secured by eight limited-service
hotels located in Columbus, Ohio and Covington, Kentucky.
Performance has declined since last review due to lower revenues
and increased expenses.  The loan matures in May 2012.  Moody's
LTV and stressed DSCR are 122% and 1.02X, respectively, compared
to 118% and 1.05X at last review.


CREDIT SUISSE: Moody's Affirms Ratings on 12 2007-C3 Certificates
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 12 classes and
downgraded 13 classes of Credit Suisse Commercial Mortgage Trust,
Commercial Mortgage Pass-Through Certificates, Series 2007-C3:

  -- Cl. A-2, Affirmed at Aaa (sf); previously on July 30, 2007
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on July 30, 2007
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-X, Affirmed at Aaa (sf); previously on July 30, 2007
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-AB, Downgraded to Aa2 (sf); previously on Oct. 20, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-4, Downgraded to Aa2 (sf); previously on Oct. 20, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-1-A1, Downgraded to Aa2 (sf); previously on Oct. 20,
     2010 Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-1-A2, Downgraded to Aa2 (sf); previously on Oct. 20,
     2010 Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-M, Downgraded to A3 (sf); previously on Oct. 20, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-J, Downgraded to B3 (sf); previously on Oct. 20, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Downgraded to Caa1 (sf); previously on Oct. 20, 2010
     Ba3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Downgraded to Caa3 (sf); previously on Oct. 20, 2010
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to Ca (sf); previously on Oct. 20, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to C (sf); previously on Oct. 20, 2010 Caa2
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to C (sf); previously on Oct. 20, 2010 Caa3
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to C (sf); previously on Oct. 20, 2010 Ca
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. H, Downgraded to C (sf); previously on Oct. 20, 2010 Ca
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. J, Affirmed at C (sf); previously on Dec. 16, 2009
     Downgraded to C (sf)

  -- Cl. K, Affirmed at C (sf); previously on Dec. 16, 2009
     Downgraded to C (sf)

  -- Cl. L, Affirmed at C (sf); previously on Dec. 16, 2009
     Downgraded to C (sf)

  -- Cl. M, Affirmed at C (sf); previously on Dec. 16, 2009
     Downgraded to C (sf)

  -- Cl. N, Affirmed at C (sf); previously on Dec. 16, 2009
     Downgraded to C (sf)

  -- Cl. O, Affirmed at C (sf); previously on Dec. 16, 2009
     Downgraded to C (sf)

  -- Cl. P, Affirmed at C (sf); previously on Dec. 16, 2009
     Downgraded to C (sf)

  -- Cl. Q, Affirmed at C (sf); previously on Dec. 16, 2009
     Downgraded to C (sf)

  -- Cl. S, Affirmed at C (sf); previously on Dec. 16, 2009
     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.  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 October 20, 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
12.8% of the current balance compared to 12.1% 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 December 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 six months.

                         Deal Performance

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance had decreased by 3% to $2.62 billion
from $2.68 billion at securitization.  The Certificates are
collateralized by 232 mortgage loans ranging in size from less
than 1% to 6% of the pool, with the top ten loans representing 32%
of the pool.  The pool does not contain any defeased loans or
loans with credit estimates.

Sixty-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.

Eleven loans have been liquidated from the pool since
securitization, resulting in an aggregate $31.6 million loss (60%
loss severity on average).  Currently, 30 loans, representing 26%
of the pool, are in special servicing.  The largest specially
serviced loan is the Main Plaza Loan ($160.7 million -- 6% of the
pool), which is secured by two 12-story office buildings located
in Irving, California.  The two buildings total 583,000 square
feet.  As of March 2010, the property was 70% leased compared to
65% at last review.  The loan was transferred to special servicing
in July 2010 for imminent default when the borrower requested a
loan modification.  The loan remains current.  The master servicer
has recognized an aggregate $153.8 million appraisal reduction for
20 of the specially serviced loans.  Moody's has estimated an
aggregate loss of $215.5 million (34% expected loss on average)
for all of the specially serviced loans.

Moody's has also assumed a high default probability for 23 poorly
performing loans representing 4% of the pool.  Moody's has
estimated a $26.0 million loss (25% expected loss based on a 50%
default probability) from the troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 82% and 63% of the pool, respectively.
Moody's weighted average LTV, excluding specially serviced and
troubled loans, is 117% compared to 131% 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 9.2%.

Moody's actual and stressed DSCRs, excluding specially serviced
and troubled loans, are 1.26X and 0.87X, respectively, compared to
1.21X and 0.83X 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 52 compared to 79 at Moody's prior review.

The top three performing loans represent 18% of the pool.  The
largest loan is the Mandarin Oriental Loan ($135.0 million -- 5.1%
of the pool), which is secured by a 248-key luxury hotel located
at Columbus Circle in New York City.  The loan is on the watch
list for low debt service coverage.  Performance has declined
since securitization due to a significant decline in tourist and
business travel in 2008 and 2009.  However, the property has
demonstrated improved performance in 2010.  For year-to-date
through September 2010, occupancy and revenue per available room
(RevPAR) were 69% and $522, respectively, compared to 60% and $460
at last review.  The borrower is Istithimar Building FZE, which
has been funding debt service shortfalls for approximately two
years.  Per the special servicer, the borrower has initiated
discussions regarding a possible loan modification.  The loan is
interest-only for its entire term and matures in March 2012.
Moody's LTV and stressed DSCR are 121% and 0.89X, essentially the
same as at last review.

The second largest loan is the Westwood Complex Loan
($95.0 million -- 3.6% of the pool), which is secured by a six
building mixed-use complex located in Bethesda, Maryland.  The
six buildings consist of two apartment buildings, a retail center,
a mixed-use space, an assisted living facility and a bowling
alley.  As of June 2010, the properties were 99% leased,
essentially the same as at last review and securitization.
Moody's LTV and stressed DSCR are 139% and 0.66X, essentially the
same as at last review.

The third largest conduit loan is the TRT Industrial Portfolio
Loan ($85.0 million -- 3.2% of the pool), which is secured by a
pool of seven industrial properties located across six states.  As
of June 2010, the portfolio was 86% leased.  Moody's LTV and
stressed DSCR are 129% and 0.76X, respectively, compared to 134%
and 0.71X at last review.


CRYSTAL RIVER: Fitch Affirms Ratings on Eight Classes of Notes
--------------------------------------------------------------
Fitch Ratings has affirmed eight and downgraded two classes of
notes issued by Crystal River Resecuritization CDO 2006-1,
Ltd./LLC.  The rating actions are a result of continued interest
shortfalls on the underlying collateral.

On the April 22, 2010 payment date, the class B notes did not
receive their full interest distribution as a result of
insufficient interest proceeds due to continued interest
shortfalls on the underlying collateral.  On May 3, 2010, the
trustee declared an event of default due to non-payment of full
and timely accrued interest to the class B notes.  The class B
notes are non-deferrable classes and are downgraded due to default
in the payment of their accrued interest.

Since Fitch's last rating action in December 2009, approximately
58% of the portfolio has been downgraded, and 31.4% is currently
on Rating Watch Negative.  The entire collateral pool is rated
below investment grade and 73.2% has a rating in the 'CCC' rating
category or lower, compared to 100% and 49.5%, respectively, 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 compared the
respective credit enhancement levels to the amount of distressed
assets ('CC' and below) and assets that are experiencing interest
shortfalls (68.9%).  Given the high probability of default of the
underlying assets and the expected limited recovery prospects upon
default, class A and classes C through K are rated 'C', indicating
that default is inevitable at maturity.

Crystal River is a static commercial real estate collateralized
debt obligation that closed on Jan. 12, 2007.  The transaction is
collateralized by 71 CMBS assets, of which 91.9% are from the 2005
and 2006 vintages, with the balance from the 2007 vintage (7.4%)
and the 2002 vintage (0.7%).

Fitch has taken action on these classes:

  -- $220,537,897 class A notes downgraded to 'Csf' from 'CCsf';
  -- $35,131,000 class B notes downgraded to 'Dsf' from 'Csf';
  -- $17,565,000 class C notes affirmed at 'Csf';
  -- $19,517,000 class D notes affirmed at 'Csf';
  -- $10,734,000 class E notes affirmed at 'Csf';
  -- $9,271,000 class F notes affirmed at 'Csf';
  -- $4,391,000 class G notes affirmed at 'Csf';
  -- $5,855,000 class H notes affirmed at 'Csf';
  -- $14,638,000 class J notes affirmed at 'Csf';
  -- $19,517,000 class K notes affirmed at 'Csf'.


CWMBS INC: Moody's Downgrades Ratings on 12 Tranches
----------------------------------------------------
Moody's Investors Service has downgraded the ratings of 12
tranches from CWMBS, Inc. Mortgage Pass-Through Certificates,
Series 2006-7.  The collateral backing this deal primarily
consists of first-lien, fixed rate Alt-A residential mortgages.

                        Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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: CWMBS, Inc. Mortgage Pass-Through Certificates, Series
2006-7

  -- Cl. 1-A-1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-2, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-3, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-4, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-5, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-X, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. PO, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-2, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-3, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-4, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-X, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade


DILLON READ: Fitch Takes Rating Actions on Various Classes
----------------------------------------------------------
Fitch Ratings has affirmed eight and downgraded one class of notes
issued by Dillon Read CMBS CDO 2006-1 Ltd./Corp.  The actions are
a result of continued negative credit migration within the
reference portfolio.

The transaction entered an Event of Default on Sept. 2, 2010, when
the ratio of the net outstanding portfolio balance over the sum of
the class A-1SVF notes (funded amount plus remaining unfunded
facility commitment) and the outstanding amount of the class A-1
notes failed the 100% threshold.  The test failure was due to
downgrades to the underlying collateral and the application of the
documented overcollateralization haircuts to assets rated below
'BBB-'.

Since Fitch's last rating action in December 2009, approximately
44.4% of the portfolio has been downgraded, and 9.9% is currently
on Rating Watch Negative.  Approximately 91.3% of the portfolio
has a Fitch derived rating below investment grade and 66.6% has a
rating in the 'CCC' rating category or lower, compared to 86.8%
and 26.7%, respectively, 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 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.  The class A-S1VF
through A-2 notes are currently receiving timely interest
distributions.  Classes A-3 through B-4 are not receiving any
interest distributions due to the A-2 OC test failure.  All
interest and principal proceeds are being diverted to defease the
unfunded A-S1VF notes by depositing proceeds into the Reserve
Account and writing down the unfunded portion by the corresponding
amount.  The proceeds of the Reserve Account will then be used to
make loss protection payments.  Fitch does not expect classes A-3
through B-4 to receive any further payments due to the expectation
of further collateral deterioration.

Dillon Read CMBS CDO 2006-1 is a hybrid revolving collateralized
debt obligation transaction that combines the use of synthetic and
cash assets, as well as unfunded and funded liabilities.  The
transaction closed on Nov. 2, 2006.  The portfolio is composed of
85.7% CMBS assets from the 2005 and 2006 vintage, 9.7% of real
estate investments trusts, and the remaining 4.6% are commercial
real estate CDOs.

Fitch has taken these actions:

  -- $639,759,215 class A-S1VF notes downgraded to 'Csf' from
     'CCCsf';

  -- $150,000,000 class A-1 notes affirmed at 'Csf';

  -- $60,000,000 class A-2 notes affirmed at 'Csf';

  -- $41,250,000 class A-3 notes affirmed at 'Csf';

  -- $12,500,000 class A-4 notes affirmed at 'Csf';

  -- $28,750,000 class B-1 notes affirmed at 'Csf';

  -- $11,250,000 class B-2 notes affirmed at 'Csf';

  -- $8,750,000 class B-3 notes affirmed at 'Csf';

  -- $10,000,000 class B-4 notes affirmed at 'Csf'.


FEDERAL FAMILY: S&P Takes Various Rating Actions on 11 Loans
------------------------------------------------------------
Standard & Poor's Ratings Services took various rating actions on
11 student loan asset-backed securities trusts backed by Federal
Family Education Loan Program student loan collateral.  S&P
lowered its ratings on nine subordinate classes of notes from four
trusts and placed them on CreditWatch with negative implications,
and affirmed its ratings on 34 senior classes from the same four
trusts.  Additionally, S&P affirmed its ratings on 81 senior and
subordinate classes from the remaining seven trusts.

S&P's analysis of each trust included an evaluation of:

Current parity ratios (the ratios of total assets to total
liabilities) and changes in parity levels over time.  This
included an examination of the assets of the trust compared to the
amount of liabilities of the trust, a credit review of these
assets, and an evaluation of how the assets and liabilities may
change over time;  The trusts' cost-of-funds structures, given the
amount of auction-rate securities in each capital structure.  Due
to failed auctions, transaction-specific interest rates could rise
and thereby reduce the trusts' levels of excess spread; The
current credit enhancement available to support each class at its
current rating level.  S&P's analysis of both the senior and
subordinate notes included a review of credit as well as liquidity
risk factors.  Liquidity issues may arise when the amount of loans
in nonpaying status (e.g., delinquencies, deferment, forbearance,
or claims) in a trust begins to erode excess spread.  However, the
U.S. government guarantee on the FFELP collateral, which caps the
potential loss at 3% of the defaulted loan balance, significantly
mitigates any credit issues for senior classes.  Subordinate notes
have the most exposure to any defaults that the government
guarantee and available excess spread may not cover.

As part of this review, S&P confirmed that the subordinate bonds
in each trust all represent an amount greater than 3% of the
capital structure of each trust.

S&P also factored the quality of reporting and availability of
data into its analysis.  S&P believes the importance of granular
data (at the asset and liability level) increases as collateral
performance deteriorates.

                       Rating Affirmations

In aggregate, S&P affirmed its ratings on 115 classes from these
11 trusts.  The affirmations reflect its view that the available
credit enhancement levels, including excess spread, continue to be
sufficient to cover remaining defaults (which the federal
guarantee would cover for at least 97% of the defaulting loan
balance) and support the related classes at their current rating
levels.  In some cases, total parity ratios, while currently below
100%, are steadily building toward 100% and/or are likely to reach
their release thresholds soon.  These trusts have been managing to
build parity despite relatively large portions of loans in
nonpaying status.  S&P discuss each trust in further detail below.

                  Access Group Inc. Series 2007-1

S&P affirmed its ratings on all six senior, subordinate, and
junior subordinate classes from Access Group Inc.'s series 2007-1
trust.  As of July 26, 2010, the total asset parity ratio was
99.23%, yet it is steadily building and is likely to reach the
transaction's release threshold of 100.25% in the next couple of
years.  This growth in parity is occurring despite 35.9% in
nonpaying loans in the pool, including 30-plus-day delinquencies
(4.8%), loans in deferment (18.9%), loans in forbearance (11.9%),
and current claims (0.3%).  The senior asset parity ratio, at
106.60%, and the subordinate parity ratio, at 102.14%, both
demonstrate that available credit enhancement is sufficient to
fully support the class A and class B notes.  This trust contains
no auction-rate liabilities.

              ALG Student Loan Trust II Series 2007-1

S&P affirmed its ratings on all eight senior and subordinate
classes from ALG Student Loan Trust II's series 2007-1.  The
senior asset parity ratio had reached 110.91% by Aug. 31, 2010.
This value is higher than its original level of 109.12% in June of
2007.  The subordinate asset parity ratio, while still below 100%
(at 99.36%), has grown at a steady rate from its original value of
97.34%.  This growth in parity has been occurring despite a
relatively large percentage of nonpaying loans in the pool
(54.1%), including 30-plus-day delinquencies (10.5%), loans in
deferment (23.4%), loans in forbearance (19.3%), and current
claims (1.0%).  Approximately one-quarter of the liabilities are
auction-rate notes, which pay according to a failed auction rate
definition based on the lowest of LIBOR plus a rating-dependent
margin, the commercial paper rate plus a rating-dependent margin,
and a net loan rate.  The issuer has been active in purchasing
auction-rate notes at a discount.  (S&P notes that Standard &
Poor's does not give any credit to the issuer's potential ability
to repurchase auction-rate securities at a discount in the
future).  The total asset parity ratio is likely to reach 100% in
approximately the next year.

          College Loan Corporation Trust II Series 2007-1

S&P affirmed its ratings on all 16 senior and subordinate classes
from College Loan Corporation Trust II's series 2007-1.  As of
June 30, 2010, the senior parity ratio, according to its
calculations, was 107.04% and the total parity ratio was 98.46%.
While total parity is currently below 100%, it has improved by
almost 100 basis points since the deal's inception in 2007.  Loans
in nonpaying status total 41.7% of the outstanding pool balance
and include 30-plus-day delinquencies (12.7%), loans in deferment
(17.3%), loans in forbearance (10.6%), and current claims (1.2%).
Approximately 38% of the liabilities are auction-rate notes,
which, due to the continued failure of the auction-rate markets,
are paying at a relatively low cost of funds based on the lesser
of the Treasury-bill rate plus a rating-dependent margin and a net
loan rate.  This should help the trust generate excess spread.  In
addition, many loans in the pool are relatively new, and as they
enter repayment, S&P expects to see the total parity ratio
continue to grow to 100%.

           GCO Education Loan Funding Master Trust - II
                     Series 2006-2 and 2007-1

S&P affirmed its ratings on 18 senior and subordinate classes from
GCO Education Loan Funding Master Trust - II's series 2006-2 and
2007-1.  The senior asset parity ratio had grown to 104.97% in
August 2010 from 102.35% at the time of the most recent issuance
in March 2007.  The subordinate asset parity ratio has also grown,
to 99.25% from 97.87%, and is likely to reach the subordinate
release ratio of 100.50% over the next couple of years.  Loans in
nonpaying status total 42.6% of the outstanding pool balance and
include 30-plus-day delinquencies (14.5%), loans in deferment
(17.3%), loans in forbearance (9.9%), and current claims (0.8%).
Auction-rate notes -- which pay at a failed-auction cost of funds
based on the lesser of LIBOR plus a rating-dependent margin and a
net loan rate -- account for approximately 23% of the liabilities,
and the issuer has been active in purchasing these notes at a
discount in an attempt to improve the parity levels.  (Standard &
Poor's does not give any credit to the issuer's potential ability
to repurchase auction-rate securities at a discount in the
future.)

                 Nelnet Student Loan Trust 2007-2

S&P affirmed its ratings on six senior and subordinate classes
from Nelnet Student Loan Trust 2007-2.  By Aug. 30, 2010, the
total parity ratio had risen to 99.52%, from 97.46% at issuance in
December 2007.  Parity has been growing at a steady rate and is
likely to reach 100% in the next year.  Loans in nonpaying status
total 36.9% of the outstanding pool balance and include 30-plus-
day delinquencies (8.8%), loans in deferment (14.7%), loans in
forbearance (12.9%), and claims (0.5%).  This transaction has a
relatively small portion (15%) of auction-rate liabilities, which
pay at a failed auction rate based on the lesser of LIBOR plus
1.25% and a net loan rate.

                 Northstar Education Finance Inc.
             Series 2004-1, 2004-2, 2005-1, and 2007-1

S&P affirmed its ratings on 23 senior and subordinate classes from
Northstar Education Finance Inc.'s series 2004-1, 2004-2, 2005-1,
and 2007-1.  The senior asset parity ratio had increased to
103.60% as of Aug. 31, 2010, from 101.89% at the time of the most
recent issuance in March of 2007.  The subordinate asset parity
ratio has also trended up since then (to 99.21%) and is likely to
reach the subordinate release ratio of 100.75% in the next couple
of years.  Loans in nonpaying status total 35.5% of the
outstanding pool balance and include 30-plus-day delinquencies
(1.8%), loans in deferment (10.5%), loans in forbearance (21.5%),
and claims (0.2%).  Approximately 22% of the liabilities are
auction-rate notes and are paying at a relatively low failed-
auction cost of funds based on the lowest of the T-bill rate plus
a rating-dependent margin, LIBOR plus 1.00%, and a net loan rate.
This should help the trust to generate excess spread.

          U.S. Education Loan Trust III LLC Series 2004

S&P affirmed its ratings on four senior and subordinate classes
from U.S. Education Loan Trust III LLC's series 2004.  As of
Aug. 31, 2010, the senior asset parity ratio had risen to 108.26%,
from 103.61% at issuance in June 2004.  In addition, the
subordinate asset parity ratio had grown to 99.49% from 97.54%
over the same period.  Loans in nonpaying status total 23.9% of
the outstanding pool balance and include 30-plus-day delinquencies
(6.2%), loans in deferment (7.1%), loans in forbearance (10.5%),
and claims (0.2%).  The liabilities are all auction-rate notes,
which pay according to a failed auction-rate definition based on
the lowest of LIBOR plus a rating-dependent margin, the CP rate
plus a rating-dependent margin, and a net loan rate.  The issuer
has been active in purchasing these notes at a discount in an
attempt to improve the parity levels.  (Standard & Poor's does not
give any credit to the issuer's potential ability to repurchase
auction-rate securities at a discount in the future.)

          Downgrades And Creditwatch Negative Placements

S&P lowered its ratings on nine subordinate classes from four
trusts and placed them on CreditWatch negative to reflect S&P's
view that the available credit enhancement levels are currently
insufficient to support the related classes at their prior rating
levels.  Parity ratios for these trusts are currently below 100%
and are either declining or stagnant.  S&P generally believe that
parity may not be building in these trusts due to several factors,
including, most notably, the negative impact of nonpaying loans on
the cost of funds and excess spread levels for these transactions.
All but one of these trusts have significant amounts of auction-
rate notes in their capital structures, which, due to the failed
auctions of the past few years, could significantly increase the
cost of funds over time and erode excess spread.  S&P's view of
the parity ratios for these trusts incorporates its opinion that
the current credit enhancement available, given their recent
trends, is insufficient to support the notes at their prior rating
levels.  Furthermore, given their position in the capital
structure, the subordinate notes have the most exposure to any
defaults that the government guarantee and available excess spread
may not cover.

       Access Group Inc. Series 2002-1, 2003-1, and 2004-1

S&P lowered its ratings on the subordinate notes from Access Group
Inc.'s series 2002-1, 2003-1, and 2004-1 and placed them on
CreditWatch with negative implications.  At the same time, S&P
affirmed its ratings on the senior notes from this trust.

The downgrades reflect S&P's view of the lack of growth in the
total asset parity ratio, which has remained relatively unchanged
(at 98.08% in August 2010) since the time of the last issuance
from this trust in 2004 (when it was 98.10%).  S&P's stressed cash
flow analysis from the most recent issuance in 2004 indicated that
the total asset percentage should have reached its release
threshold of 101% by now.  Loans in nonpaying status total 16.1%
of the outstanding pool balance and include 30-plus-day
delinquencies (3.6%), loans in deferment (5.7%), loans in
forbearance (6.4%), and current claims (0.4%).  Auction-rate notes
make up 40% of the liabilities outstanding, and based on the
auction-rate definition applicable for auction failures (the
lowest of LIBOR plus 1.50%, a quarterly average T-bill rate plus a
rating dependent margin, and a net loan rate), the cost of funds
could increase and thereby further erode excess spread.

The affirmations of S&P's ratings on the senior notes reflect
S&P's view that available credit enhancement is sufficient to
support the 'AAA (sf)' ratings on these classes.  The senior asset
parity ratio was 103.62% in August 2010, up from 101.60% in May
2004.

         Education Loans Inc. Series 2005-1A3 and 2005-1B

S&P lowered its ratings on the subordinate LIBOR-based floating-
rate notes from Education Loans Inc.'s series 2005-1B to 'BB (sf)'
from 'A (sf)' and placed them on CreditWatch with negative
implications.  Concurrently, S&P affirmed its ratings on the
series 2005-1A3 senior notes.

The downgrades reflect S&P's view of declines in the total asset
parity ratio, which had fallen to 96.40% as of Aug. 31, 2010, from
96.96% at issuance in August 2005.  This trust experienced heavy
prepayments due to loan consolidations within the deal shortly
after the inception of the deal.  Because the trust documents did
not contain provisions for asset recycling, prepayment proceeds
were used to pay principal on the notes; the principal balance of
the notes now stands at approximately 37% of the original par
amount of the notes outstanding.  Consequently, the trust has not
been able to generate the excess spread originally expected.
Loans in nonpaying status total 42.2% of the outstanding pool
balance and include 30-plus-day delinquencies (15.3%), loans in
deferment (16.1%), loans in forbearance (8.0%), and current claims
(1.5%).

S&P downgraded these notes below investment-grade due to its view
that this trust is significantly less likely than the other trusts
S&P reviewed to be able to make full and timely payments of
interest and the ultimate payment in full of principal on the
subordinate notes.

The affirmation of S&P's ratings on the senior notes indicates its
view that available credit enhancement is sufficient to support
the 'AAA (sf)' ratings on these classes.  The senior asset parity
ratio, according to S&P's calculation, now stands at over 115%,
which is significantly higher than the original percentage, which
S&P calculated at 103.28%.

          Educational Loan Company Trust I Series 2006-1

S&P lowered its ratings on the subordinate notes from Educational
Loan Company Trust I's series 2006-1 and placed them on
CreditWatch with negative implications.  At the same time, S&P
affirmed its ratings on the senior notes in this trust.

The downgrades reflect S&P's view of declines in the subordinate
asset parity ratio, which had fallen to 97.02% as of Aug. 31,
2010, from 98.59% at the date of the last issuance in June 2007.
Nonpaying loans account for almost one-quarter (23.5%) of the
outstanding pool balance, while loans in deferment and forbearance
stand at 11.0% and 10.3%, respectively.  Thirty-plus-day
delinquencies, however, are relatively low, at 2.5% of the pool
balance, and claims represent 0.3% of the pool.  All of the
liabilities are auction-rate notes, and based on the auction-rate
definition applicable in auction failures (the lowest of LIBOR
plus a rating-dependent margin, a quarterly average CP rate plus a
rating-dependent margin, and a net loan rate), the cost of funds
could increase and further erode excess spread.

The affirmation of S&P's ratings on the senior notes reflects its
view that available credit enhancement remains sufficient to
support the 'AAA (sf)' ratings on these classes.  The senior asset
parity ratio has declined somewhat from its original level of
105.64% in June 2007 but remains well above par at 104.69%.

                U.S. Education Loan Trust IV LLC

S&P lowered its ratings on the subordinate notes from U.S.
Education Loan Trust IV LLC and placed them on CreditWatch with
negative implications.  At the same time, S&P affirmed its ratings
on the senior notes from this trust.

The downgrades reflect S&P's view of the marginal growth in the
total parity ratio since the latest trust issuance in October
2007, when total parity stood at 97.46% (according to the December
2007 distribution report, which was the first quarterly
distribution report after the October 2007 issuance).  The master
servicer has furnished information indicating that total parity
has since risen to 98.08% as of September 2010.  The levels of
loans in forbearance and deferment are relatively high, at 20.3%
and 15.0% of the outstanding pool balance, respectively.  The
total percent of nonpaying loans, which also includes 8.7% in 30-
plus-day delinquencies and 0.2% in claims, totals 44.2% of the
outstanding pool balance.  Also, over half (approximately 55%) of
the liabilities are auction-rate notes, and based on the auction-
rate definition applicable in auction failures (the lowest of
LIBOR plus a rating-dependent margin, the CP rate plus a rating-
dependent margin, and a net loan rate), the cost of funds could
increase and further erode excess spread.

The affirmation of S&P's ratings on the senior notes reflects its
opinion that available credit enhancement is sufficient to support
the 'AAA (sf)' ratings on these classes.  The senior note
collateralization ratio has been trending up, and at 103.10%, now
stands approximately 50 basis points above its level of 102.58% at
the end of 2007.

        Ratings Lowered And Placed On Creditwatch Negative

                        Access Group Inc.
US$488.9 mil federal student loan asset-backed notes series 2002-1

                                       Rating
                                       ------
        Class      CUSIP       To                   From
        -----      -----       --                   ----
        B          00432CAP6   BBB (sf)/Watch Neg   A (sf)

                        Access Group Inc.
      US$669.154 mil federal student loan asset-backed notes
                         series 2003-1

                                       Rating
                                       ------
        Class      CUSIP       To                   From
        -----      -----       --                   ----
        B          00432CBE0   BBB (sf)/Watch Neg   A (sf)

                        Access Group Inc.
US$750 mil federal student loan asset-backed notes series 2004-1

                                       Rating
                                       ------
        Class      CUSIP       To                   From
        -----      -----       --                   ----
        B          00432CBT7   BBB (sf)/Watch Neg   A (sf)

                       Education Loans Inc.
US$750 mil student loan asset-backed notes senior and subordinate
                          series 2005-1

                                       Rating
                                       ------
        Class      CUSIP       To                   From
        -----      -----       --                   ----
        B          280907BX3   BB (sf)/Watch Neg    A (sf)

                Educational Loan Company Trust I
US$300 mil educational loan company trust I student loan backed
                       notes series 2006-1

                                       Rating
                                       ------
        Class      CUSIP       To                   From
        -----      -----       --                   ----
        B          28148VAC9   BBB (sf)/Watch Neg   A (sf)

                U.S. Education Loan Trust IV LLC
       US$1.106 bil student loan-backed notes series 2006-1

                                       Rating
                                       ------
        Class      CUSIP       To                   From
        -----      -----       --                   ----
        B-1        90342NAJ6   BBB (sf)/Watch Neg   A (sf)
        B-2        90342NAK3   BBB (sf)/Watch Neg   A (sf)

                 U.S. Education Loan Trust IV LLC
        US$600 mil student loan-backed notes series 2006-2

                                       Rating
                                       ------
        Class      CUSIP       To                   From
        -----      -----       --                   ----
        B-1        90342NAT4   BBB (sf)/Watch Neg   A (sf)

                 U.S. Education Loan Trust IV LLC
        US$780 mil student loan-backed notes series 2007-1

                                       Rating
                                       ------
        Class      CUSIP       To                   From
        -----      -----       --                   ----
        B-1        90342NAZ0   BBB (sf)/Watch Neg   A (sf)

                        Ratings Affirmed

                        Access Group Inc.
US$488.9 mil federal student loan asset-backed notes series 2002-1

                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-2        00432CAL5   AAA (sf)
                 A-3        00432CAM3   AAA (sf)
                 A-4        00432CAN1   AAA (sf)

                        Access Group Inc.
      US$669.154 mil federal student loan asset-backed notes
                         series 2003-1

                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-2        00432CAY7   AAA (sf)
                 A-3        00432CAZ4   AAA (sf)
                 A-4        00432CBA8   AAA (sf)
                 A-5        00432CBB6   AAA (sf)
                 A-6        00432CBC4   AAA (sf)

                        Access Group Inc.
       US$750 mil federal student loan asset-backed notes
                          series 2004-1


                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-1        00432CBM2   AAA (sf)
                 A-2        00432CBN0   AAA (sf)
                 A-3        00432CBP5   AAA (sf)
                 A-4        00432CBQ3   AAA (sf)
                 A-5        00432CBR1   AAA (sf)

                        Access Group Inc.
   US$1.18 bil federal student loan asset-backed floating rate
                       notes series 2007-1


                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-2        00432CDM0   AAA (sf)
                 A-3        00432CDN8   AAA (sf)
                 A-4        00432CDP3   AAA (sf)
                 A-5        00432CDQ1   AAA (sf)
                 B          00432CDR9   AA+ (sf)
                 C          00432CDS7   A (sf)

                    ALG Student Loan Trust II
        US$1.3 bil student loan-backed notes series 2007-1


                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-1        001621AA9   AAA (sf)
                 A-2        001621AB7   AAA (sf)
                 A-3        001621AC5   AAA (sf)
                 A-4        001621AD3   AAA (sf)
                 A-5        001621AE1   AAA (sf)
                 A-6        001621AF8   AAA (sf)
                 B-1        001621AJ0   A (sf)
                 B-2        001621AK7   A (sf)

               College Loan Corporation Trust II
    US$1.7 bil student loan asset-backed notes series 2007-1


                 Class      CUSIP       Rating
                 -----      -----       ------
                 1A-1       194268AA6   AAA (sf)
                 1A-2       194268AB4   AAA (sf)
                 1A-3       194268AC2   AAA (sf)
                 1A-4       194267AA8   AAA (sf)
                 1A-5       194267AB6   AAA (sf)
                 1A-6       194267AC4   AAA (sf)
                 1A-7       194267AD2   AAA (sf)
                 1A-8       194267AE0   AAA (sf)
                 1A-9       194267AF7   AAA (sf)
                 1A-10      194267AG5   AAA (sf)
                 1A-11      194267AH3   AAA (sf)
                 1A-14      194267AQ3   AAA (sf)
                 1B-1       194267AL4   A- (sf)
                 1B-3       194267AN0   A- (sf)
                 1B-2       194267AM2   A- (sf)
                 1B-4       194267AP5   A- (sf)

                       Education Loans Inc.
      US$750 mil student loan asset-backed notes senior and
                    subordinate series 2005-1

                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-3        280907BW5   AAA (sf)

                 Educational Loan Company Trust I
    US$300 mil educational loan company trust I student loan
                    backed notes series 2006-1


                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-1        28148VAA3   AAA (sf)
                 A-2        28148VAB1   AAA (sf)
                 A-3        28148VAD7   AAA (sf)

          GCO Education Loan Funding Master Trust - II
CAD280 mil, US$1.25 bil GCO ELF student loan asset-backed notes
                          series 2006-2


                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-1L       36156YAB7   AAA (sf)
                 A-2L       36156YAC5   AAA (sf)
                 A-3L       36156YAD3   AAA (sf)
                 A-1RRN     36156YAA9   AAA (sf)
                 A-1AR      36156YAE1   AAA (sf)
                 A-2AR      36156YAF8   AAA (sf)
                 A-3AR      36156YAG6   AAA (sf)
                 A-4AR      36156YAL5   AAA (sf)
                 B-1AR      36156YAH4   A (sf)
                 B-2AR      36156YAJ0   A (sf)
                 B-3AR      36156YAK7   A (sf)

          GCO Education Loan Funding Master Trust - II
    US$1.54 bil student loan asset-backed notes series 2007-1


                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-4L       36156YAM3   AAA (sf)
                 A-5L       36156YAN1   AAA (sf)
                 A-6L       36156YAP6   AAA (sf)
                 A-7L       36156YAQ4   AAA (sf)
                 A-5AR      36156YAR2   AAA (sf)
                 A-6AR      36156YAS0   AAA (sf)
                 A-7AR      36156YAT8   AAA (sf)

                Nelnet Student Loan Trust 2007-2
    US$1.5 bil student loan asset-backed notes series 2007-2


                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-2L       64032FAD6   AAA (sf)
                 A-3L       64032FAG9   AAA (sf)
                 A-4AR-1    64032FAK0   AAA (sf)
                 A-4AR-2    64032FAH7   AAA (sf)
                 B-1        64032FAL8   A (sf)
                 B-2        64032FAM6   A (sf)

                NorthStar Education Finance Inc.
     US$1 bil student loan asset-backed notes series 2004-1


                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-3        66704JAS7   AAA (sf)
                 A-4        66704JAT5   AAA (sf)
                 B-1        66704JAY4   A (sf)

                NorthStar Education Finance Inc.
     US$1 bil student loan asset-backed notes series 2004-2


                 Class      CUSIP       Rating
                 -----      -----       ------
                 2004-2A-1  66704JAZ1   AAA (sf)
                 2004-2A-2  66704JBA5   AAA (sf)
                 2004-2A-3  66704JBB3   AAA (sf)
                 2004-2A-4  66704JBC1   AAA (sf)
                 2004-2B    66704JBD9   A (sf)

                 NorthStar Education Finance Inc.
    US$1.02 bil student loan asset-backed notes series 2005-1


                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-1        66704JBE7   AAA (sf)
                 A-2        66704JBF4   AAA (sf)
                 A-3        66704JBG2   AAA (sf)
                 A-4        66704JBH0   AAA (sf)
                 A-5        66704JBJ6   AAA (sf)
                 B          66704JBK3   A (sf)

                 NorthStar Education Finance Inc.
    US$1.07 bil student loan asset-backed notes series 2007-1

                 Class      CUSIP       Rating
                 -----      -----       ------
                 2007-1A-1  66704JBT4   AAA (sf)
                 2007-1A-2  66704JBU1   AAA (sf)
                 2007-1A-3  66704JBV9   AAA (sf)
                 2007-1A-4  66704JBW7   AAA (sf)
                 2007-1A-5  66704JBX5   AAA (sf)
                 2007-1A-6  66704JBY3   AAA (sf)
                 2007-1A-7  66704JBZ0   AAA (sf)
                 2007-1A-8  66704JCA4   AAA (sf)
                 2007-1B    66704JCB2   A (sf)

               U.S. Education Loan Trust III LLC
    US$341.2 mil student loan asset-backed notes series 2004

                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-1        91730EAA3   AAA (sf)
                 A-2        91730EAB1   AAA (sf)
                 A-3        91730EAC9   AAA (sf)
                 B          91730EAD7   A (sf)

                 U.S. Education Loan Trust IV LLC
      US$1.106 bil student loan-backed notes series 2006-1

                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-2        90342NAB3   AAA (sf)
                 A-3        90342NAC1   AAA (sf)
                 A-4        90342NAD9   AAA (sf)
                 A-5        90342NAE7   AAA (sf)
                 A-6        90342NAF4   AAA (sf)
                 A-7        90342NAG2   AAA (sf)
                 A-8        90342NAH0   AAA (sf)

                U.S. Education Loan Trust IV LLC
       US$600 mil student loan-backed notes series 2006-2

                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-1        90342NAL1   AAA (sf)
                 A-2        90342NAM9   AAA (sf)
                 A-3        90342NAN7   AAA (sf)
                 A-4        90342NAP2   AAA (sf)
                 A-5        90342NAQ0   AAA (sf)
                 A-6        90342NAR8   AAA (sf)
                 A-7        90342NAS6   AAA (sf)

                U.S. Education Loan Trust IV LLC
       US$780 mil student loan-backed notes series 2007-1

                 Class      CUSIP       Rating
                 -----      -----       ------
                 A-2        90342NAW7   AAA (sf)
                 A-3        90342NAX5   AAA (sf)
                 A-4        90342NAY3   AAA (sf)


FEP RECEIVABLES: Moody's Cuts Ratings on 4 Classes to C (sf)
------------------------------------------------------------
Moody's has downgraded the remaining outstanding tranches of the
FEP Receivables Trust 2001-1, a transaction backed by interests in
mutual fund fees.  The complete rating action is:

Issuer: FEP Receivables Trust 2001-1

  -- Class A, Downgraded to C (sf); previously on May 25, 2006
     Downgraded to Caa3 (sf)

  -- Class A-3L, Downgraded to C (sf); previously on May 25, 2006
     Downgraded to Caa2 (sf)

  -- Class B, Downgraded to C (sf); previously on May 25, 2006
     Downgraded to Ca (sf)

  -- Class BL, Downgraded to C (sf); previously on May 25, 2006
     Downgraded to Ca (sf)

                        Ratings Rationale

The cash flows supporting these Notes are various future fees
generated by equity and debt mutual funds.  The credit quality of
a security backed by mutual fund fees depends on the likely fees
to be generated by the mutual funds during the life of the
security, and the potential variability of such collections.
Expected future fees are highly dependent upon forecast values of
the mutual funds, which, in turn, are linked to current values and
informed by historical performance.  The future fee revenues also
depend upon the fee schedules relating to the mutual fund pools
from which fees are generated.

Fees providing cash flows to these transactions include: CDSC
fees, based on a 5-8 year declining scale and assessed upon
redemption of mutual fund shares, and 12b-1 fees, charged for the
first 6-12 years of share ownership.  Both types of fees are
linked to the Net Asset Values of mutual fund positions.

The notes have received only immaterial amounts of cash --
interest or principal -- for several months.  Apart from possible
distributions from a small reserve account, Moody's anticipate
minimal if any future distributions on these notes due to the age
of the deal and finite life of the assets as described above.

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.


FFCA SECURED: Moody's Reviews Ratings on Various Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service has placed on review for possible
upgrade the Class C-1 and D-1 fixed rate and the Class C-2 and D-2
floating rate notes from FFCA Secured Franchise Loan Owner Trust
1999-1.  The fixed and floating rate notes are backed by fixed and
floating rate franchise loans, respectively, made to fast-food and
casual dining restaurants.  The complete rating action is:

Issuer: Franchise Secured Franchise Loan Grantor Trust 1999-1

  -- Class D-1, Ba2 (sf) Placed Under Review for Possible Upgrade;
     previously on Aug. 25, 2004 Downgraded to Ba2 (sf)

  -- Class D-2, Ba2 (sf) Placed Under Review for Possible Upgrade;
     previously on Aug. 25, 2004 Downgraded to Ba2 (sf)

  -- Class C-1, Baa3 (sf) Placed Under Review for Possible
     Upgrade; previously on Aug. 25, 2004 Downgraded to Baa3 (sf)

  -- Class C-2, Baa3 (sf) Placed Under Review for Possible
     Upgrade; previously on Aug. 25, 2004 Downgraded to Baa3 (sf)

The securities listed above were placed on review for possible
upgrade due to the high levels of credit enhancement available to
them.  Total credit support for the notes consists of
subordination and any available overcollateralization.  The fixed
and floating rate pools are cross-supported with losses allocated
to both subpools in reverse alphabetical order.

As of October 18th, 2010 the total subordination percentage for
the Class C-1 fixed rate note and Class C-2 floating rate note is
76.3%.  The total subordination percentage for the Class D-1 fixed
rate note, and Class D-2 floating rate is 61.2%.

The transaction has a low balance of specially serviced loans
which comprise less than 1% of the current pool balance.  However,
there are significant obligor concentrations risks in Go-Mart
(50%), United Dairy (17%), and Burger King (4%) as percentage of
the current pool.

During the review period, Moody's will estimate the recovery rates
of foreclosed properties and assess any future stresses on the
rest of the collateral pool.  Moody's will also qualitatively
assess the business challenges currently faced by the restaurant
industry.

In order to estimate losses on the collateral pool, Moody's
calculates the expected loss given default of the obligors that
have become nonperforming, and also estimates future losses on
performing portion of the pool, all as a percentage of the
outstanding pool.  In evaluating the nonperforming loans, key
factors include collateral valuations and expected recovery rates,
volatility around those recovery rates, historical obligor
performance, time until recovery or liquidation on defaulted
obligors, concessions due to restructuring which may negatively
impact the overall cash flow of the trust and the collateral, and
future industry expectations.  Net losses are then evaluated
against the available credit enhancement provided by
overcollateralization, subordination, and excess spread.
Sufficiency of coverage is considered in light of remaining
borrower concentrations and concepts, remaining bond maturities,
and economic outlook.


FIRST MARBLEHEAD: Fitch Downgrades Ratings on 2006-A Notes
----------------------------------------------------------
Fitch Ratings has downgraded the outstanding ratings on the notes
issued by First Marblehead Corporation's National Collegiate Trust
2006-A.  In addition, the class A notes have been removed from
Rating Watch Negative and subsequently assigned a Negative Rating
Outlook.  No Outlook has been assigned to the class B notes as
Fitch does not assign Rating Outlooks to classes rated 'CCC' or
below.

Fitch's U.S. Private Student Loan ABS Criteria and Global
Structured Finance Rating Criteria were used to review the rating
of the notes.  The rating actions are detailed at the end of this
press release.

The downgrades reflect the default rate for CHELA loans
(representing 34.3% of the current collateral pool) that continues
to increase in excess of Fitch's initial expectation.  Calculated
loss multiples were indicative of the lower ratings for the
remaining two classes in the trust.  A Negative Outlook was
assigned to reflect Fitch's concern that the collateral may
continue to deteriorate and warrant further downgrades.  It also
corresponds with Fitch's Negative Outlook for the private student
loan sector in general.

The loss coverage multiples were determined by comparing the
projected net loss amount to available credit enhancement levels.
Fitch used historical vintage loss data provided by First
Marblehead Inc. to form a loss timing curve representative of GATE
loans, which accounts for 65.7% of the collateral pool, and CHELA
loans, which accounts for 34.3% of the collateral pool.  After
giving credit for seasoning of loans in repayment, Fitch applied
the current cumulative gross loss levels to the loss timing curves
of GATE loans and CHELA loans to derive the expected gross losses
of the pool over the remaining life.  A recovery rate of 30% is
applied based on updated recovery data provided by FMD.

Credit enhancement consists of excess spread, a general reserve
fund and cash collateralized guarantees.  Credit enhancement for
the class A notes also includes subordination of the class B
notes.  Fitch assumed excess spread to be the lesser of the
average historical excess spread (earning on the assets minus
interest payments to bondholders, swap payments and fees) and the
most recent 12-month average excess spread, and applied that same
rate over the stressed projection of remaining life.

Given the high default forecasts relative to the remaining pool
balance, the multiples were compressed to achieve through-the-
cycle rating stability.  However, despite the compression,
multiples were indicative of lower ratings for both remaining
classes.  The class B rating is downgraded to the distressed
category since the multiple is lower than one.

As of the end of the October 2010 collection period, the
cumulative default level for GATE portfolio is approximately 8.46%
of the original loan balance and 17.48% for the CHELA portfolio.
The performance of GATE loans are in line with the original
expectations.  However, the default rate for CHELA loans is
substantially higher than what was expected and the trust has not
been able to build parity up to 100%.

Fitch had downgraded these classes of notes issued from National
Collegiate Trust 2006-A:

  -- Class A2 'to 'A-sf' from 'AA+sf'; Outlook Negative;
  -- Class B 'to 'CCsf' from 'BBBsf'.


FLORIDA KEYS: S&P Assigns 'BB+' Rating to Senior Revenue Bonds
--------------------------------------------------------------
Standard & Poor's Rating Services assigned its 'BB+' long term
rating to the Florida Keys College Campus Foundation, Inc., Fla.'s
series 2010 senior leasehold industrial development revenue bonds,
issued on behalf of the Florida Keys Community College Foundation.
The outlook is stable.

"The rating reflects S&P's view of the uncertain demand and rent-
up risk as this is the first and only housing project for the
Florida Keys Community College," said Standard & Poor's credit
analyst Bianca Gaytan-Burrell.  "Further affecting the rating is
the college's large majority of students that attend part-time and
are in state/in county, which could diminish the need for on
campus housing."

Management indicates proceeds from the approximately $8.3 million
bonds will be used to construct a 100-bed dormitory facility on
the Key West campus of FKCC, fund a debt service reserve, and
provide capitalized interest for 12 months.

Florida Keys Community College is a public, two-year institution
established in 1965.  It is the southernmost college in the United
States and has three campuses in Coral Shores, Marathon, and the
main campus in Key West, Fla.  FKCC offers associate's and
bachelor's degrees, and continued education and certificate
programs in some subjects.  The college's niche programs are
marine sciences and diving.


GE COMMERCIAL: S&P Raises Ratings on Various Classes of Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2 and B notes issued by GE Commercial Loan Trust's series 2006-2
and removed them from CreditWatch with positive implications.  S&P
also affirmed its rating on the class C note and removed it from
CreditWatch with positive implications.  In addition, S&P affirmed
its ratings on the class D and preferred trust notes.  At the same
time, S&P affirmed its ratings of the class A-2 and B notes issued
by GE Commercial Loan Trust's series 2006-3 and removed them from
CreditWatch with positive implications.  S&P affirmed its ratings
on the remaining notes from series 2006-3.

Both transactions are cash flow collateralized loan obligation
transactions collateralized in large part by middle market and
syndicated corporate loans.

The two transactions are in their amortization phase, and the
class A-2 notes of both series continue to get paid down.
Following their most recent payment date on Oct. 19, the class A-2
note balance of series 2006-2 is at 7.18% of its original amount,
and the class A-2 note balance of series 2006-3 is at 12.41% of
its original amount.  As a result, the class A-2 note's
overcollateralization ratio increased to 337.4% and 169.8%
respectively (versus 149.3% and 124.0%, respectively, in March
2010, at the time of S&P's last rating action).  The paydowns also
improved the B notes' O/C ratios of the two series; they are
currently at 201.0% and 111.6% respectively (versus 131.2% and
107.5% in March 2010).

Because the classes failed to withstand the specified combination
of underlying asset defaults above their current rating level in
the largest obligor default test, the rating actions were limited
to the levels that could be supported.

                  Rating And Creditwatch Actions

              GE Commercial Loan Trust Series 2006-2

                              Rating
                              ------
       Class            To             From
       -----            --             ----
       A-2              A+ (sf)        BBB+ (sf)/Watch Pos
       B                BBB+ (sf)      BB+ (sf)/Watch Pos

             GE Commercial Loan Trust Series 2006-2

                              Rating
                              ------
       Class            To             From
       -----            --             ----
       C                CCC- (sf)      CCC- (sf)/Watch Pos

             GE Commercial Loan Trust Series 2006-3

                              Rating
                              ------
       Class            To             From
       -----            --             ----
       A-2              BB+ (sf)       BB+ (sf)/Watch Pos
       B                CCC- (sf)      CCC- (sf)/Watch Pos

                        Ratings Affirmed

              GE Commercial Loan Trust Series 2006-2

                     Class            Rating
                     -----            ------
                     D                CC (sf)
                     Pfd Tr Crt       CC (sf)

              GE Commercial Loan Trust Series 2006-3

                     Class            Rating
                     -----            ------
                     C                CC (sf)
                     D                CC (sf)
                     Pfd Tr Crt       CC (sf)


GE COMMERCIAL: S&P Withdraws Ratings on Various Classes of Notes
----------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on the
class A-2, B, and C notes from GE Commercial Loan Trust Series
2006-1, a collateralized loan obligation transaction managed by GE
Commercial Financial Services.  At the same time, S&P lowered its
rating on the preferred trust certificate to 'D (sf)'.

The withdrawals follow the full repayment of the notes on the
Oct. 19, 2010 distribution date.  S&P lowered its rating on the
preferred trust certificates to 'D (sf)' from 'CC (sf)' after the
notes failed to receive a principal distribution in the amount of
their remaining principal balance on the same distribution date.

                        Ratings Withdrawn

              GE Commercial Loan Trust Series 2006-1

                          Rating
                          ------
          Class       To            From
          -----       --            ----
          A-2         NR            BBB+ (sf)/Watch Pos
          B           NR            CCC+ (sf)/Watch Pos
          C           NR            CCC- (sf)/Watch Pos

                          NR - Not rated.

                         Rating Lowered

             GE Commercial Loan Trust Series 2006-1

                                 Rating
                                 ------
                Class       To            From
                -----       --            ----
                Pfd Tr Crt  D (sf)        CC (sf)

  Transaction Information
  -----------------------
Issuer:             GE Commercial Loan Trust Series 2006-1
Collateral manager: GE Commercial Financial Services
Arranger:           Citigroup Global Structured Credit
                    Group
Trustee:            Wells Fargo Bank N.A.
Transaction type:   Cash flow CLO


GMAC COMMERCIAL: S&P Downgrades Ratings on Five 2000-C2 Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
classes of commercial mortgage-backed securities from GMAC
Commercial Mortgage Securities Inc.'s series 2000-C2.  S&P lowered
its ratings on classes J and K to 'D (sf)' and raised its rating
on class D to 'AAA (sf)'.  Concurrently, S&P affirmed its ratings
on three other classes.

The downgrades follow S&P's analysis of interest shortfalls that
have affected the trust.  S&P also considered the susceptibility
of the transaction to future interest shortfalls given the portion
of the collateral that is with the special servicer (14 of the 20
remaining assets, representing 68.7% of the collateral pool).  As
of the October 2010 remittance report, the trust experienced
monthly interest shortfalls totaling $86,052, primarily related to
appraisal subordinate entitlement reduction amounts associated
with eight of these 14 specially serviced assets.  Seven of these
assets had appraisal reduction amounts in effect totaling
$10.9 million, which generated ASERs of $77,585.  Further driving
the interest shortfalls were monthly special servicing fees
($7,937).  The monthly interest shortfalls affected class J, K,
and L, and also reduced the liquidity support available to the
remaining pooled classes.

The upgrade and affirmation of the classes D and E, respectively,
followed S&P's analysis of the remaining collateral in the pool,
the transaction structure, and the liquidity available to the
classes.  S&P affirmed its 'D (sf)' rating for the class L
certificates, which S&P previously downgraded to 'D (sf)' due to
recurring interest shortfalls.  Class L subsequently experienced a
principal loss as of the Oct. 18, 2010, remittance report.  The
class lost 55% of its original balance.  In addition, S&P affirmed
its rating on the class X interest-only certificate based on its
current criteria.

                      Credit Considerations

As of the Oct. 18, 2010, remittance report, 14 assets
($52.6 million; 68.7%) were with the special servicer, Berkadia
Commercial Mortgage LLC.  The payment status of these loans is:
two of these assets are real estate owned ($9.5 million; 12.4%),
three are in foreclosure ($13.3 million; 17.4%), four are 90-plus-
days delinquent ($14.7 million, 19.2%), and five are late but
within their grace periods ($15.1 million; 19.7%).  Seven of the
specially serviced assets have ARAs in effect totaling
$10.9 million.  Eight of the top 10 assets ($43.0 million; 56.1%)
are with the special servicer.  S&P describe the three largest
assets with the special servicer below.

Eastlake Commons, the second-largest asset and largest asset with
the special servicer, has a total exposure of $8.6 million
(10.5%), which includes $608,905 million of advancing and interest
thereon.  The property, which is REO, is a 99,155-sq.-ft. anchored
shopping center in Sterling Heights, Michigan, built in 1988 and
renovated in 1998.  The asset was transferred to the special
servicer on March 13, 2009, due to a payment default and an ARA of
$3.4 million is in effect.  The property is listed with a broker
and is being marketed for sale.  S&P expects a moderate loss upon
the eventual resolution of this asset.

The Lafayette Building loan, the fourth-largest asset and the
second-largest asset with the special servicer, has a total
exposure of $7.6 million (8.9%), which includes $828,162 of
advancing and interest thereon.  The property is an 162,564-sq.-
ft. office building in Philadelphia, Pa., built in 1907 and
renovated in 1990 and 2000.  The asset was transferred to the
special servicer on Jan. 7, 2010, due to a payment default.
Berkadia has indicated that subsequent to the Oct. 19, 2010,
remittance date, the loan was repaid in full.

The Mountain View Shopping Center loan ($6.1 million; 7.9%), the
fifth-largest asset and the third-largest asset with the special
servicer, is secured by a 216,890-sq.-ft. anchored shopping center
in Ardmore, Ok., built in 1980.  The loan, which is in the process
of being extended for two years, was transferred to the special
servicer due to a maturity default as of April 1, 2010.  An ARA of
$1.5 million is in effect.  For year-end 2008, the reported DSC
and occupancy were 1.01x and 87%, respectively.  The June 30,
2010, rent roll reflects a 62% occupancy, and after considering a
new lease to Big Lots (26,432 sq. ft.; 12.2%), S&P estimates a
current DSC of 0.58x.

The 11 remaining specially serviced assets ($31.8 million, 41.5%)
have balances that individually represent less than 7.0% of the
total pool balance.  S&P separately estimated losses for nine of
these assets, resulting in a weighted average loss severity of
33.0%.  The remaining two assets are matured loans.  The borrower
and special servicer are discussing a forbearance agreement for
the larger loan ($5.3 million; 6.9%), and the special servicer
recently executed a forbearance agreement on the small loan
($1.7 million; 2.2%).

                       Transaction Summary

As of the Oct. 12, 2010, remittance report, the transaction had an
aggregate trust balance of $76.6 million (20 loans), compared with
a $773.8 million trust balance (130 loans) at issuance.  The
master servicer, also Berkadia, provided either full-year 2008 or
full-year 2009 financial information for 86.6% of the assets in
the pool.  S&P calculated a weighted average DSC of 1.20x based on
the reported figures.  The master servicer's watchlist consists of
two loans (none of which are defeased) ($11.6 million; 15.1%).
The trust has experienced $18.6 million of principal losses to
date on 14 loans.

                     Summary Of Top 10 Loans

The top 10 assets have an aggregate outstanding trust balance of
$59.1 million (77.2%).  Using servicer-reported information, S&P
calculated a weighted average DSC of 1.09x.  In addition to the
eight top 10 assets with the special servicer, one of the top 10
assets appears on the master servicer's watchlist and is discussed
below.

The O'Herron Portfolio loan ($9.1 million; 11.9%) is the largest
asset and is secured by five cross-collateralized and cross-
defaulted anchored retail properties totaling 239,324 sq. ft. The
portfolio includes a 57,950-sq.-ft. property in Vinton, Va., built
in 1988, a 49,110-sq.-ft. property in Wendell, N.C., built in 1992
and renovated in 1999; a 49,064-sq.-ft. property in Conover, N.C.,
built in 1986; a 43,320-sq.-ft. property in Laurinburg, N.C.,
built in 1988; and a 39,880-sq.-ft. property in Denver, N.C.,
built in 1990 and renovated in 1997.  This loan appears on the
master servicer's watchlist due to a low DSC.  The reported DSC
was 1.13x for year-end 2009, while the reported occupancy was 94%
as of September 2010.  Based on the current leasing status, S&P
estimate a similar DSC.

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

                         Ratings Lowered

             GMAC Commercial Mortgage Securities Inc.
   Commercial mortgage pass-through certificates series 2000-C2

                  Rating
                  ------
     Class     To          From       Credit enhancement (%)
     -----     --          ----       ----------------------
     F         BBB- (sf)   BBB+ (sf)                   61.62
     G         B- (sf)     BB+ (sf)                    28.79
     H         CCC- (sf)   BB (sf)                     21.21
     J         D (sf)      B+ (sf)                     13.63
     K         D (sf)      CCC (sf)                     2.26

                          Rating Raised

             GMAC Commercial Mortgage Securities Inc.
  Commercial mortgage pass-through certificates series 2000-C2

                     Rating
                     ------
         Class    To       From   Credit enhancement (%)
         -----    --       ----   ----------------------
         D        AAA(sf)  AA (sf)                 99.52

                        Ratings Affirmed

             GMAC Commercial Mortgage Securities Inc.
  Commercial mortgage pass-through certificates series 2000-C2

             Class     Rating   Credit enhancement (%)
             -----     ------   ----------------------
             E         A-(sf)                    74.25
             L         D (sf)                     0.00
             X         AAA (sf)                    N/A

                       N/A - Not applicable.


GRAYSTON CLO: Moody's Upgrades Ratings on Various Classes
---------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Grayston CLO II 2004-1 Ltd.:

  -- US$283,750,000 Class A-1L Floating Rate Notes Due August 2016
     (current outstanding balance of $162,116,605), Upgraded to
     Aaa (sf); previously on July 23, 2009 Downgraded to Aa2 (sf);

  -- US$20,000,000 Class A-2L Floating Rate Notes Due August 2016,
     Upgraded to Aa3 (sf); previously on July 23, 2009 Downgraded
     to A3 (sf);

  -- US$24,500,000 Class A-3L Floating Rate Notes Due August 2016,
     Upgraded to Baa3 (sf); previously on July 23, 2009 Confirmed
     at Ba1 (sf);

  -- US$16,750,000 Class B-1LA Floating Rate Notes Due August
     2016, Upgraded to B2 (sf); previously on July 23, 2009
     Downgraded to B3 (sf).

                        Ratings Rationale

According to Moody's, the rating actions taken on the notes result
primarily from the delevering of the Class A Notes, which have
been paid down by approximately 43% or $122 million since the last
rating action in July 2009.  As a result of the delevering, the
overcollateralization ratios have increased.  As of the latest
trustee report dated October 14, 2010, the Senior Class A, Class A
and Class B-1LA overcollateralization ratios are reported at
130.99%, 115.45% and 106.8%, respectively, versus July 2009 levels
of 119.94%, 110.98% and 105.6%, respectively.

Moody's also notes that the credit profile of the underlying
portfolio has been relatively stable since the last rating action.
Based on the October 2010 trustee report, the weighted average
rating factor is 2917 compared to 2935 in July 2009.  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." The deal
also experienced a decrease in defaults.  In particular, the
dollar amount of defaulted securities has decreased to about
$4 million from approximately $14.6 million 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 $232.5 million, defaulted par of $9.3 million,
weighted average default probability of 23.53% (implying a WARF of
3632), a weighted average recovery rate upon default of 44.31%,
and a diversity score of 37.  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.

Grayston CLO II 2004-1 Ltd., issued in June 2004, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

The principal methodology used in this rating was the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.  Other methodologies and
factors that may have been considered in the process of rating
this issuer can also be found on Moody's website.
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% (2906)

  -- Class A-1L: 0
  -- Class A-2L: +2
  -- Class A-3L: +2
  -- Class B-1LA: +2

Moody's Adjusted WARF + 20% (4358)
  -- Class A-1L: -1
  -- Class A-2L: -2
  -- Class A-3L: -1
  -- Class B-1LA: -3

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% (46.31%)

  -- Class A-1L: 0
  -- Class A-2L: 0
  -- Class A-3L: 0
  -- Class B-1LA: 0

Moody's Adjusted WARR - 2% (42.31%)

  -- Class A-1L: 0
  -- Class A-2L: 0
  -- Class A-3L: -1
  -- Class B-1LA: 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 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) 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.


GREENPOINT HOME: Moody's Downgrades Ratings on 11 Tranches
----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 11
tranches and confirmed the ratings of five tranches from nine RMBS
transactions issued by GreenPoint Home Equity Loan Trust and
Greenpoint Mortgage Funding Trust.  The collateral backing these
deals primarily consists of closed end second lien loans and home
equity lines of credit.

                        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.  Class Ac issued by
Greenpoint Mortgage Funding Trust 2006-HE1 is wrapped by CIFG
Assurance North America, Inc. (Rating Withdrawn).  RMBS securities
wrapped by CIFG Assurance North America, Inc. are rated at their
underlying rating without consideration of the respective
guaranties.

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-
1 and class M-2 from Greenpoint Mortgage Funding Trust 2005-HE2
and Class IA-1, IIA-1a, IIA-1b, IIA-3c, IIA-4c from Greenpoint
Mortgage Funding Trust 2005-HE4, for each of which model implied
results would be one notch lower (for example, Ba2 versus Ba1, or
Ca versus Caa3).

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: GreenPoint Home Equity Loan Trust 2004-1

  * Expected Losses (as a % of Original Balance): 3%

  -- Cl. A, Confirmed at Caa2 (sf); previously on April 16, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

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

Issuer: GreenPoint Home Equity Loan Trust 2004-2

  * Expected Losses (as a % of Original Balance): 4%

  -- Cl. A-1, Downgraded to Caa2 (sf); previously on March 18,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. A-2, Downgraded to Caa2 (sf); previously on March 18,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

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

Issuer: GreenPoint Home Equity Loan Trust 2004-3

  * Expected Losses (as a % of Original Balance): 5%

  -- Cl. A, Confirmed at Caa3 (sf); previously on April 16, 2010
     Downgraded to Caa3 (sf) and Placed Under Review for Possible
     Downgrade

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

Issuer: GreenPoint Home Equity Loan Trust 2004-4

  * Expected Losses (as a % of Original Balance): 5%

  -- Cl. A, Downgraded to Caa3 (sf); previously on March 18, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

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

Issuer: Greenpoint Mortgage Funding Trust 2005-HE2

  * Expected Losses (as a % of Original Balance): 14%

  -- Cl. M-1, Downgraded to Ba2 (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
     Caa3 (sf) Placed Under Review for Possible Downgrade

Issuer: Greenpoint Mortgage Funding Trust 2005-HE3

  * Expected Losses (as a % of Original Balance): 15%

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

  -- Underlying Rating: Downgraded to Ca (sf); previously on Mar
     18, 2010 Caa3 (sf) Placed Under Review for Possible Downgrade

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

Issuer: Greenpoint Mortgage Funding Trust 2005-HE4

  * Expected Losses (as a % of Original Balance): Group 1 25%,
    Group 2 24%

  -- Cl. IA-1, Downgraded to B1 (sf); previously on March 18, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IIA-1a, Downgraded to B1 (sf); previously on March 18,
     2010 Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IIA-1b, Confirmed at Baa1 (sf); previously on March 18,
     2010 Baa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IIA-3c, Confirmed at Baa1 (sf); previously on March 18,
     2010 Baa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IIA-4c, Downgraded to B1 (sf); previously on March 18,
     2010 Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. M-1, Downgraded to Caa3 (sf); previously on March 18,
     2010 Ba2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. M-2, Downgraded to C (sf); previously on March 18, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

Issuer: Greenpoint Mortgage Funding Trust 2006-HE1

  * Expected Losses (as a % of Original Balance): 53%

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

  -- Financial Guarantor: CIFG Assurance North America, Inc.
      (Insured Rating Withdrawn Nov 12, 2009)

Issuer: Greenpoint Mortgage Funding Trust 2007-HE1, Mortgage-
Backed Notes, Series 2007-HE1

  * Expected Losses (as a % of Original Balance): 72%

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

  -- Underlying Rating: Confirmed at Ca (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)


GSC CAPITAL: Moody's Downgrades Ratings on Three Tranches
---------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 3 tranches
from 2 RMBS transactions issued by GSC Capital Corp.  The
collateral backing these deals primarily consists of first-lien,
adjustable rate Alt-A residential mortgages.

                        Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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: GSC Capital Corp. Mortgage Trust 2006-1

  -- Cl. A-1, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

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

Issuer: GSC Capital Corp. Mortgage Trust 2006-2

  -- Cl. A-1, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade


HSI ASSET: Moody's Downgrades Ratings on Six 2007-WF1 Tranches
--------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 6 tranches
from HSI Asset Loan Obligation Trust 2007-WF1.  The collateral
backing this deal primarily consists of first-lien, fixed rate
Alt-A residential mortgages.

                        Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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: HSI Asset Loan Obligation Trust 2007-WF1

  -- Cl. A-1, Downgraded to Ba3 (sf); previously on Jan. 14, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-2, Downgraded to Caa2 (sf); previously on Jan. 14, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-3, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-4, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-5, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-6, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade


JEFFERSON COUNTY: Moody's Affirms 'Ba3' Rating to Housing Bondss
---------------------------------------------------------------
Moody's Investors Service has affirmed the Ba3 rating on
$434,728.75 of outstanding Jefferson County Assisted Housing
Corporation, First Mortgage Refunding Housing Revenue Bonds
(Spring Gardens Project) Series 1999.  The outlook on the bonds
remains negative.

Spring Gardens is a 100 - unit housing property located in
Jefferson County, Alabama.  The property contains 98 one-bedroom
apartments and 2 two-bedroom apartments.  It is intended for low-
income elderly and disabled tenants.  In October 2005, a fire
destroyed the property's community center.  It was rebuilt and
opened in the first half of this year (2010).  The funds for the
rebuild came from insurance proceeds and $2 million from the
Jefferson Affordable Housing Initiative.  The Jefferson Affordable
Housing Initiative also funds the full-time positions of a
registered nurse and social worker for the benefit of Spring
Gardens residents.

                            Strengths

* Fully funded debt service reserve fund as of October, 2010

* 90% occupancy rate as of March, 2010

* Relatively short time until bond maturity in 12/1/2011

* Rental rates are well below Fair Market Rent, making future
  increases in rental rates possible.

                            Challenges

* Debt service coverage levels continue to deteriorate.  Audited
  financial statements show debt service coverage levels have
  declined from 1.00x (FY2006) to 0.82 (FY2007) to 0.69x (FY2008)
  to .65X(FY2009).  The most recent debt service coverage level is
  in line with other Moody's rated properties in the Ba3 rating
  category.

* Rents have not increased since 2008 and occupancy has dropped
  from 95% to 90%.  These two factors show why there has been a
  further decline in debt service coverage levels.

* HAP contract expires before bond maturity.  Preserving the
  balance in the debt service reserve fund takes on additional
  importance when the HAP contract expires before maturity and the
  debt service coverage is below 1.00x. Though the HAP contract is
  expected to be renewed by HUD, the current HAP contract expires
  five months before bond maturity.  The expiration of the current
  contract could reduce rental revenue if not renewed in a timely
  manner.

                  What Could Move The Rating - Up

* Significant increase in debt service coverage

                 What Could Move The Rating - Down

* A further decrease in debt service coverage

                             Outlook

The outlook on the bonds remains negative due to the continued
decline in debt service coverage and the potential for draws on
the debt service reserve fund.

                          Key Statistics

* Current Occupancy: 90%
* Bond Maturity: 12/1/2011
* HAP Expiration: 6/30/2011
* Debt Service Coverage (FY2009): 0.65x
* Average Rent as % of FMR: 66%


JEFFERIES MILITARY: DBRS Assigns B Rating on Hunter Project Certs.
------------------------------------------------------------------
DBRS has assigned provisional ratings to the classes of Jefferies
Military Housing Trust, Series 2010-XLII.  The trend is Stable.

HUNTER Project Certificates Series 2010A at B (sf)

The collateral for the transaction consists of the residual cash
flow interests from 12 U.S. military housing projects located at
11 bases, along with the property management and asset management
fees from eight of the 12 projects.  The loan is sponsored by Hunt
Companies of El Paso, Texas, who is a leader in the military
privatization market, having developed over 31,000 units for the
Department of Defense under the Military Housing Privatization
Initiative.  In addition to the $90 million loan, which is being
contributed to the trust, there is currently a total of
$839 million in senior securitized loans and $344 million of
government direct loans outstanding that are also secured by the
leasehold interests in the 12 projects.  The senior securitized
loans and the government direct loans are senior in priority to
the transaction's $90 million underlying loan.

The loan benefits from sponsors and property management that have
significant experience with the specialized nature of the
collateral and a stable source of revenue provided by the basic
allowance for housing (BAH) from servicmember occupants.  While
the loan's collateral is deeply subordinated within each of the
subject property's payment priority waterfalls, DBRS assumed
annual growth rates in BAH that are a fraction of the portfolio's
actual historical BAH growth rate.  In addition, the transaction's
structure features trap cash both at the loan level and at the
Grantor Trust level, which is designed to benefit the Series 2010A
certificates.  The Series 2010 I/0 certificate is fully
subordinated to the Series 2010A note, and in the event that the
loan's DSCR is less than 1.0x, funds otherwise payable to the
Series 2010 I/O certificate will be trapped for the benefit of the
Series 2010A certificates.


JOHNSON CITY: Moody's Downgrades Ratings on Revenue Bonds to 'Ba3'
------------------------------------------------------------------
Moody's Investors Service has downgraded to Ba3 from Aaa the
refunded Health and Educational Facilities Board of the Johnson
City's (Tennessee) Hospital Revenue Refunding and Improvement
Bonds (Johnson City Medical Center Hospital), Series 1991 and
1998C.  The outlook is negative.  The rating downgrade is based on
the quality of investments and the escrow structure.  The escrow
funds are invested in these:

1.  Investment agreement with MBIA Inc. (rated Ba3 with a negative
    outlook)

2.  Health and Educational Facilities Board of the City of Johnson
    City's (Tennessee), Hospital First Mortgage Revenue Bonds,
    Series 2000C (insured rating of Baa1)

3.  Mountain States Health Alliance's First Mortgage Bonds, Series
    2000D (insured rating of Baa1)

The Ba3 rating on the refunded bonds reflects the credit quality
of the investment agreement provider.  At the time the refunded
bonds were rated, the investment agreement and insured rating on
the investments were Aaa.

This is a list of outstanding bonds affected:

* The Health and Educational Facilities Board of the City of
  Johnson City, Tennessee, Hospital Revenue Refunding and
  Improvement Bonds, Series 1991 (Johnson City Medical Center
  Hospital), dated August 1, 1991, term bonds due July 1, 2016,
  escrowed to maturity.  CUSIP#: 478271 FE4.  Amount refunded:
  $12,020,000.

* The Health and Educational Facilities Board of the City of
  Johnson City, Tennessee, Hospital Revenue Refunding and
  Improvement Bonds, Series 1998C (Johnson City Medical Center
  Hospital), dated December 1, 1998, term bonds due July 1, 2025,
  escrowed to maturity.  CUSIP#: 478271 FG9.  Amount refunded:
  $59,565,000.

* The Health and Educational Facilities Board of the City of
  Johnson City, Tennessee, Hospital Revenue Refunding and
  Improvement Bonds, Series 1998C (Johnson City Medical Center
  Hospital), dated December 1, 1998, term bonds due July 1, 2028,
  escrowed to maturity.  CUSIP#: 478271DC0.  Amount refunded:
  $75,105,000.


JP MORGAN: Moody's Downgrades Ratings on 17 Tranches
----------------------------------------------------
Moody's Investors Service has downgraded the ratings of 17
tranches and confirmed the rating of 1 tranche from 2 RMBS
transactions, issued by J.P. Morgan Mortgage Acquisition Trust.
The collateral backing these deals primarily consists of first-
lien, fixed and adjustable-rate subprime residential mortgages.

Issuer: J.P.  Morgan Mortgage Acquisition Corp. 2006-CW1

  -- Cl. A-1A, Downgraded to Aa3 (sf); previously on Jan 13, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-1B, Downgraded to B1 (sf); previously on Jan 13, 2010
     A2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-4, Downgraded to Ba3 (sf); previously on Jan 13, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-5, Downgraded to Caa1 (sf); previously on Jan 13, 2010
     Ba2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. M-1, Downgraded to C (sf); previously on Jan 13, 2010 B1
      (sf) Placed Under Review for Possible Downgrade

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

Issuer: J.P.  Morgan Mortgage Acquisition Trust 2006-CW2

  -- Cl. AF-2, Downgraded to Ba1 (sf); previously on Jan 13, 2010
     A2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-3, Downgraded to Caa3 (sf); previously on Jan 13, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. AF-5, Downgraded to Ca (sf); previously on Jan 13, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-6, Downgraded to Ca (sf); previously on Jan 13, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. MV-1, Downgraded to Ca (sf); previously on Jan 13, 2010
     Ba3 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. MV-3, Downgraded to C (sf); previously on Jan 13, 2010 Ca
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. AV-1, Downgraded to B1 (sf); previously on Jan 13, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AV-3, Confirmed at Aaa (sf); previously on Jan 13, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. AV-4, Downgraded to B1 (sf); previously on Jan 13, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AV-5, Downgraded to Caa2 (sf); previously on Jan 13, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

                        Ratings Rationale

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

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

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.

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.


JP MORGAN: Moody's Reviews Ratings on Nine 2003-LN1 Certificates
----------------------------------------------------------------
Moody's Investors Service placed nine classes of JP Morgan Chase
Commercial Mortgage Securities Corp., Commercial Mortgage Pass-
Through Certificates, Series 2003-LN1 on review for possible
downgrade:

  -- Cl. F, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 26, 2007 Upgraded to A3 (sf)

  -- Cl. G, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 9, 2003 Definitive Rating Assigned Baa2
      (sf)

  -- Cl. H, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 9, 2003 Definitive Rating Assigned Baa3
      (sf)

  -- Cl. J, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 9, 2003 Definitive Rating Assigned Ba1
     (sf)

  -- Cl. K, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 9, 2003 Definitive Rating Assigned Ba2
     (sf)

  -- Cl. L, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 9, 2003 Definitive Rating Assigned Ba3
     (sf)

  -- Cl. M, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 9, 2003 Definitive Rating Assigned B1 (sf)

  -- Cl. N, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 9, 2003 Definitive Rating Assigned B2 (sf)

  -- Cl. P, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Oct. 9, 2003 Definitive Rating Assigned B3 (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 July 26, 2007.  Please see
the ratings tab on the issuer / entity page on moodys.com for the
last rating action and the ratings history.

                   Deal And Performance Summary

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 21.8% to
$983 million from $1.3 billion at securitization.  The
Certificates are collateralized by 165 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 26% of the pool.  Twenty-one loans, representing 17%
of the pool have defeased and collateralized with U.S. Government
securities.  Defeasance at last was represented by 18 loans, or
14% of the pool.

Forty-one loans, representing 25% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the 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 a $23.3 million aggregate loss.
Currently two loans, representing 0.4% of the pool, are in special
servicing.  The master servicer has recognized an aggregate
$2.6 million appraisal reduction for two 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 15 2004-LN2 Certificates
--------------------------------------------------------------
Moody's Investors Service placed 15 classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp., Commercial Mortgage Pass-
Through Certificates, Series 2004-LN2, on review for possible
downgrade:

  -- Cl. A-2, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Aug. 23, 2004 Definitive Rating Assigned Aaa
      (sf)

  -- Cl. A-1A, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Aug. 23, 2004 Definitive Rating
     Assigned Aaa (sf)

  -- Cl. B, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Aug. 23, 2004 Definitive Rating Assigned Aa2
      (sf)

  -- Cl. C, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Aug. 23, 2004 Definitive Rating Assigned Aa3
     (sf)

  -- Cl. D, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Aug. 23, 2004 Definitive Rating Assigned A2
     (sf)

  -- Cl. E, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Aug. 23, 2004 Definitive Rating Assigned A3
     (sf)

  -- Cl. F, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Aug. 23, 2004 Definitive Rating Assigned Baa1
      (sf)

  -- Cl. G, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Jan. 8, 2009 Downgraded to Ba1 (sf)

  -- Cl. H, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Jan. 8, 2009 Downgraded to Ba2 (sf)

  -- Cl. J, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Jan. 8, 2009 Downgraded to B1 (sf)

  -- Cl. K, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Jan. 8, 2009 Downgraded to B2 (sf)

  -- Cl. L, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Jan. 8, 2009 Downgraded to B3 (sf)

  -- Cl. M, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Jan. 8, 2009 Downgraded to Caa1 (sf)

  -- Cl. N, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Jan. 8, 2009 Downgraded to Caa2 (sf)

  -- Cl. P, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Jan. 8, 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 January 8, 2009.

                   Deal And Performance Summary

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 19% to
$1.01 billion from $1.25 billion at securitization.  The
Certificates are collateralized by 156 mortgage loans ranging in
size from less than 1% to 7% of the pool.

Forty loans, representing 31% 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.

Eight loans have been liquidated from the trust since
securitization, resulting in a $11.5 million loss (65% loss
severity).  Currently 14 loans, representing 13% of the pool, are
in special servicing.  The largest specially serviced loan is the
Countryside Apartments loan ($22.7 million -- 2.2%), which was
transferred to special servicing in January 2010.  The master
servicer has recognized an aggregate $26.7 million appraisal
reduction for eight 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 15 2005-CIBC12 Certs.
-----------------------------------------------------------
Moody's Investors Service placed 15 classes of J.P. Morgan
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2005-CIBC12 on review for possible downgrade:

  -- Cl. A-M, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 29, 2005 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. A-J, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to Aa1 (sf)

  -- Cl. B, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to Aa3 (sf)

  -- Cl. C, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to A1 (sf)

  -- Cl. D, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to A3 (sf)

  -- Cl. E, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to Baa1 (sf)

  -- Cl. F, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to Baa3 (sf)

  -- Cl. G, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to Ba2 (sf)

  -- Cl. H, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to Ba3 (sf)

  -- Cl. J, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to B1 (sf)

  -- Cl. K, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to B2 (sf)

  -- Cl. L, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to Caa1 (sf)

  -- Cl. M, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to Caa2 (sf)

  -- Cl. N, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 2009 Downgraded to Caa3 (sf)

  -- Cl. P, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 16, 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 July 16, 2009.

                   Deal And Performance Summary

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 10% to
$2.00 billion from $2.22 billion at securitization.  The
Certificates are collateralized by 185 mortgage loans ranging in
size from less than 1% to 5% of the pool, with the top ten loans
representing 26% of the pool.

Thirty-three loans, representing 13% 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.

Seven loans have been liquidated from the pool, resulting in an
aggregate realized loss of $21.5 million (45% loss severity
overall).  Twenty-five loans, representing 15% of the pool, are
currently in special servicing.  The specially serviced loans are
secured by a mix of multifamily, office, retail, industrial and
mixed use property types.  The servicer has recognized appraisal
reductions totaling $82.7 million from 18 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 18 2005-LDP2 Certificates
---------------------------------------------------------------
Moody's Investors Service placed 18 classes of J.P. Morgan
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2005-LDP2, on review for possible downgrade:

  -- Cl. A-M, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 5, 2005 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. A-MFL, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on July 5, 2005 Definitive Rating
     Assigned Aaa (sf)

  -- Cl. A-J, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 5, 2005 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. B, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 5, 2005 Definitive Rating Assigned Aa1
     (sf)

  -- Cl. C, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 5, 2005 Definitive Rating Assigned Aa2
     (sf)

  -- Cl. D, Aa3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 5, 2005 Definitive Rating Assigned Aa3
     (sf)

  -- Cl. E, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 5, 2005 Definitive Rating Assigned A1 (sf)

  -- Cl. F, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on July 5, 2005 Definitive Rating Assigned A2 (sf)

  -- Cl. G, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on July 5, 2005 Definitive Rating Assigned A3 (sf)

  -- Cl. H, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on July 5, 2005 Definitive Rating Assigned Baa1
      (sf)

  -- Cl. J, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on June 5, 2009 Downgraded to Ba1 (sf)

  -- Cl. K, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on June 5, 2009 Downgraded to Ba3 (sf)

  -- Cl. L, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on June 5, 2009 Downgraded to B2 (sf)

  -- Cl. M, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on June 5, 2009 Downgraded to B3 (sf)

  -- Cl. N, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on June 5, 2009 Downgraded to Caa1 (sf)

  -- Cl. O, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on June 5, 2009 Downgraded to Caa2 (sf)

  -- Cl. P, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on June 5, 2009 Downgraded to Caa3 (sf)

  -- Cl. Q, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on June 5, 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 25, 2010.

                   Deal And Performance Summary

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 14% to
$2.57 billion from $2.98 billion at securitization.  The
Certificates are collateralized by 268 mortgage loans ranging in
size from less than 1% to 5% of the pool.

Seventy 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.

Fourteen loans have been liquidated from the trust since
securitization, resulting in a $25.3 million loss (37% loss
severity).  Currently 25 loans, representing 13% of the pool, are
in special servicing.  The largest specially serviced loan is the
Cross Creek Crossing Center loan ($45.8 million -- 1.8%), which
was transferred to special servicing in January 2010.  The master
servicer has recognized an appraisal reduction of $32.6 million
for this loan and an aggregate $78.2 million appraisal reduction
for nine of the specially serviced loans.

Based on the most recent remittance statement, Classes K through Q
have cumulative interest shortfalls totaling $2.6 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.


JP MORGAN: Moody's Reviews Ratings on 2006-CIBC15 Certificates
--------------------------------------------------------------
Moody's Investors Service placed 15 classes of J.P. Morgan
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2006-CIBC15 on review for possible downgrade:

  -- Cl. A-M, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on July 12, 2006 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. A-J, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to A2 (sf)

  -- Cl. B, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to Baa1 (sf)

  -- Cl. C, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to Baa2 (sf)

  -- Cl. D, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to Ba1 (sf)

  -- Cl. E, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to Ba2 (sf)

  -- Cl. F, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to B1 (sf)

  -- Cl. G, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to B2 (sf)

  -- Cl. H, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to B3 (sf)

  -- Cl. J, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to Caa2 (sf)

  -- Cl. K, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to Caa2 (sf)

  -- Cl. L, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to Caa3 (sf)

  -- Cl. M, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to Caa3 (sf)

  -- Cl. N, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to Ca (sf)

  -- Cl. P, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 12, 2009 Downgraded to Ca (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 12, 2009.

                   Deal And Performance Summary

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 4% to $2.03 billion
from $2.12 billion at securitization.  The Certificates are
collateralized by 121 mortgage loans ranging in size from less
than 1% to 15% of the pool, with the top ten loans representing
43% of the pool.

Thirty-nine loans, representing 19% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (formerly 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 $14.4 million (98% loss severity).  Nine loans,
representing 16% of the pool, are currently in special servicing.
The specially serviced loans are secured by a mix of multifamily,
office, retail and industrial property types.  The servicer has
recognized appraisal reductions totaling $111.3 million from eight
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 15 2006-CIBC17 Certs.
-----------------------------------------------------------
Moody's Investors Service placed 15 classes of J.P. Morgan
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2006-CIBC17 on review for possible downgrade:

  -- Cl. A-M, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 20, 2007 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, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa1 (sf)

  -- Cl. K, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa1 (sf)

  -- Cl. L, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa2 (sf)

  -- Cl. M, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa2 (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 2% to $2.50 billion
from $2.54 billion at securitization.  The Certificates are
collateralized by 150 mortgage loans ranging in size from less
than 1% to 11% of the pool, with the top ten loans representing
46% of the pool.

Thirty-eight loans, representing 28% of the pool, are on the
master servicer's watchlist.  The watchlist includes loans which
meet certain portfolio review guidelines established as part of
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 deal performance.

One loan has been liquidated from the pool, resulting in a
realized loss of $1.3 million (26% loss severity).  Fourteen
loans, representing 9% of the pool, are currently in special
servicing.  The specially serviced loans are secured by a mix of
multifamily, office, retail and hotel property types.  The
servicer has recognized an aggregate $69.1 million appraisal
reduction for 12 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.


KATONAH IV: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B, C, D-1, and D-2 notes from Katonah IV Ltd., a collateralized
loan obligation transaction managed by Sankaty Advisors LLC.  At
the same time, S&P removed its rating on the class A notes from
CreditWatch with positive implications.

The upgrades reflect the improved performance S&P has observed in
the underlying portfolio since January 2010 when S&P lowered the
ratings on all the notes following a review of the transaction
under S&P's updated criteria for rating corporate collateralized
debt obligations.

According to the Dec. 18, 2009, trustee report, the transaction
was holding approximately $26.4 million in defaulted obligations
and $55.8 million in underlying obligors with a rating, either by
Standard & Poor's or another rating agency, in the 'CCC+' or lower
range.  As of the Sept. 12, 2010, trustee report, those values
were significantly lower at $8.9 million and $40.3 million,
respectively.  With the strengthening of the corporate market,
many of the defaulted obligors were sold at prices much higher
than the recovery values assigned based on the transaction
documents.  To date, the Katonah IV Ltd. transaction has paid down
the class A notes to approximately 45% of its original outstanding
balance, including $59.16 million since the beginning of the year.

The reductions in the defaulted and 'CCC+' or lower assets, and
the $59.16 million paydown on the class A notes has reduced the
overall credit risk for the remaining outstanding notes.
Moreover, S&P based its previous rating actions on the class C, D-
1, and D-2 notes on the largest-obligor default test.  The
supplemental test did not drive its current actions on these
classes.

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

                         Katonah IV Ltd.

                                 Ratings
                                 -------
      Class                   To           From
      -----                   --           ----
      A                       AAA(sf)      AA+(sf)/Watch Pos
      B                       AA-(sf)      BBB+(sf)
      C                       BBB(sf)      B+(sf)
      D-1                     BB+(sf)      CCC+(sf)
      D-2                     BB+(sf)      CCC+(sf)


KIMBERLITE CDO: Fitch Affirms Ratings on Eight Classes of Notes
---------------------------------------------------------------
Fitch Ratings has affirmed eight classes of notes issued by
Kimberlite CDO I Ltd./LLC.  The notes are affirmed at 'C' as a
result of continued negative credit migration within the reference
portfolio.

Since Fitch's last rating action in December 2009, approximately
34.5% of the portfolio has been downgraded, and 6% is currently on
Rating Watch Negative.  Approximately 93.3% of the portfolio has a
Fitch derived rating below investment grade and 55.9% has a rating
in the 'CCC' rating category or lower, compared to 89.3% and
26.8%, respectively, at last review.  Defaulted securities, as
defined in the transaction's governing documents, now comprise
13.8% of the portfolio, compared to 4.7% at last review.

The transaction entered an Event of Default on Nov. 13, 2009 when
the ratio of the net outstanding portfolio balance over the sum of
the super senior notional amount and the outstanding amount of the
class A notes failed the 100% threshold.  The test failure was due
to downgrades to the underlying collateral and the application of
the documented overcollateralization haircuts to assets rated
'BB-' and below.

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, all classes have been affirmed at
'C'.  While the classes A and B notes are receiving timely
interest distributions, the notional balance of the super senior
notes relative to the performing portion of the portfolio makes it
unlikely for the class A notes to receive any principal repayment.
The class C through H notes are receiving interest paid in kind
whereby the principal amount of the notes is written up by the
amount of interest due.  Fitch does not expect these classes to
receive any future payments.

Kimberlite CDO I is a hybrid commercial real estate collateralized
debt obligation that closed on Sept. 28, 2006.  Kimberlite CDO I
combines the use of synthetic and cash assets, as well as unfunded
and funded liabilities.  The unfunded super senior class is senior
to the funded liabilities and is not rated by Fitch.

Fitch has affirmed these classes:


  -- $79,375,000 Class A at 'Csf';
  -- $40,125,000 Class B at 'Csf';
  -- $46,583,518 Class C at 'Csf';
  -- $10,317,264 Class D at 'Csf';
  -- $9,950,174 Class E at 'Csf';
  -- $11,935,579 Class F at 'Csf';
  -- $12,432,646 Class G at 'Csf';
  -- $23,113,287 Class H at 'Csf'.


KINGSLAND II: 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 Kingsland II, Ltd:

  -- US$8,000,000 Class A-2 Senior Secured Floating Rate Notes due
     2021, Upgraded to A3 (sf); previously on October 1, 2009
     Downgraded to Baa1 (sf);

  -- US$29,200,000 Class B Senior Secured Deferrable Floating Rate
     Notes due 2021, Upgraded to Ba1 (sf); previously on
     October 1, 2009 Downgraded to Ba2 (sf);

  -- US$27,525,000 Class C Senior Secured Deferrable Floating Rate
     Notes due 2021, Upgraded to Caa1 (sf); previously on
     October 1, 2009 Downgraded to Caa2 (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 October 2009.  In
Moody's view, these positive developments coincide with
reinvestment of principal proceeds (including higher than
previously anticipated recoveries realized on defaulted
securities) into substitute assets with higher par amounts and/or
higher ratings.

Improvement in the credit quality is observed through an
improvement in the average credit rating (as measured by the
weighted average rating factor) and a decrease in the proportion
of securities from issuers rated Caa1 and below.  In particular,
as of the latest trustee report dated October 11, 2010, the
weighted average rating factor is currently 2342 compared to 2679
in the September 2009 report, and securities rated Caa1 or lower
make up approximately 6.45% of the underlying portfolio versus
11.44% in September 2009.  Additionally, defaulted securities
total about $6.5 million of the underlying portfolio compared to
$20.8 million in September 2009.

The overcollateralization ratios of the rated notes have also
improved since the last rating action.  The Class A, Class B,
Class C and Class D overcollateralization ratios are reported at
126.24%, 115.78%, 107.40% and 105.73%, respectively, versus
September 2009 levels of 120.59%, 110.61%, 102.60% and 101.01%,
respectively, and all related overcollateralization tests are
currently in compliance.

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 balance,
including principal proceeds, of $406 million, defaulted par of
$6.7 million, weighted average default probability of 29.49%
(implying a WARF of 3723), a weighted average recovery rate upon
default of 41.07%, and a diversity score of 45.  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.

Kingsland II, Ltd., issued in April 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.

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, whereby a positive difference corresponds to lower
expected losses), assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2978)

  -- Class A1: +2
  -- Class A2: +2
  -- Class B: +2
  -- Class C: +3
  -- Class D: +1

Moody's Adjusted WARF + 20% (4468)

  -- Class A1: -1
  -- Class A2: -2
  -- Class B: -2
  -- Class C: -3
  -- Class D: -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, whereby a positive difference
corresponds to lower expected losses), assuming that all other
factors are held equal:
Moody's Adjusted WARR + 2% (43.07%)

  -- Class A1: +1
  -- Class A2: 0
  -- Class B: 0
  -- Class C: 0
  -- Class D: 0

Moody's Adjusted WARR - 2% (39.07%)

  -- Class A1: 0
  -- Class A2: -1
  -- Class B: -1
  -- Class C: -1
  -- Class D: 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 behavior, 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities and 3) potential additional
expected loss associated with swap agreements in CDOs as a result
of recent U.S. bankruptcy court ruling on Lehman swap termination
in the Dante case.

Sources of additional performance uncertainties are described
below:

1) 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.

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 deal's
   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) 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 worse
   of reported and covenanted values for weighted average rating
   factor, weighted average spread, weighted average coupon, and
   diversity score.  Additionally, in light of the large positive
   difference between the reported and covenant levels for the
   weighted average rating factor, Moody's considered the impact
   of assuming the actual Moody's calculated weighted average
   rating factor in its analysis.


LB-UBS COMMERCIAL: Moody's Downgrades Ratings on 2002-C2 Certs.
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of six classes
and affirmed fourteen classes of LB-UBS Commercial Mortgage Trust
2002-C2, Commercial Mortgage Pass-Through Certificates, Series
2002-C2:

  -- Cl. A-3, Affirmed at Aaa (sf); previously on July 9, 2002
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed at Aaa (sf); previously on July 9, 2002
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-CL, Affirmed at Aaa (sf); previously on July 9, 2002
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-D, Affirmed at Aaa (sf); previously on July 9, 2002
     Definitive Rating Assigned Aaa (sf)

  -- Cl. B, Affirmed Aaa (sf); previously on March 9, 2006
     Upgraded to Aaa (sf)

  -- Cl. C, Affirmed Aaa (sf); previously on March 9, 2006
     Upgraded to Aaa (sf)

  -- Cl. D, Affirmed Aaa (sf); previously on May 2, 2007 Upgraded
     to Aaa (sf)

  -- Cl. E, Affirmed Aaa (sf); previously on Nov. 8, 2007 Upgraded
     to Aaa (sf)

  -- Cl. F, Affirmed Aa3 (sf); previously on Nov. 8, 2007 Upgraded
     to Aa3 (sf)

  -- Cl. G, Affirmed A1 (sf); previously on Nov. 8, 2007 Upgraded
     to A1 (sf)

  -- Cl. H, Affirmed A2 (sf); previously on Nov. 8, 2007 Upgraded
     to A2 (sf)

  -- Cl. J, Affirmed Baa1 (sf); previously on Nov. 8, 2007
     Upgraded to Baa1 (sf)

  -- Cl. K, Affirmed Baa3 (sf); previously on July 9, 2002
     Definitive Rating Assigned Baa3 (sf)

  -- Cl. L, Affirmed Ba1 (sf); previously on July 9, 2002
     Definitive Rating Assigned Ba1 (sf)

  -- Cl. M, Downgraded to Ba3 (sf); previously on Nov. 8, 2007
     Upgraded to Ba2 (sf)

  -- Cl. N, Downgraded to B2 (sf); previously on Nov. 8, 2007
     Upgraded to Ba3 (sf)

  -- Cl. P, Downgraded to B3 (sf); previously on Nov. 8, 2007
     Upgraded to B1 (sf)

  -- Cl. Q, Downgraded to Caa2 (sf); previously on Nov. 8, 2007
     Upgraded to B2 (sf)

  -- Cl. S, Downgraded to C (sf); previously on Nov. 8, 2007
     Upgraded to B3 (sf)

  -- Cl. T, Downgraded to C (sf); previously on Nov. 8, 2007
     Upgraded to Caa2 (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.

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 1.2%.  Moody's stressed scenario loss is
5.1% 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 11 compared to 14 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 November 8, 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 six months.

                        Deal Performance

As of the October 17, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 31% to
$830.0 million from $1.21 billion at securitization.  The
Certificates are collateralized by 76 mortgage loans ranging in
size from less than 1% to 17% of the pool, with the top ten non-
defeased loans representing 58% of the pool.  The pool includes
four loans with investment grade credit estimates, representing
40% of the pool.  Eighteen loans, representing 19% of the pool,
have defeased and are collateralized with U.S. Government
securities.

Nineteen 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.

Seven loans have been liquidated from the pool, resulting in an
aggregate realized loss of $4.1 million (8% loss severity
overall).  Four loans, representing 2.5% of the pool, are
currently in special servicing.  The master servicer has
recognized an aggregate $8.5 million appraisal reduction for the
specially serviced loans.  Moody's has estimated an aggregate
$10.4 million loss (50% expected loss on average) for the
specially serviced loans.

Moody's has assumed a high default probability for four poorly
performing loans representing 1% of the pool and has estimated a
$2.1 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 94% and 69% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 82% compared to 83% 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 9.7%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.27X and 1.31X, respectively, compared to
1.5X and 1.36X 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 largest loan with a credit estimate is the Dadeland Mall Loan
($153.6 million -- 18.5%), which is secured by the borrower's
interest in a 1.4 million square foot super regional mall located
in Miami, Florida.  The property is the dominant mall in the
region and is anchored by Macy's, Macy's Home Gallery & Kids, J.C.
Penney, Nordstrom and Saks Fifth Avenue.  The overall occupancy is
98% essentially the same as at last review and securitization.
Performance has been very strong since securitization.  The loan
has amortized 6% since last review.  Moody's current credit
estimate and stressed DSCR are Aaa and 2.14X, respectively,
compared to Aaa and 1.61X at last review.

The second loan with a credit estimate is the Square One Mall Loan
($84.7 million -- 10.2%), which is secured by the borrower's
interest in a 865,400 square foot regional mall located
approximately 8 miles northeast of Boston in Saugus,
Massachusetts.  The property is anchored by Sears, Macy's,
T.J.Maxx and Filene's Basement.  The overall occupancy is 92%
compared to 95% at last review.  Performance has been stable.  The
loan has amortized 5% since last review.  Moody's current credit
estimate and stressed DSCR are Baa1 and 1.64X, respectively,
compared to Baa1 and 1.54X at last review.

The third loan with a credit estimate is the 250 Park Avenue Loan
($65.9 million -- 7.9%), which is secured by a 448,000 square foot
Class A office building located in New York City.  The property
was 77% leased as of June 2010 compared to 95% at last review.
The loan is on the servicer watchlist due to low occupancy.  The
loan has amortized 8% since last review.  Moody's current credit
estimate and stressed DSCR are Aaa and 1.86X, respectively,
compared to Aaa and 1.91X at last review.

The fourth loan with a credit estimate is the 21 Chelsea Loan
($31.3 million -- 3.8%), which is secured by a 209-unit
multifamily complex located in New York City.  The property is 98%
leased compared to 100.0% at last review.  Performance has been
stable.  The loan has amortized 5% since last review.  Moody's
current credit estimate and stressed DSCR are A1 and 1.64X,
respectively, compared to A1 and 1.57X at last review.

The top three conduit loans represent 12% of the pool balance.
The largest loan is the 1750 Pennsylvania Avenue Loan
($45.2 million -- 5.5%), which is secured by a 259,000 square foot
Class A office building located in Washington, D.C.  The property
is 96% leased compared to 98% at last review.  The loan is on the
servicer's watchlist due major upcoming lease rollovers.  The
property's net operating income has declined 14% since last
review.  Moody's LTV and stressed DSCR are 87% and 1.15X,
respectively, compared to 80% and 1.24X at last review.

The second largest loan is the Bank of America Tower Loan
($31.1 million -- 3.7%), which is secured by a 299,700 square foot
office building located in St.  Petersburg, Florida.  The property
is 82% leased, the same as at last review.  Although occupancy has
been stable, performance has declined since last review due to
lower revenues.  NOI has declined by 13% since last review.
Moody's LTV and stressed DSCR are 99% and 1.04X, respectively,
compared to 96% and 1.07X at last review.

The third largest loan is the White Flint Plaza Loan
($25.2 million -- 3.0%), which is secured by a 194,975 square foot
community shopping center located in Rockville, Maryland.  The
property is 83% leased compared to 97% at last review.
Performance has declined due to lower occupancy and revenues.  NOI
has declined by 22% since last review.  Moody's LTV and stressed
DSCR are 92% and 1.17X, respectively, compared to 79% and 1.37X at
last review.


LCM I: S&P Corrects Press Release; Raises Ratings on Various Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services reports that in the press
release published Oct. 28, 2010, the manager of the transaction
was misstated in the first paragraph.  A corrected version is:

S&P 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 LCM Asset Management LLC 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)


LEHMAN BROTHERS: Moody's Confirms Ratings on 14 2006-C3 Certs.
--------------------------------------------------------------
Moody's Investors Service confirmed the ratings of two classes,
affirmed ten classes and downgraded 14 classes of Lehman Brothers-
UBS Commercial Mortgage Inc., Commercial Pass-Through
Certificates, Series 2006-C3:

  -- Cl. A-1, Affirmed at Aaa (sf); previously on April 13, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2, Affirmed at Aaa (sf); previously on April 13, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on April 13, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-AB, Affirmed at Aaa (sf); previously on April 13, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Confirmed at Aaa (sf); previously on Sept. 29, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-1A, Confirmed at Aaa (sf); previously on Sept. 29, 2010
     Aaa (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. A-J, Downgraded to Ba2 (sf); previously on Sept. 29, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Downgraded to Ba3 (sf); previously on Sept. 29, 2010
     A1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Downgraded to B1 (sf); previously on Sept. 29, 2010 A2
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. D, Downgraded to B3 (sf); previously on Sept. 29, 2010 A3
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. E, Downgraded to Caa1 (sf); previously on Sept. 29, 2010
     Baa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to Caa2 (sf); previously on Sept. 29, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

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

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

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

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

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

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

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

  -- Cl. FTH-1, Affirmed at Baa3 (sf); previously on Feb. 11, 2009
     Downgraded to Baa3 (sf)

  -- Cl. FTH-2, Affirmed at Ba3 (sf); previously on Feb. 11, 2009
     Downgraded to Ba3 (sf)

  -- Cl. FTH-3, Affirmed at B3 (sf); previously on Feb. 11, 2009
     Downgraded to B3 (sf)

  -- Cl. FTH-4, Affirmed at Caa1 (sf); previously on Feb. 11, 2009
     Downgraded to Caa1 (sf)

  -- Cl. X-CL, Affirmed at Aaa (sf); previously on April 13, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-CP, Affirmed at Aaa (sf); previously on April 13, 2006
     Definitive Rating Assigned Aaa (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 refinance risk
associated with loans approaching maturity in an adverse
environment.  Ten loans, representing 14% of the pool, mature
within the next six months and have a Moody's stressed debt
service coverage ratio less than 1.0X.

The confirmations and 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.

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

Moody's rating action reflects a cumulative base expected loss of
11.0% of the current balance.  At last full review, Moody's
cumulative base expected loss was 2.2%.  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 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 December 12, 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 six months.

                         Deal Performance

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 4% to $1.68 billion
from $1.74 billion at securitization.  The Certificates are
collateralized by 123 mortgage loans ranging in size from less
than 1% to 9% of the pool, with the top ten loans representing 46%
of the pool.  The pool does not contain any defeased loans.  Two
loans, representing 9% of the pool, have investment grade credit
estimates.

Forty-eight 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 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 $14.8 million loss (75%
loss severity on average).  Currently 12 loans, representing 21%
of the pool, are in special servicing.  The largest specially
serviced loan is the 200 South Wacker Drive Loan ($95.5 million --
5.8% of the pool), which is secured by a 743,133 square foot
office property located in Chicago, Illinois.  The loan was
transferred to special servicing in May 2010 due to imminent
default is currently 30 days delinquent.  A major tenant vacated
the building in January 2010 and the property's cashflow is no
longer sufficient to cover debt service and operating expenses.
The remaining 11 specially serviced loans are secured by a mix of
property types.  Moody's has estimated an aggregate $134.6 million
loss (38.6% expected loss on average).

Moody's has assumed a high default probability for nine poorly
performing loans representing 5% of the pool and has estimated a
$12.5 million loss (15% expected loss based on a 30% probability
default) from these troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 99% and 68% of the performing pool,
respectively.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 104% compared to 110% at last full
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
8.9%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.30X and 0.97X, respectively, compared to
1.18X and 0.91X at last full 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 30 compared to 36 at Moody's prior full review.

The largest loan with a credit estimate is the Station Place II
Loan ($100.7 million -- 6.2%), which is secured by a built-to-suit
office building built in 2005 with a total of 362,000 square feet
located in the Capitol Hill submarket of Washington, DC.  The
property is 100% leased to the U.S. Securities and Exchange
Commission through January 2020.  The loan matures in February
2016.  Moody's current credit estimate and stressed DSCR are A3
and 1.04X, respectively, compared to A3 and 1.00X at Moody's last
full review.

The second largest loan with a credit estimate is the 623 Fifth
Avenue Loan ($54.5 million -- 3.3%), which is secured by a 351,000
square foot Class A office building located in New York City.  The
loan had a 36-month interest only period and matures in June 2015.
The property is also encumbered by a $37.4 million subordinate
non-pooled B-Note which is held in the trust and secures rake
classes FTH-1, FTH-2, FTH-3 and FTH-4.  Moody's current credit
estimate and stressed DSCR are A3 and 1.97X, respectively,
compared to A3 and 1.73X at Moody's last full review.  Based on
the stable performance of the property, the ratings of the rake
classes are affirmed.

The top three performing conduit loans represent 16% of the pool
balance.  The largest loan is the 888 Seventh Avenue Loan
($145.9 million -- 8.9%), which is a pari-passu interest in a
$291.8 million first mortgage loan.  The property is also
encumbered by a $26.8 million subordinate note.  The loan is
secured by a 908,000 square foot office building located in New
York City.  The property was 96% leased as of July 2010 compared
to 99% at last review.  Despite a slight drop in occupancy, the
property has performed better than at last full review due to
increased base rental income.  The loan is interest only for the
entire term and matures in January 2016.  Moody's LTV and stressed
DSCR are 92% and 1.00X, respectively, compared to 121% and 0.74X
at Moody's last full review.

The second largest loan is the Marriott Hotel - Orlando Airport
Loan ($59.0 million -- 3.6%), which is secured by a 486-room full
service hotel built in 1983 and located in Orlando, Florida.
Property performance has declined since last review as the hotel
has been impacted by the downturn in the tourism industry.  The
loan has three months remaining of a 60-month interest only period
and will amortize on a 360-month schedule maturing in January
2016.  Moody's LTV and stressed DSCR are 122% and 0.96X,
respectively, compared to 108% and 1.08X at Moody's last full
review.

The third largest loan is the 1 Allen Bradley Drive Loan
($52.7 million -- 3.2%), which is secured by a 462,000 square foot
single-tenant office building located in Mayfield Heights, Ohio.
The property serves the headquarters facility for a division of
Rockwell Automation, Inc. (Moody's senior unsecured rating A3,
stable outlook) and is leased through November 2020.  The loan is
interest-only for its entire ten-year term maturing in March 2016.
Moody's LTV and stressed DSCR are 125% and 0.78X, respectively,
compared to 119% and 0.82X at Moody's last full review.


LNR CDO: Fitch Affirms Ratings on 12 Classes of Notes
-----------------------------------------------------
Fitch Ratings has affirmed 12 classes of notes issued by LNR CDO
2007-1 Ltd./LLC.  The notes are affirmed at 'C' and 'D' as a
result of continued negative credit migration within the
underlying collateral.  A complete list of rating actions follows
at the end of this release.

Since Fitch's last rating action in December 2009, approximately
57.9% of the portfolio has been downgraded, and 18.1% is currently
on Rating Watch Negative.  The entire collateral pool is rated
below investment grade and 89.3% has a rating in the 'CCC' rating
category or lower, compared to 100% and 47.4%, respectively, 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 compared the respective credit
enhancement levels to the amount of distressed assets ('CC' and
below).  Given the high probability of default of the underlying
assets and the expected limited recovery prospects upon default,
classes C through L have been affirmed at 'C', indicating that
default is inevitable at maturity.

On the Nov. 27, 2009 payment date, the classes A and B notes did
not receive interest distributions as a result of the partial
payment of the interest rate hedge termination amount that is
senior in priority to the class A notes.  On Dec. 3, 2009, the
trustee declared an event of default due to non-payment of full
and timely accrued interest to the class A and B notes.  According
to the Oct. 21, 2010 payment date, the classes A and B notes are
not receiving any interest distributions, therefore the notes have
been affirmed at 'D'.

LNR CDO V is currently collateralized by all or a portion of 108
classes of fixed-rate 2006 vintage CMBS in 21 separate underlying
transactions.  Approximately 35% of the collateral currently is
not rated and represents the first loss position of the respective
underlying CMBS transaction.  All underlying classes are thin,
junior tranches that are susceptible to losses in the near term.
Fitch has affirmed these classes:

  -- $170,484,000 Class A Notes at 'Dsf';
  -- $89,826,000 Class B Notes at 'Dsf';
  -- $15,000,000 Class C-FX Notes at 'Csf';
  -- $51,989,000 Class C-FL Notes at 'Csf';
  -- $35,778,000 Class D Notes at 'Csf';
  -- $35,017,000 Class E Notes at 'Csf';
  -- $35,017,000 Class F Notes at 'Csf';
  -- $15,224,000 Class G Notes at 'Csf';
  -- $35,017,000 Class H Notes at 'Csf';
  -- $56,332,000 Class J Notes at 'Csf';
  -- $25,121,000 Class K Notes at 'Csf';
  -- $20,553,000 Class L Notes at 'Csf'.


MAGNOLIA FINANCE: S&P Puts 'CCC-' Rating on CreditWatch Positive
----------------------------------------------------------------
Standard & Poor's Ratings Services placed its 'CCC- (sf)' rating
on Magnolia Finance I PLC's $9 million collateralized debt
obligation referenced fixed-rate notes from series 2005-19 on
CreditWatch with positive implications.

The rating on the fixed-rate notes is dependent on the lower
of S&P's ratings on (i) the rate and credit default swap
counterparty, Credit Suisse International ('A+'), and (ii) the
reference obligation, CSAM Funding II's class D notes due
Oct. 15, 2016 ('CCC- (sf)/Watch Pos').

The rating action follows the Nov. 8, 2010, placement of the 'CCC-
(sf)' rating on the reference obligation on CreditWatch with
positive implications.  S&P may take subsequent rating actions on
Magnolia Finance I PLC's fixed-rate notes due to the changes in
S&P's ratings assigned to the reference obligation or Credit
Suisse International.


MERRILL LYNCH: DBRS Upgrades Class G Rating to BB (High) From BB
----------------------------------------------------------------
DBRS has upgraded these ratings of eight classes of Merrill Lynch
Financial Assets Inc., Series 2005-Canada 16 Commercial Mortgage
Pass-Through Certificates:

Class B to AA from AAA
Class C to AA from A
Class D1 to A from BBB
Class D2 to A from BBB
Class E1 to A (low) from BBB (low)
Class E2 to A (low) from BBB (low)
Class F to BBB from BB (high)
Class G to BB (high) from BB

DBRS has also confirmed the ratings of nine classes as follows:

Class A-1 at AAA
Class A-2 at AAA
Class XP1 at AAA
Class XP2 at AAA
Class XC at AAA
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 the transaction remain Stable.

The ratings upgrades reflect the increased credit enhancement to
the bonds from a collateral reduction of approximately 27% since
issuance.  Additionally, as of the October 2010 remittance, the
weighted-average debt service coverage ratio remains strong at
1.93x.

There is currently one loan, representing 0.99% of the
transaction, on the servicer's watchlist; DBRS has placed this
loan on the DBRS HotList.

Prospectus ID#27, 165 Saint Madeleine, is secured by a 117,833 sf
anchored retail property located in Cap-de-la-Madeleine, Quebec,
approximately 100 kilometers northeast of Montreal.  The loan is
on the servicer's watchlist because of a low DSCR due to higher
than anticipated vacancy rates, with the YE2009 showing an
occupancy rate of 77%.  The corresponding YE2009 DSCR was 0.66x
with a debt yield of 6%.  Despite the declining performance, the
loan per square foot of $24 is reasonable.  DBRS will keep this
loan on the DBRS HotList to monitor leasing updates as they become
available.

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 to the bond classes, 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.


MERRILL LYNCH: DBRS Confirms 'B' Rating on Class K Certs.
---------------------------------------------------------
DBRS has confirmed these ratings of all 18 classes of Merrill
Lynch Financial Assets Inc. Commercial Mortgage Pass-Through
Certificates, Series 2005-Canada 15:

Class A-1 at AAA
Class A-2 at AAA
Class B at AA (high)
Class C at A (high)
Class D-1 at BBB (high)
Class D-2 at BBB (high)
Class E-1 at BBB
Class E-2 at BBB
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 XC-1 at AAA
Class XC-2 at AAA
Class XP-1 at AAA
Class XP-2 at AAA

All classes were confirmed with a Stable trend.

The ratings reflect the increased credit enhancement to the bonds
from a collateral reduction of approximately 37.3% since issuance,
the healthy weighted-average debt service coverage ratio (DSCR) of
1.68x for the pool and the strong performance of the ten largest
loans in the pool, which had a straight-average debt yield of
15.1% for 2009.  Furthermore, there are two defeased loans in the
pool, both of which are in the top ten loans, comprising 10.06% of
the pool.

One loan has been liquidated since issuance, Prospectus ID#48,
Snowdown Professional Building.  This loan was transferred to the
special servicer in 2009 after failing to payoff at the October 1,
2009 maturity.  The property was sold via a receivership sale in
July 2010, with proceeds of $914,965, the Trust experienced a
realized loss to the unrated Class M certificates of $625,390 for
this $1.54 million loan.  There are no other loans in special
servicing currently in the pool.

There are five loans on the servicer's watchlist, representing a
combined 5.92% of the pool.

The largest of the watch-listed loans is Prospectus ID#20, Royal
Windsor, with 2.59% of the transaction.  The loan is
collateralized by a 204,136 sf industrial property located in a
largely industrial section of Mississauga, Ontario.  The loan is
on the servicer's watchlist for a low DSCR at YE2009 of 1.02x due
to the space reduction for the largest tenant at the property in
2009, which left the property at 75% occupancy.  The property is
exposed to significant rollover between August 2010 and February
2011, with over 40% of the NRA scheduled for expiry during those
months.  DBRS has requested a leasing update from the servicer and
will continue to monitor the loan by placing it on the DBRS
HotList for further review.  The loan remains current, with no
payment issues throughout this period of reduced occupancy as
compared to historical levels.

The second largest watchlisted loan is Prospectus ID#27, Armdale
Place, with 2.11% of the transaction.  This loan is collateralized
by a high-rise multifamily property located in Halifax.  The
property was constructed in 1976 and has undergone renovations to
the common areas and unit interiors over the past three years.
The borrower invested $250,000 in 2009 and intends to invest that
much or more in 2010, according to the servicer.  The loan is on
the servicer's watchlist for a low DSCR at YE2009 of 0.98x.  The
occupancy has steadily improved throughout the past two years,
with the property at 85% occupied in August 2010 as compared with
73% occupied at YE2008.  The reduction in DSCR from issuance is
primarily due to an increase in expenses at the property, which
have climbed by 35% overall from the underwritten figures at
YE2009.  The city of Halifax has fared well in the current
economic climate; the unemployment rate at August 2010 was 6.1%
per StatCan, as compared to approximately 8% for the country
overall.  DBRS will continue to monitor the loan's performance.

There are three smaller loans on the servicer's watchlist,
comprising a combined 1.21% of the pool; two of those loans are
Prospectus ID#55 and ID#58, both of which are part of a crossed
pool of eight loans backed by smaller retail properties scattered
throughout British Columbia and anchored by Prospera Credit Union.
These two loans comprise a small portion of the crossed pool,
which combines for 4.91% of the transaction and has a straight-
average DSCR of 1.39x and 99% occupancy.  These properties also
had sublease space that was not renewed; both properties are
primarily occupied by Prospera Credit Union on a master lease
through 2019, five years after the loans' maturity.  The other six
loans in the crossed pool are 100% master leased to Prospera
Credit Union through 2019.  This pool of loans should continue to
perform well in the aggregate.

There is one shadow rated loan in the transaction, Prospectus
ID#1, EPR Pooled Senior Interest.  The shadow rating was also
confirmed, as the loan, which represents 12.98% of the current
pool balance, continues to perform well with a DSCR of 2.10x at
YE2009 and a debt yield of 24% for the whole loan.  The whole loan
balance is $103.8 million and includes a pari passu A-note balance
of $78.3 million and a $25.5 million subordinate B-note.  This
trust holds the controlling piece of the pari passu senior
interest, with a current balance of $39.1 million.  The whole loan
is collateralized by four retail/entertainment properties, each
anchored by a 16- or 24-screen AMC theatre, located in
Misssissauga, Whitby, Oakville, and Kanata, all in Ontario.  The
loan sponsor is Entertainment Properties Trust, a publicly traded
REIT with assets exceeding $2 billion as of November 3, 2010.

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.

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 Takes Rating Actions on 2004-MKB1 Certs.
---------------------------------------------------------------
Moody's Investors Service upgraded the rating of one class,
downgraded six classes and affirmed 12 classes of Merrill Lynch
Mortgage Trust 2004-MKB1, Commercial Mortgage Pass-Through
Certificates, Series 2004-MKB1:

  -- Cl. A-2, Affirmed at Aaa (sf); previously on May 14, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on May 14, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed at Aaa (sf); previously on May 14, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-1A, Affirmed at Aaa (sf); previously on May 14, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. XP, Affirmed at Aaa (sf); previously on May 14, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. XC, Affirmed at Aaa (sf); previously on May 14, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. B, Affirmed at Aaa (sf); previously on April 23, 2007
     Upgraded to Aaa (sf)

  -- Cl. C, Upgraded to Aaa (sf); previously on April 23, 2007
     Upgraded to Aa2 (sf)

  -- Cl. D, Affirmed at A2 (sf); previously on May 14, 2004
     Definitive Rating Assigned A2 (sf)

  -- Cl. E, Affirmed at A3 (sf); previously on May 14, 2004
     Definitive Rating Assigned A3 (sf)

  -- Cl. F, Affirmed at Baa1 (sf); previously on May 14, 2004
     Definitive Rating Assigned Baa1 (sf)

  -- Cl. G, Affirmed at Baa2 (sf); previously on May 14, 2004
     Definitive Rating Assigned Baa2 (sf)

  -- Cl. H, Affirmed at Baa3 (sf); previously on May 14, 2004
     Definitive Rating Assigned Baa3 (sf)

  -- Cl. J, Downgraded to Ba2 (sf); previously on May 14, 2004
     Definitive Rating Assigned Ba1 (sf)

  -- Cl. K, Downgraded to B1 (sf); previously on May 14, 2004
     Definitive Rating Assigned Ba2 (sf)

  -- Cl. L, Downgraded to B3 (sf); previously on May 14, 2004
     Definitive Rating Assigned Ba3 (sf)

  -- Cl. M, Downgraded to Caa1 (sf); previously on May 14, 2004
     Definitive Rating Assigned B1 (sf)

  -- Cl. N, Downgraded to C (sf); previously on May 14, 2004
     Definitive Rating Assigned B2 (sf)

  -- Cl. P, Downgraded to C (sf); previously on May 14, 2004
     Definitive Rating Assigned B3 (sf)

                        Ratings Rationale

The upgrade is due to the significant increase in subordination
due to loan payoffs and amortization and stable overall
performance.  The pool has paid down by 39% since Moody's last
review.  In addition, the pool benefits from 30% defeasance.  The
downgrades are due to higher expected losses for the pool
resulting from realized and 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 the current ratings.

Moody's rating action reflects a cumulative base expected loss of
3.2% of the current balance.  At last review, Moody's cumulative
base expected loss was 2.1%.  Moody's stressed scenario loss is
5.8% 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.  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 8 compared to 14 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 March 17, 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 during the previous six months.

                         Deal Performance

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 42% to
$569.3 million from $979.9 million at securitization.  The
Certificates are collateralized by 56 mortgage loans ranging in
size from less than 1% to 9% of the pool, with the top ten loans
representing 33% of the pool.  The pool includes one loan with an
investment grade credit estimate, representing 10% of the pool.
Eight loans, representing 30% of the pool, have defeased and are
collateralized with U.S. Government securities.  Defeasance at
last review represented 23% of the pool.

Five loans, representing 14% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the 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
securitization, resulting in an aggregate $3.6 million loss (10%
loss severity on average).  Currently, two loans, representing 3%
of the pool, are in special servicing.  The master servicer has
recognized an aggregate $5.0 million appraisal reduction for all
of the specially serviced loans.  Moody's has estimated an
aggregate $8.2 million loss (50% expected loss on average) for the
specially serviced loans.

Moody's has assumed a high default probability for three poorly
performing loans representing 3% of the pool.  Moody's has
estimated a $4.6 million loss (24% expected loss based on a 75%
probability default) from the troubled loans.

Moody's was provided with full year 2009 operating results for 86%
of the pool.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV for the conduit component is 82%
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 9.7%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs for the conduit component are 1.51X and 1.34X,
respectively, compared to 1.49X and 1.16X 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 an investment grade credit estimate is the Galileo
Pool #2 Loan ($54.0 million -- 9.5% of the pool), which is secured
by nine anchored retail properties totaling 993,000 square feet
located in eight states.  As of June 2010, the portfolio was 92%
leased compared to 95% in December 2009.  The loan's sponsor is
Centro Properties Group.  This loan is currently on the master
servicer's watchlist due to its upcoming maturity in November
2010.  The borrower is currently seeking replacement financing.
Per the Pooling and Servicing Agreement (PSA), the special
servicer is able to extend this loan by 12 months if it is not
repaid by its maturity date.  Moody's underlying rating and
stressed DSCR are A2 and 1.58X, respectively, compared to A2 and
1.61X at last review.

The top three performing conduit loans represent 11% of the pool.
The largest loan is the WestPoint Crossing Shopping Center Loan
($25.3 million -- 4.4% of the pool), which is secured by a 241,000
square foot retail center located in Tucson, Arizona.  The center
is shadow anchored by Target and Home Depot.  As of June 2010, the
property was 96% leased compared to 100% at last review.  Moody's
LTV and stressed DSCR are 94% and 1.07 X, respectively, compared
to 91% and 1.10X, at last review.

The second largest loan is the GFS Marketplace Portfolio Loan
($18.9 million -- 3.3% of the pool), which is secured by 17
single-tenant retail properties with a total of 272,000 square
feet located in Ohio (6), Michigan (5) Indiana (4), and Illinois
(2).  All the properties are leased to GFS Holdings, Inc., a
foodservice distributor, under leases expiring in September 2028.
Moody's LTV and stressed DSCR 51% and 2.02X, respectively,
compared to 59% and 1.70X at last review.

The third largest loan is the MHC Portfolio - Mariner's Cove Loan
($15.7 million -- 2.8% of the pool), which is secured by a 374-pad
manufactured housing community located in Millsboro, Delaware.  As
of December, the property was 97% leased, the same as at last
review.  Moody's LTV and stressed DSCR 72% and 1.28X,
respectively, compared to 85% and 1.08X at last review.


MEZZ CAP: S&P Downgrades Ratings on 13 Classes of Certs.
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 13
classes of certificates from Mezz Cap Commercial Mortgage Trust's
series 2004-C1, 2004-C2, 2005-C3, and 2007-C5.

S&P lowered its ratings on 10 classes to 'D (sf)' because these
classes are experiencing interest shortfalls that S&P expects will
continue.  Concurrently, S&P lowered its ratings on three other
classes due to a significant reduction in the amount of available
interest to the respective trusts resulting from poor collateral
performance.  S&P believes these classes may be susceptible to
future interest shortfalls.  There are 71 loans ($49.3 million)
classified as 30 or more days delinquent across the four
securitizations, with total delinquencies ranging from 18.50% to
31.9% of the respective pool balances.  The master servicer,
Wachovia Bank N.A., has declared future payment advances
nonrecoverable for all of the 30-plus-day delinquent loans in each
transaction.

The collateral for each transaction consists of subordinate B
notes secured by commercial real estate properties.  It is S&P's
understanding that Wachovia, which is the master and special
servicer for all four transactions, has stopped advancing on all
loans that are 30-plus-days delinquent.  In addition, numerous A
notes that are senior to the B-note collateral in the Mezz Cap
Commercial Mortgage Trust transactions are current in their
payments.  In certain instances, the special servicers of the
delinquent A notes have asked Wachovia to remit any debt service
payments on the related B notes to the respective special
servicers.  As a result, S&P believes interest shortfalls to the
respective Mezz Cap Commercial Mortgage Trust transactions are
likely to increase.

Details of the four Mezz Cap Commercial Mortgage Trusts series as
of the Oct. 18, 2010, remittance report are:

The collateral pool for series 2004-C1 consisted of 69 loans with
an aggregate trust balance of $38.0 million, and 13 loans are 30
or more days delinquent ($9.9 million, 26.05% of the pool).  S&P
lowered its rating on the class A certificates to 'CCC- (sf)' from
'BB+ (sf)' because S&P believes this class is susceptible to
future interest shortfalls.  As of the Oct. 18, 2010, remittance
report, interest shortfalls totaled $99,097 and have affected all
of the classes subordinate to and including class B.  As of the
Oct. 18, 2010, remittance report, 12 loans totaling $9.9 million
were with the special servicer.  The payment status of these loans
is: two are in foreclosure (2.2 million, 0.80%), eight loans
($6.4 million, 16.8%) are 90-plus-days delinquent, one is 30-plus-
days delinquent ($2.3 million, 2.3%), and one is a nonperforming
matured balloon ($413,339, 1.1%).  In addition, five loans
($2.9 million, 0.80%) are categorized as late but less than 30
days delinquent.  To date, the trust has experienced seven losses
totaling $4.2 million.  Each loan experienced a 100% loss
severity.

The collateral pool for series 2004-C2 consisted of 76 loans with
an aggregate trust balance of $48.9 million, and 14 loans are 30
or more days delinquent ($9.04 million, 18.5%).  S&P lowered its
ratings on the class A, B, C, D, and E certificates due to
interest shortfalls resulting from interest not advanced by the
master servicer for 14 loans that are 30-plus days delinquent, as
well as special servicing fees.  S&P lowered its rating on the
class A and B certificates to 'CCC-(sf)' because S&P believes the
classes are susceptible to future interest shortfalls.  S&P
lowered its ratings on class C, D, and E certificates to 'D (sf)'
due to interest shortfalls S&P expects to continue.  The
transaction's reported interest shortfalls totaled $95,508 and
have affected all of the classes subordinate to and including
class C.  As of the Oct. 18, 2010, remittance report, 19 assets
totaling $11.4 million (23.4%) are with the special servicer.  The
payment status of these assets is: seven loans are 90-plus-days
delinquent ($5.9 million, 12.1%), three are in foreclosure
($1.8 million, 3.7%), three  are real estate owned ($1.04 million,
2.1%) and six are late but less than 30 days ($2.7 million,
0.55%).  To date, the trust has experienced three losses totaling
$2.1 million.  Each loan experienced a 100% loss severity.

The collateral pool for series 2005-C3 consisted of 100 loans with
an aggregate trust balance of $58.9 million, and 26 loans are 30
or more days delinquent ($18.8 million, 31.9%).  S&P lowered its
ratings on the class A, B, C, D, and E certificates to 'D (sf)'
due to interest shortfalls that S&P expects to continue.  The
interest shortfalls resulted from interest not advanced by the
master servicer for 30 loans that are 30-plus days delinquent
($19.1 million, 32.4%), as well as special servicing fees.  The
transaction's reported interest shortfalls totaled $178,568 and
have affected all of the classes subordinate to and including
class A.  As of the Oct. 18, 2010, remittance report, 30 assets
totaling $19.1 million (32.3%) are with the special servicer.  The
payment status of these assets is: 15 are 90-plus-days delinquent
($10.6 million, 18.0%), three are in foreclosure ($1.04 million,
1.8%), six are REO ($5.3 million, 8.9%), four are nonperforming
matured balloons ($1.3 million, 2.2%), one is 60-plus days
delinquent ($263,589, 0.45%), and one is 30-plus days delinquent
(451,423, 0.80%).  To date, the trust has experienced six losses
totaling $2.8 million.  Each loan experienced a 100% loss
severity.

The collateral pool for series 2007-C5 consisted of 77 loans with
an aggregate trust balance of $52.4 million, and 18 of these loans
are 30 or more days delinquent ($11.6 million, 22.2%).  S&P
lowered its ratings on the class A and B certificates to 'D (sf)'
due to interest shortfalls S&P expects to continue.  The interest
shortfalls resulted from interest not advanced by the master
servicer for the 18 loans that are 30-plus days delinquent, as
well as special servicing fees.  The transaction's reported
interest shortfalls totaled $114,380 and have affected all of
the classes subordinate to and including class A.  As of the
Oct. 18, 2010, remittance report, 17 loans totaling $14.1 million
(26.9%) are with the special servicer.  The payment status of
these loans is: 10 are 90-plus-days delinquent ($5.2 million,
9.9%), four are in foreclosure ($2.2 million, 4.3%), and three are
REO ($4.1 million, 7.8%).  To date, the trust has experienced six
losses totaling $3.4 million, with a weighted average loss
severity of 89%.

                         Ratings Lowered

                Mezz Cap Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2004-C1

            Rating
            ------
  Class   To            From     Current credit enhancement (%)
  -----   --            ----     ------------------------------
  A       CCC- (sf)     BB+ (sf)                          41.16

                Mezz Cap Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2004-C2

             Rating
             ------
   Class   To             From  Current credit enhancement (%)
   -----   --             ------------------------------------
   A       CCC- (sf)      BBB- (sf)                      30.61
   B       CCC- (sf)      BB (sf)                        26.32
   C       D (sf)         B+ (sf)                        22.97
   D       D (sf)         B- (sf)                        17.74
   E       D (sf)         CCC- (sf)                      15.60


               Mezz Cap Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2005-C3

             Rating
             ------
   Class   To             From  Current credit enhancement (%)
   -----   --             ------------------------------------
   A       D (sf)         BB+ (sf)                       30.78
   B       D (sf)         BB (sf)                        27.68
   C       D (sf)         B+ (sf)                        24.45
   D       D (sf)         B- (sf)                        19.07
   E       D (sf)         CCC (sf)                       15.97

                Mezz Cap Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2007-C5

             Rating
             ------
   Class   To             From  Current credit enhancement (%)
   -----   --             ------------------------------------
   A       D (sf)       B+ (sf)                         24.49
   B       D (sf)       CCC+ (sf)                       22.21


MORGAN STANLEY: Moody's Reviews Ratings on 18 2007-HQ11 Certs.
--------------------------------------------------------------
Moody's Investors Service placed 18 classes of Morgan Stanley
Capital I Trust, Commercial Mortgage Pass-Through Certificates,
Series 2007-HQ11 on review for possible downgrade:

  -- Cl. A-M, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 28, 2007 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. A-MFL, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 28, 2007 Assigned Aaa (sf)

  -- Cl. A-J, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to A1 (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, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Baa1 (sf)

  -- Cl. E, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Baa2 (sf)

  -- Cl. F, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Baa3 (sf)

  -- Cl. G, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Ba2 (sf)

  -- Cl. H, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Ba3 (sf)

  -- Cl. J, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to B1 (sf)

  -- Cl. K, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to B3 (sf)

  -- Cl. L, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa1 (sf)

  -- Cl. M, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa1 (sf)

  -- Cl. N, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa2 (sf)

  -- Cl. O, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa2 (sf)

  -- Cl. P, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa3 (sf)

  -- Cl. Q, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 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 11, 2009.

                   Deal And Performance Summary

As of the October 15, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 1.4% to
$2.383 billion from $2.418 billion at securitization.  The
Certificates are collateralized by 171 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 48% of the pool.  No loans have defeased.

Forty-eight loans, representing 27% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the 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.

There have no realized losses from the pool since securitization.
Currently 19 loans, representing 13% of the pool, are in special
servicing.  The master servicer has recognized an aggregate
$58.4 million appraisal reduction for 14 of the specially serviced
loans.

Based on the most recent remittance statement, Classes N through
S have experienced cumulative interest shortfalls totaling
$2.2 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.


MORGAN STANLEY: Moody's Reviews Ratings on 15 2007-TOP25 Certs.
---------------------------------------------------------------
Moody's Investors Service placed 15 classes of Morgan Stanley
Capital I Trust, Commercial Mortgage Pass-Through Certificates,
Series 2007-TOP25 on review for possible downgrade:

  -- Cl. A-M, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 2, 2007 Definitive Rating Assigned Aaa
     (sf)

  -- Cl. A-J, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to A1 (sf)

  -- Cl. B, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to A3 (sf)

  -- Cl. C, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Baa1 (sf)

  -- Cl. D, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Baa3 (sf)

  -- Cl. E, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Ba1 (sf)

  -- Cl. F, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Ba2 (sf)

  -- Cl. G, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Ba3 (sf)

  -- Cl. H, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to B2 (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, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 2009 Downgraded to Caa2 (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. O, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 11, 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 11, 2009.

                   Deal And Performance Summary

As of the October 12, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 2.3% to
$1.518 billion from $1.555 billion at securitization.  The
Certificates are collateralized by 202 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 37% of the pool.  No loans have defeased.

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.

Realized losses total $1.1 million from one loan with a loss
severity of 80%.  Currently seven loans, representing 7% of the
pool, are in special servicing.  The master servicer has
recognized an aggregate $54.8 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.


MORGAN STANLEY: S&P Raises Rating on Class H 1998-HF1 Certs.
------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
H commercial mortgage pass-through certificates from Morgan
Stanley Capital I Inc.'s series 1998-HF1, a U.S. commercial
mortgage-backed securities transaction, to 'BBB+ (sf)' from 'BBB-
(sf)'.  At the same time, S&P affirmed its ratings on the class J
and K certificates from the same transaction.

S&P's upgrade of the class H certificates and affirmation of its
rating on the class J certificates reflect increased credit
enhancement, the liquidity available to the rated securities, and
S&P's analysis of the transaction structure and the remaining
collateral.  S&P also affirmed its 'D (sf)' rating on the class K
certificates, which S&P lowered on July 19, 2010, due to principal
losses sustained by the class at that time.

S&P's analysis included a review of the credit characteristics of
all of the remaining assets in the transaction.  Using servicer-
provided financial information, Standard & Poor's calculated an
adjusted debt service coverage of 1.42x and a loan-to-value ratio
of 59.0%.  S&P further stressed the loans' cash flows under its
'AAA' scenario to yield a weighted average DSC of 1.26x and an LTV
of 70.0%.

                       Transaction Summary

As of the Oct. 15, 2010, remittance report, the aggregate trust
balance was $44.6 million, which represents 3.5% of the aggregate
trust balance at issuance.  There are 20 loans remaining, down
from 349 at issuance.  The master servicer for the transaction,
Berkadia Commercial Mortgage LLC, provided financial information
for 98.5% of the pool.  All of the servicer-provided financial
information was full-year 2008 data (1.5%), full-year 2009 (93.6%)
data, or interim 2010 data (3.4%).

S&P calculated a weighted average DSC of 1.58x for the loans in
the pool based on the reported figures.  S&P's adjusted DSC and
LTV were 1.42x and 59.0%, respectively.  As of the October 2010
remittance report, no assets were reported to be with the special
servicer, LNR Partners Inc. Four loans ($5.5 million, 12.3%) are
on the master servicer's watchlist.  Two loans ($2.4 million,
5.3%) have a reported DSC between 1.0x and 1.1x, and three loans
($4.8 million, 10.8%) have reported DSCs of less than 1.0x.  The
trust has experienced $22.7 million of principal losses on 13
loans to date.

                     Credit Considerations

The Stone Creek Plaza loan ($1.8 million, 4.2%) is the sixth-
largest loan in the transaction and the largest loan on the master
servicer's watchlist.  The loan is secured by a 44,517-sq.-ft.
retail property built in 1995 in Flower Mound, Texas.  The loan is
on the watchlist due to low DSC and its payment status is current.
As of Dec. 31, 2009, the reported DSC was 0.65x, and occupancy was
53%.   According to Berkadia, the borrower stated that the
occupancy has increased to 69% as of Sept. 9, 2010.

The Valencia Gardens loan ($1.5 million, 3.4%) is the seventh-
largest loan in the transaction and the second-largest loan on the
master servicer's watchlist.  The loan is secured by a 160-unit
multifamily property built in 1984 in Tucson.  The loan appears on
the watchlist due to low DSC, and its payment status is current.
As of Dec. 31, 2009, the reported DSC was 0.79x, and occupancy was
71%.   The property was last inspected on Nov. 20, 2009, and
received a rating of good.

The Westminster Garden loan ($1.4 million, 3.2%) is the eighth-
largest loan in the transaction and the third-largest loan on the
master servicer's watchlist.  The loan is secured by a 144-unit
multifamily property built in 1971 in Vestal, N.Y.  The loan is on
the watchlist due to low DSC, and its payment status is current.
For the six months ended June 30, 2010, the reported DSC was 0.67x
and occupancy was 90%, compared with 0.52x and 88% as of year-end
2009.

Four loans ($13.3 million, 29.7%) have balloon maturities within
the next 24 months.  As of year-end 2009, the weighted average
reported DSC was 1.94x.

                     Summary of Top 10 Loans

The top 10 loans have an aggregate outstanding balance of
$37.4 million (83.8%).  Using servicer-reported numbers, S&P
calculated a weighted average DSC of 1.58x for the top 10 loans.
S&P's adjusted DSC and LTV for the top 10 loans were 1.41x and
62.9%, respectively.  Three of the top 10 loans are on the master
servicer's watchlist and are discussed above.

Details regarding the top three loans in the transaction:

The A&P Food Market loan ($10.8 million, 24.2%) is the largest
loan in the transaction.  The loan is secured by a 70,000-sq.-ft.
single-tenant grocery anchored retail property in Woodcliff Lake,
N.J.  As of Dec. 31, 2009, the reported DSC and occupancy were
1.56x and 100%, respectively.  A&P, which occupies 100% of the net
rentable area, has a lease that expires in February 2021.
The Sunset Mall loan ($6.2 million, 13.9%) is the second-largest
loan in the transaction.  The loan is secured by a 133,145-sq.-ft.
grocery anchored retail property located in Portland, Ore.  The
tenants include Safeway (42.4% NRA), Sherwin-Williams, and Dollar
Tree.  As of Dec. 31, 2009, the reported DSC was 2.17x, and
occupancy was 96%.  Safeway, which occupies 42.4% of the NRA, has
a lease that expires in August 2017.  The loan matures on Oct. 1,
2012.

The Cedar Ridge Apartments loan ($5.2 million, 11.7%) is the
third-largest loan in the transaction.  The loan is secured by a
180-unit multifamily property in Minnetonka, Minn.  As of Dec. 31,
2009, the reported DSC was 1.26x, and occupancy was 89%.
Standard & Poor's stressed the collateral in the pool according to
S&P's criteria.  The resultant credit enhancement levels are
consistent with the raised and affirmed ratings.

                          Rating Raised

                   Morgan Stanley Capital I Inc.
   Commercial mortgage pass-through certificates series 1998-HF1

                   Rating
                   ------
        Class   To         From      Credit enhancement (%)
        -----   --         ----      ----------------------
        H       BBB+ (sf)  BBB- (sf)              78.54

                        Ratings Affirmed

                   Morgan Stanley Capital I Inc.
   Commercial mortgage pass-through certificates series 1998-HF1

          Class     Rating        Credit enhancement (%)
          -----     ------        ----------------------
          J         B+ (sf)                    21.00
          K         D (sf)                      0.00

                      N/A - Not applicable.


MORGAN STANLEY: S&P Downgrades Ratings on Eight 2002-IQ3 Certs.
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of commercial mortgage-backed securities from Morgan
Stanley Dean Witter Capital I Trust 2002-IQ3.  In addition, S&P
affirmed its ratings on 10 other classes from the same
transaction, including three classes that are rated 'D (sf)'.

The rating actions reflect S&P's analysis of the interest
shortfalls that have affected the trust, as well as the potential
for future interest shortfalls.  As of the October 2010 remittance
report, the trust experienced monthly interest shortfalls totaling
$99,718 primarily related to an appraisal subordinate entitlement
reduction amount associated with the Northwestern Corporate Center
loan ($26.5 million, 4.2%, discussed below).  This loan had a
$14.3 million appraisal reduction amount in effect, which
generated an ASER of $92,786.  The monthly interest shortfalls
affected all of the classes subordinate to and including class H.
The recurring interest shortfalls have also reduced liquidity
support available to the remaining pooled classes.

The affirmations of the ratings on classes A-2, A-3, A-4, and B
reflect subordination levels and liquidity that are consistent
with the outstanding ratings.  S&P affirmed its 'D (sf)' ratings
on classes L, M, and N.  S&P lowered the ratings to 'D (sf)' in
February 2007 due to interest shortfalls S&P determined were
recurring at that time.  According to the October 2010 remittance
report, classes M and N have both lost 100% of their original
principal balance, while class L has lost 49% of its original
principal balance.  S&P affirmed its ratings on the class X-1, X-
2, and X-Y interest-only certificates based on S&P's current
criteria.

                     Credit Considerations

As of the October 2010 remittance report, two ($29.6 million,
4.7%) loans in the pool were with the special servicer, CWCapital
Asset Management LLC.  The Northwestern Corporate Center loan
($27.8 million total exposure, 4.5%) is the largest loan with the
special servicer.  The loan is classified as 90-plus-days
delinquent in its payments.  The loan is secured by a 250,322-sq.-
ft. office property in Southfield, Mich.  The loan was transferred
to the special servicer in August 2009.  According to the special
servicer, a deed-in-lieu agreement is being finalized.  There is a
$14.3 million ARA in effect against the loan.  Standard & Poor's
expects a significant loss upon the eventual resolution of this
loan.

The Highland Gardens Apartments loan ($3.3 million total exposure,
0.5%) is the second-largest loan with the special servicer.  The
loan is classified as 90-plus-days delinquent in its payments.
The loan is secured by a 100-unit multifamily property in
Chamblee, Ga.  The loan was transferred to the special servicer in
November 2009.  The special servicer is in the process of
obtaining the title to the property.  Standard & Poor's expects a
moderate loss upon the eventual resolution of this asset.

In addition to the specially serviced loans, S&P determined two
($2.2 million; 0.4%) loans to be credit-impaired.  The larger of
these is the 7100 Pines Plaza loan ($1.8 million, 0.3%).  The loan
is secured by a 48,498-sq.-ft. retail property in Pembroke Pines,
Fla.  The loan appears on the master servicer's watchlist due to a
low DSC of 0.52x and 67.0% occupancy as of December 2009.  This
compares to 1.53x DSC and 93.0% occupancy at issuance.  Given the
property's performance decline, S&P considers this loan to be at
an increased risk of default and loss.

The Westway Plaza loan ($383,615, 0.1%) is secured by a 14,850-
sq.-ft. retail property in Westland, Mich.  The loan appears on
the master servicer's watchlist due to a low DSC of 0.77x and
61.0% occupancy as of June 2010.  This compares to a DSC of 1.22x
and 100.0% occupancy at issuance.  S&P considers this loan to be
at an increased risk of default and loss given the property's
performance decline.

                       Transaction Summary

As of the October 2010 remittance report, the collateral pool
had an aggregate trust balance of $624.9 million, down from
$909.6 million at issuance.  The pool includes 175 loans, down
from 239 at issuance.  The master servicer, Berkadia Commercial
Mortgage, provided full-year 2008, full-year 2009, or interim-2010
financial information for 94.0% of the nondefeased loans and
nonCOOP loans in the pool (NCB FSB is the master servicer for the
COOP loans).  S&P calculated a weighted average DSC of 1.59x for
the pool based on the reported figures.  S&P's adjusted DSC and
LTV ratio were 1.44x and 70.2%, respectively.  S&P's adjusted DSC
and LTV figures exclude the transaction's defeased loans
($95.3 million, 15.3%), COOP loans ($71.1 million, 13.4%),
specially serviced loans, and the two loans that S&P determined
to be credit-impaired.  S&P separately estimated losses for the
specially serviced and credit-impaired loans.  S&P excluded the
COOP loans because they did not default under S&P's stress
scenario due to extremely low leverage.  The master servicers
reported a watchlist of 49 loans ($190.1 million, 30.4%),
including three of the top 10 loan exposures.  Twenty-six
($73.4 million, 11.7%) loans in the pool have a reported DSC of
less than 1.10x, and 17 ($47.0 million, 7.5%) 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 $218.3 million (34.9%).  Using
servicer-reported numbers, S&P calculated a weighted average DSC
of 1.76x for the top 10 real estate loans.  S&P's adjusted DSC and
LTV ratio for the top 10 loans are 1.40x and 79.9%, respectively.

The 77 P Street Office loan is the largest loan in the pool and on
the master servicer's watchlist.  The loan has a balance of
$59.7 million (9.6%) and is secured by a 341,701-sq.-ft. office
property in Washington, D.C.  As of December 2009, reported DSC
was 1.73x and occupancy was 100.0% as of June 2010.  According to
the master servicer, the loan appears on their watchlist due to
rollover risk associated with the District of Columbia, which
occupies 99.5% of the property's net rentable area (NRA).  In
addition, 30.8% of the total space the tenant leases is set to
expire in June 2011, and the remainder of their leased space is
set to expire in November 2011.

The Richards Building loan is the second-largest loan in the pool
and on the master servicer's watchlist.  The loan has a balance of
$29.5 million (4.7%) and is secured by a 126,065-sq.-ft. office
property in Cambridge, Mass.  As of January 2010, reported DSC was
1.64x, while occupancy was 100.0% as of March 2010.  According to
the master servicer, the loan appears on its watchlist due to
rollover risk associated with Genzyme Corp., which occupies 41.7%
of the property's NRA.  The tenant's lease is set to expire in
February 2011.

The Village Greens Shopping Center loan is the eighth-largest loan
in the pool and the third-largest loan on the master servicer's
watchlist.  The loan has a balance of $13.5 million (2.2%) and is
secured by a 75,356-sq.-ft. retail property in Staten Island, N.Y.
As of December 2009, reported DSC and occupancy were 1.10x and
100.0%, respectively.  According to the master servicer, the loan
appears on its watchlist due to rollover risk associated with King
Kullen, which occupies 47.4% of the property's NRA.  The tenant's
lease is set to expire in February 2011.

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

                         Ratings Lowered

       Morgan Stanley Dean Witter Capital I Trust 2002-IQ3
         Commercial mortgage pass-through certificates

                      Rating
                      ------
   Class      To           From         Credit enhancement (%)
   -----      --           ----         ----------------------
   C          A- (sf)      A (sf)                         9.66
   D          BBB+ (sf)    A- (sf)                        9.29
   E          BB+ (sf)     BBB (sf)                       7.11
   F          B+ (sf)      BBB- (sf)                      5.47
   G          CCC+ (sf)    BB+ (sf)                       4.38
   H          CCC- (sf)    BB- (sf)                       2.74
   J          CCC- (sf)    B- (sf)                        1.29
   K          CCC- (sf)    CCC (sf)                       0.56

                        Ratings Affirmed

       Morgan Stanley Dean Witter Capital I Trust 2002-IQ3
          Commercial mortgage pass-through certificates

          Class      Rating      Credit enhancement (%)
          -----      ------      ----------------------
          A-2        AAA (sf)                     18.21
          A-3        AAA (sf)                     18.21
          A-4        AAA (sf)                     18.21
          B          AA+ (sf)                     14.03
          L          D (sf)                        0.00
          M          D (sf)                        0.00
          N          D (sf)                        0.00
          X-1        AAA (sf)                       N/A
          X-2        AAA (sf)                       N/A
          X-Y        AAA (sf)                       N/A

                       N/A - Not applicable.


MORGAN STANLEY: S&8P Downgrades Ratings on 12 2007-XLF9 Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 12
classes of commercial mortgage pass-through certificates from
Morgan Stanley Capital I Inc.'s series 2007-XLF9, a U.S.
commercial mortgage-backed securities transaction.  Concurrently,
S&P affirmed its ratings on four other classes from the same
transaction.

The downgrades and affirmations follow S&P's analysis of the
transaction, which included the revaluation of the collateral
securing the remaining 12 floating-rate loans in the pool, two of
which are currently in special servicing.  All of the loans are
indexed to one-month LIBOR.  The primary reason for the downgrades
was downward revisions to S&P's lodging property valuations.  The
valuations declined, on average, by 23.6% from S&P's last review
in May 2009.

S&P lowered its ratings to 'CCC- (sf)' on the class M-635 and N-
635 raked certificates.  These certificates derive 100% of their
cash flow from a subordinate nonpooled component of the 635
Madison loan.  In addition, S&P affirmed the 'BB (sf)' rating on
the class M-BEL raked certificate, which derives 100% of its cash
flow from a subordinate nonpooled component of the Belltel Lofts
loan.  The lowered and affirmed ratings follow S&P's analysis of
the respective loans and are described further below.

The class X certificate is an interest-only certificate with a
balance that references the aggregate certificate balances of the
pooled principal and interest certificates in the transaction.
S&P affirmed its rating on class X based on its current criteria.

S&P previously downgraded class L to 'D (sf)' on Oct. 7, 2010, due
to ongoing interest shortfalls.  According to the Oct. 15, 2010,
trustee remittance report, class L has accumulated outstanding
interest shortfalls of $32,903.

The trust contains 12 loans that are secured by these asset types:
lodging ($433.5 million, 39.6% of the pooled trust balance),
office ($485.8 million, 44.4%); a ground lease ($61.7 million,
5.6%), casino/hotel ($53.1 million, 4.9%), residential
condominium conversion ($37.4 million, 3.4%), and a land parcel
($22.5 million, 2.1%).

                       Lodging Collateral

Lodging properties secure three loans in the pool totaling
$433.5 million (39.6% of the pooled trust balance).  These
properties are in Orlando, Fla. (20.1% of the pooled trust
balance), Phoenix (14.8%), Tarrytown, N.Y. (2.7%), and Texas
(2.0%).  S&P based its hotel analyses, in part, on a review of the
borrowers' operating statements for full-year 2009, operating
statements for year-to-date 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 properties in 2009 compared
with 2008.  S&P's analysis also considered current conditions in
the local lodging markets that have occurred for year-to-date
2010.  According to STR, the Orlando and Phoenix lodging markets
posted a 1.0% increase and a 0.5% decrease, respectively, in
revenue per available room for the first nine months of 2010
compared with 2009.  In comparison, the general U.S. hotel
industry reported a 4.5% increase in RevPAR for the same period.
S&P's lodging property valuations have declined, on average, by
23.6% from the levels S&P assessed in its last review dated
May 27, 2009.

                    The Largest Lodging Loan

The MSREF Resort Portfolio loan, the largest loan in the pool, is
secured by three full-service luxury resort hotels totaling 2,532
rooms in Orlando and Phoenix.  The loan has a whole loan balance
of $729.9 million that consists of a $545.0 million senior
participation interest and two non-trust junior participation
interests totaling $184.9 million.  The senior participation
interest is further divided into three pari passu pieces, of which
one piece totaling $381.5 million makes up 34.9% of the pooled
trust balance.  In addition, the equity interests in the borrower
of the whole loan secure four mezzanine loans totaling
$265.4 million.  The master servicer, Midland Loan Services Inc.,
reported a combined in-trust debt service coverage of 7.01x for
year-end 2009 and occupancy of 68.2% for the 12 months ended
June 30, 2010.  S&P's adjusted valuation, which yielded a stressed
in-trust loan-to-value ratio of 98.7%, has fallen 23.6% since
S&P's last review.

The valuation decline is primarily due to a drop in average daily
rate and occupancy.  The loan matures on May 9, 2011, and has one
12-month extension option remaining.

              Lodging Loan With The Special Servicer

There is one lodging loan in the pool with the special servicer.
The Hyatt Place Portfolio loan, the smallest loan in the pool, has
a trust balance of $22.0 million (2.0% of the pooled trust
balance) and a whole-loan balance of $49.0 million.  The loan is
secured by four limited service, Hyatt Place flagged hotels
totaling 512 rooms in Austin, Grand Prairie, Houston, and San
Antonio, Texas.  The loan was transferred to the special servicer,
Berkadia Commercial Mortgage LLC, on Feb. 18, 2010, due to
imminent default after the borrower indicated that it was unable
to payoff the loan by its April 9, 2010, maturity.  Berkadia has
indicated that the resolution timing for this loan is uncertain as
the borrower has filed for bankruptcy protection.
Berkadia has stated that under the direction of the bankruptcy
court, the borrower will make adequate protection payments
starting in September 2010.  Berkadia is waiting to review the
borrower's plan of organization.  The updated July 1, 2010,
appraisals value the properties at $38.3 million.  The master
servicer reported an in-trust combined DSC of 2.18x for year-end
2009 and occupancy of 65.8% for the 12 months ended May 31, 2010.
S&P's adjusted valuation, which yielded a stressed in-trust LTV
ratio of 114.6%, is down 12.9% since its last review.  The
valuation decline is mainly due to increased operating expenses.

                        Office Collateral

Office properties secure five loans totaling $485.8 million (44.4%
of the pooled trust balance).  The office properties are located
in Manhattan (19.4% of the pooled trust balance), Chicago (12.8%),
Denver (10.1%), and Sacramento (2.1%).  S&P based its analysis of
the office properties on its review of the borrowers' operating
statements for full-year 2009 and year-to-date 2010 (where
available), the borrowers' 2010 budgets, as well as the borrowers'
2010 rent rolls.  Based on S&P's analysis, its office property
valuations have declined, on average, by 2.4% since its last
review.

                     The Largest Office Loan

The 14 Wall Street loan, the second-largest loan in the pool, has
a trust and whole-loan balance of $145.0 million (13.3% of the
pooled trust balance).  In addition, the equity interests in the
borrower of the whole loan secure mezzanine debt with a maximum
balance of $175.0 million.

The loan is secured by a 1.0 million-sq.-ft. 37-story office
building in downtown Manhattan.  Midland reported an in-trust DSC
of 2.07x for year-end 2009 and 74.2% occupancy as of June 2010.
S&P's adjusted valuation, which yielded a stressed in-trust LTV
ratio of 82.9%, is comparable to the levels S&P assessed in its
last review.  The loan matures on May 9, 2011, and has one 12-
month extension option remaining.

      Office Loan With Maturity Within The Next Three Months

The Herakles Data Center loan, the 10th-largest loan in the pool,
has a trust balance of $23.6 million (2.1% of the pooled trust
balance) and a whole-loan balance of $34.3 million.  The loan is
secured by a 92,200-sq.-ft. telecommunications facility containing
52,500 sq. ft. of raised floor area in Sacramento.  Midland
reported an in-trust DSC of 1.89x for year-end 2009 and 100%
occupancy as of August 2010.  S&P's adjusted valuation, which
yielded a stressed in-trust LTV ratio of 47.3%, is down 12.9%
since its last review.  The loan matures on Dec. 9, 2010.  Midland
has stated that the borrower has given notice to exercise one of
its two one-year extension options.

                  Other Specially Serviced Loan

The Reunion Development loan has a trust and whole-loan balance of
$35.0 million, which consists of a $22.5 million senior pooled
component (2.1% of the pooled trust balance) and a $12.5 million
subordinate nonpooled component raked to the class M-RND and N-RND
certificates.  Both of these classes are not rated by Standard &
Poor's.  The loan is secured by 419 acres of undeveloped land that
are part of a 2,300-acre master planned community in Reunion, Fla.
(near Orlando).  The loan was transferred to the special servicer,
KeyBank Real Estate Capital, on Aug. 14, 2009, after the borrower
did not pay off the loan at its Aug. 9, 2009, maturity.  According
to KeyBank, the borrower has been operating under a forbearance
agreement that expired on Oct. 10, 2010.  KeyBank stated that it
is in the process of amending the forbearance period to Dec. 31,
2010, to provide the borrower additional time to market and sell
the property.  The updated Oct. 5, 2009, appraisal valued the
property at $4.2 million.  S&P expects a severe loss upon the
eventual resolution of this asset.

            Other Loans With Rated Raked Certificates

Standard & Poor's rates the class M-BEL, M-635, and N-635 raked
certificates.  Details are:

The 635 Madison loan, the sixth-largest loan in the pool, has a
trust and whole loan balance of $69.1 million, which consists of a
$61.7 million senior pooled component (5.6% of the pooled trust
balance) and a $7.4 million subordinate nonpooled component that
supports the class M-635 and N-635 raked certificates.  In
addition, the equity interests in the borrower of the whole loan
secure $15.0 million of mezzanine debt.  The loan is secured by
the fee interest in land subject to a ground lease underneath 635
Madison Avenue, a 143,800-sq.-ft., 19-story class B office and
ground floor retail property in midtown Manhattan.  According to
the transaction's documents, the $1.0 million ground rent amount
was scheduled to be adjusted in May 2009 to a percentage of the
fair market value of the land, as unimproved and vacant.  At
origination and in S&P's last review, using the June 2007
appraisal value, the borrower had expected a substantial increase
in the ground rent amount to $6.8 million.  However, the ground
rent amount was in arbitration, and the arbiter has recently ruled
on a new ground rent amount of $3.7 million which is significantly
below expectations.  Accordingly, S&P lowered its ratings to 'CCC-
(sf)' on both raked classes.  Midland reported a 2.89x DSC for the
12 months ended June 30, 2010.The 635 Madison loan was transferred
to the special servicer, Berkadia, on April 1, 2010, due to
imminent maturity default.  The loan matured on Aug. 9, 2010.
Berkadia has indicated that the loan has since been modified (on
June 28, 2010) and returned to the master servicer on Aug. 12,
2010.  The modification terms included, among other items, a
partial paydown of the principal balance and a maturity date
extension to August 9, 2012.  As of the Oct. 15, 2010, trustee
remittance report, class N-635 incurred $29,292 of principal
losses due to additional trust expenses.

The Belltel Lofts loan, the eighth-largest loan in the pool, has a
current whole-loan balance of $63.3 million that consists of a
$37.4 million senior pooled component (3.4% of the pooled trust
balance), a $1.6 million subordinate nonpooled component that is
raked to the class M-BEL certificate, and a $24.3 million non-
trust subordinate junior participation.  The loan is secured by
122 unsold units in a 249-unit for-sale residential condominium
conversion project in Brooklyn, N.Y.  S&P's adjusted valuation,
yielding a stressed in-trust LTV ratio of 74.9%, is comparable to
the levels S&P assessed in its last review.  Accordingly, S&P
affirmed its 'BB (sf)' rating on class M-BEL.  The loan matures on
Feb. 9, 2011, and has no extension options remaining.

               Ratings Lowered (Pooled Certificates)

                   Morgan Stanley Capital I Inc.
  Commercial mortgage pass-through certificates series 2007-XLF9

                Rating
                ------
    Class    To           From           Credit enhancement (%)
    -----    --           ----           ----------------------
    A-2      A+ (sf)      AA (sf)                         33.98
    B        BBB+ (sf)    A+ (sf)                         29.95
    C        BBB- (sf)    A (sf)                          26.49
    D        BB+ (sf)     BBB+ (sf)                       23.04
    E        BB (sf)      BBB (sf)                        19.58
    F        B+ (sf)      BB+ (sf)                        16.13
    G        B- (sf)      BB- (sf)                        12.67
    H        CCC (sf)     B+ (sf)                          9.21
    J        CCC- (sf)    CCC+ (sf)                        5.76
    K        CCC- (sf)    CCC (sf)                         2.88

              Ratings Lowered (Nonpooled Certificates)

                   Morgan Stanley Capital I Inc.
  Commercial mortgage pass-through certificates series 2007-XLF9

                Rating
                ------
    Class    To           From           Credit enhancement (%)
    -----    --           ----           ----------------------
    M-635    CCC- (sf)    BBB+ (sf)                         N/A
    N-635    CCC- (sf)    BBB- (sf)                         N/A

              Ratings Affirmed (Pooled Certificates)

                   Morgan Stanley Capital I Inc.
  Commercial mortgage pass-through certificates series 2007-XLF9

    Class          Rating                Credit enhancement (%)
    -----          ------                ----------------------
    A-1            AAA (sf)                              53.76
    L              D (sf)                                 0.00
    X              AAA (sf)                                N/A

             Rating Affirmed (Nonpooled Certificate)

                   Morgan Stanley Capital I Inc.
  Commercial mortgage pass-through certificates series 2007-XLF9

    Class          Rating                Credit enhancement (%)
    -----          ------                ----------------------
    M-BEL          BB (sf)                                 N/A

                       N/A - Not applicable.


NEW CENTURY: Moody's Downgrades Ratings on 11 Tranches
------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 11
tranches from 2 RMBS transactions issued by New Century
Alternative Mortgage Loan Trust.  The collateral backing these
deals primarily consists of first-lien, fixed rate Alt-A
residential mortgages.

                        Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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: New Century Alternative Mortgage Loan Trust 2006-ALT1

  -- Cl. AF-2, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-3, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-4, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-5, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-6, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

Issuer: New Century Alternative Mortgage Loan Trust 2006-ALT2

  -- Cl. AF-2, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-3, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-4, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-5, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-6A, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AF-6B, Downgraded to C (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade


NEWGATE FUNDING: Moody's Reviews Ratings on Various Classes
-----------------------------------------------------------
Moody's Investors Service has placed under review for possible
downgrade classes Ba, Bb, Cb, D and E issued by Newgate Funding
PLC: Series 2007-3.  The review was prompted by the worse-than-
expected performance of the collateral backing the notes.
According to Moody's analysis, the credit enhancement available
under the affected notes is likely to be not fully sufficient to
support the loss assumptions for the mortgage portfolio.

                      Transaction Overview

Newgate Funding PLC: Series 2007-3 closed in December 2007 and the
current pool factor is approximately 82.6%.  The assets supporting
the notes are first-lien mortgage loans secured by residential
properties located in England, Wales, Scotland and Northern
Ireland.  The transaction was already reviewed in March 2009 on
the basis of the performance data as of December 2008.  At that
time, the expected loss for the mortgage portfolio was increased
from 1.88% to 3.5% of the original portfolio balance.

Since December 2008, 90+ arrears (including outstanding
repossessions) have increased from 9.8% to 15.3% of the current
portfolio balance.  However, 90+ delinquencies have decreased by
approximately GBP70 million since the peak of 23.6% reached in
December 2009.  Over the same time horizon, cumulative losses have
increased from 0.01% to the current level of 1.43% of the original
portfolio balance.  In addition, mortgage loans for an amount of
7.5% of the current portfolio balance were previously delinquent
by more than 90 days and have been subject to capitalization of
arrears.  According to the investor report as of September 2010,
550 loans, corresponding to approximately 10.7% of the current
portfolio balance, have had arrears capitalized.  The reserve fund
is currently at its target level, equal to GBP23,799,400.

                       Transaction Review

According to the data from the latest investor report,
approximately two-thirds of the decrease in the 90+ delinquencies
since the arrears peak in December 2009 are associated with
arrears capitalizations.  Taking into account the performance of
the collateral and the levels of arrears capitalization to date,
the performance of the portfolio since the last review has been
worse than initially expected.  During its analysis, the rating
agency has also taken into account the levels of credit
enhancement available to absorb the future projected losses on the
underlying mortgage portfolio.  After performing cash flow
sensitivities on the stability of the current ratings, the worse-
than-expected performance of the collateral has prompted Moody's
to review the ratings of the affected notes for possible
downgrade.

The full review of the ratings of the affected notes will take
into account the current capital structure and credit enhancement
levels.  As part of its detailed transaction review, Moody's will
fully reassess its lifetime loss expectation reflecting the
collateral performance to date as well as the future macro-
economic environment.  Moody's will also test different
distribution of losses, in order to quantify the potential rating
impact of a more backloaded loss distribution, which could result
from the re-default of loans previously in arrears.  Moody's will
also use updated loan-by-loan information to revise its MILAN Aaa
credit enhancement.  Loan-by-loan information will also allow
Moody's to validate its assumptions with regards to which loans
have a higher default propensity.  The lifetime loss and the MILAN
Aaa credit enhancement are the key parameters used by Moody's to
calibrate its loss distribution curve, which is one of the core
inputs in Moody's cash-flow model.

Moody's has also factored into its analysis the negative sector
outlook for UK non-conforming RMBS.  The sector outlook reflects
these expectations of key macro-economic indicators: GDP to
increase by 1.6% in 2010 and by 2.3% in 2011, unemployment to stay
at approximately 7.9% in 2010 and 2011, house prices to remain
relatively flat over the next year.

                      List Of Affected Notes

The classes of notes affected by the rating review are detailed
below.

Issuer: Newgate Funding PLC: Series 2007-3

  -- GBP31.2M Ba Notes, A3 (sf) Placed Under Review for Possible
     Downgrade; previously on March 25, 2009 Downgraded to A3 (sf)

  -- EUR42M Bb Notes, A3 (sf) Placed Under Review for Possible
     Downgrade; previously on March 25, 2009 Downgraded to A3 (sf)

  -- EUR44M Cb Notes, Ba1 (sf) Placed Under Review for Possible
     Downgrade; previously on March 25, 2009 Downgraded to Ba1
     (sf)

  -- GBP12.75M D Notes, B2 (sf) Placed Under Review for Possible
     Downgrade; previously on March 25, 2009 Downgraded to B2 (sf)

  -- GBP11.5M E Notes, Caa2 (sf) Placed Under Review for Possible
     Downgrade; previously on March 25, 2009 Downgraded to Caa2
     (sf)

Moody's ratings address the expected loss posed to investors by
the legal final maturity of the notes.  Moody's ratings address
only the credit risks associated with the transactions.  Other
non-credit risks have not been addressed, but may have a
significant effect on yield to investors.


PHH ALTERNATIVE: Moody's Downgrades Ratings on 17 Tranches
----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 17
tranches and confirmed the ratings of 4 tranches from 3 RMBS
transactions issued by PHH Alternative Mortgage Trust.  The
collateral backing these deals primarily consists of first-lien,
fixed and adjustable rate Alt-A residential mortgages.

                        Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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: PHH Alternative Mortgage Trust, Series 2007-1

  -- Cl. I-A-1, Confirmed at B3 (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. I-A-2, Confirmed at Caa1 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. I-A-3, Downgraded to C (sf); previously on Jan. 14, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

Issuer: PHH Alternative Mortgage Trust, Series 2007-2

  -- Cl. 1-A-1, Downgraded to B2 (sf); previously on Jan. 14, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-2, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-3, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-4, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A-5, Downgraded to C (sf); previously on Jan. 14, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-2, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-3, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-4, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-5, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A-6, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A-1, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A-2, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A-1, Confirmed at B3 (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

Issuer: PHH Alternative Mortgage Trust, Series 2007-3

  -- Cl. A-1, Confirmed at B2 (sf); previously on Jan. 14, 2010 B2
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-2, Downgraded to Caa1 (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-3, Downgraded to Caa1 (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-4, Downgraded to C (sf); previously on Jan. 14, 2010
     Caa3 (sf) Placed Under Review for Possible Downgrade


PHH WACHOVIA: Moody's Downgrades Ratings on Six Tranches
--------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 6 tranches
from 2 RMBS transactions issued by PHH Wachovia Mortgage Loan
Trust.  The collateral backing these deals primarily consists of
first-lien, fixed and adjustable rate Alt-A residential mortgages.

                        Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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: Wachovia Mortgage Loan Trust, Series 2006-ALT1

  -- Cl. A-1, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-2, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-3, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

Issuer: Wachovia Mortgage Loan Trust, Series 2006-AMN1

  -- Cl. A-1, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     B1 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. A-3, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade


PHOENIX CLO: S&P Raises Ratings on Various Classes of Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B, and C notes issued by Phoenix CLO I Ltd., a collateralized
loan obligation transaction managed by ING Alternative Asset
Management LLC.  In addition, S&P removed its rating on the class
A notes from CreditWatch with positive implications and affirmed
its ratings on the class X and D notes.

The upgrades reflect the improved performance S&P has observed in
the transaction's underlying asset portfolio since November 2009,
when S&P lowered the ratings on all of the notes except for the
class X notes.  The November 2009 downgrades followed a review of
the transaction under S&P's criteria for rating corporate
collateralized debt obligations.

According to the Sept. 28, 2009, trustee report, the transaction
held approximately $34 million in defaulted obligations and
$63 million in underlying obligors with a rating, either by
Standard & Poor's or another rating agency, in the 'CCC' range.
As a result, Phoenix CLO I was failing its class A, B, C, and D
overcollateralization ratios, causing a deferral of the interest
for the class B, C, and D notes.  Since that time, a number of
defaulted obligors held in the deal emerged from bankruptcy, while
recoveries on some defaulted assets were higher than their
carrying values in the O/C ratio test calculations.  This, in
combination with a reduction in the 'CCC' range assets and a
$9 million paydown on the class A notes, benefited all O/C tests
in the transaction.  For example, the class A O/C ratio test had
increased to 125.17% by Sept. 28, 2010, from 116.91% as of
Sept. 28, 2009.  As of Sept. 28, 2010, only the transaction's
excess interest deflection test was failing, which diverts excess
interest to purchase additional assets.  To date, Phoenix CLO I
Ltd. transaction has paid down approximately 4.85% of the class A
notes' 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 deems necessary.

                  Rating And Creditwatch Actions

                        Phoenix CLO I Ltd.

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

                        Ratings Affirmed

                        Phoenix CLO I Ltd.

                      Class       Rating
                      -----       ------
                      X           AAA (sf)
                      D           CC (sf)


PROTECTIVE FINANCE: Moody's Upgrades Ratings on Six Classes
-----------------------------------------------------------
Moody's Investors Service upgraded the ratings of six classes and
affirmed three classes of Protective Finance Corporation II,
Commercial Mortgage FASIT Certificates, Series I:

  -- Cl. C-1, Affirmed at Aaa (sf); previously on Jan. 4, 2008
     Upgraded to Aaa (sf)

  -- Cl. C-2, Affirmed at Aaa (sf); previously on Jan. 4, 2008
     Upgraded to Aaa (sf)

  -- Cl. C-3, Affirmed at Aaa (sf); previously on Jan. 4, 2008
     Upgraded to Aaa (sf)

  -- Cl. D-1, Upgraded to Aa2 (sf); previously on Oct. 6, 2006
     Upgraded to A1 (sf)

  -- Cl. D-2, Upgraded to Aa2 (sf); previously on Oct. 6, 2006
     Upgraded to A1 (sf)

  -- Cl. D-3, Upgraded to Aa2 (sf); previously on Oct. 6, 2006
     Upgraded to A1 (sf)

  -- Cl. E-1, Upgraded to Ba1 (sf); previously on Oct. 6, 2006
     Upgraded to Ba2 (sf)

  -- Cl. E-2, Upgraded to Ba1 (sf); previously on Oct. 6, 2006
     Upgraded to Ba2 (sf)

  -- Cl. E-3, Upgraded to Ba1 (sf); previously on Oct. 6, 2006
     Upgraded to Ba2 (sf)

                        Ratings Rationale

The upgrades are due to increased credit subordination levels due
to loan payoffs and amortization and overall stable pool
performance.  The pool has paid down by 61% since Moody's last
review.

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
1.7% of the current balance.  Moody's stressed scenario loss is
4.7% 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 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 prior
full review is summarized in a press release dated January 4,
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 six months.

                         Deal Performance

As of the October 25, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 90% to $83.4
million from $845.4 million at securitization.  The Certificates
are collateralized by 115 mortgage loans ranging in size from less
than 1% to 4% of the pool, with the top ten loans representing 25%
of the pool.

Two loans have been liquidated from the pool, resulting in an
aggregate realized loss of $752,907 (51% loss severity on an
average).  There are no loans currently on the watchlist or in
special servicing.

Moody's was provided with full year 2009 for 61% of the pool.
Moody's weighted average LTV is 51% compared to 50% at Moody's
prior review.  Moody's net cash flow reflects a weighted average
haircut of 16% to the most recently available net operating
income.  Moody's value reflects a weighted average capitalization
rate of 10.2%.

Moody's actual and stressed DSCRs are 1.10X and 3.05X,
respectively, compared to 2.40X and 2.39X 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.

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 75 compared to 115 at Moody's prior review.

Approximately 75% of the loans (65% of the pool balance) are
secured by single tenant retail properties, many of which are
owner occupied.  The top exposures are Rite Aid Corporation (22%
of the pool; Moody's senior unsecured rating Caa3, stable outlook)
and CVS/Caremark Corp. (17%; Moody's senior unsecured rating Baa2,
stable outlook).

The top three conduit loans represent 10% of the pool balance.
The largest loan is the Pearman Dairy Plaza Loan ($3.6 million --
4.1%), which is secured by a 68,151 square foot shopping center
located in Anderson, South Carolina.  As of June 2010 the property
was 75% leased.  Performance has been stable since last review.
Moody's LTV and stressed DSCR are 111% and 0.88X, respectively,
compared to 115% and 0.85X at last review.

The second largest loan is the Theodore Dawes Plaza Loan
($3.0 million -- 3.4%), which is secured by a 124,014 square foot
shopping center located in Mobile, Alabama.  As of June 2010 the
property was 72% leased.  Performance has declined since last
review due to lower revenues.  Moody's LTV and stressed DSCR are
68% and 1.49X, respectively, compared to 52% and 2.08X at last
review.

The third largest loan is the Bi-Lo Shopping Center Loan
($2.2 million -- 2.4%), which is secured by a 51,991 square foot
grocery anchored retail center.  As of June 2010 the property was
94% leased.  Performance has declined since last review but the
loan has benefited from amortization.  The loan has amortized 22%
since last review.  Moody's LTV and stressed DSCR are 54% and
1.90X, respectively, compared to 52% and 1.92X at last review.


PORTER SQUARE: Fitch Cuts Rating on CDO I Class B Notes to 'Csf'
----------------------------------------------------------------
Fitch Ratings has downgraded one class, affirmed two classes and
revised Rating Outlooks of Porter Square CDO I, Ltd./Inc. notes as
indicated:

  -- $3,263,735 class A-3 notes affirmed at 'AAsf/LS5'; Outlook to
     Stable from Negative;

  -- $24,000,000 class B notes downgraded to 'Csf' from 'CCsf';

  -- $17,765,725 class C notes affirmed at 'Csf'.

The Class A-2 notes have paid in full.

The rating downgrade reflects the deterioration to the portfolio
since the last rating action in November 2009.  Approximately
42.7% of the portfolio has been downgraded since November 2009.

The affirmation of the class A-3 notes is attributed to the
increase in credit enhancement available to the notes resulting
from principal amortizations.  The class A-3 notes have paid off
87.4% since closing.  It is likely that they will be paid off in
2011, as reflected by the Stable Rating Outlook assigned to the
notes.

Defaulted collateral as defined by the trustee totals $27,108,116
or 58.1% of the portfolio.  Interest due to class B is being
partially paid through the use of principal.  This class is
reliant on defaulted collateral to pay off, therefore, default is
inevitable and it has been downgraded to 'Csf'.  The class C notes
continue to defer interest.

Porter Square I is a structured finance collateralized debt
obligation that closed on July 31, 2003.  The portfolio is
monitored by TCW Asset Management Company.  The portfolio is
composed of 55.5% residential mortgage-backed securities, 37.3%
CDOs, 7% commercial mortgage-backed securities, and 0.2% corporate
bonds.


PORTER SQUARE: Fitch Cuts Rating on CDO II Class A-2 Notes to Csf
-----------------------------------------------------------------
Fitch Ratings has downgraded one and affirmed three classes of
Porter Square CDO II, Ltd./Inc. notes:

  -- $58,785,192 class A-2 notes downgraded to 'Csf' from 'CCsf';
  -- $23,500,000 class B notes affirmed at 'Csf';
  -- $10,775,177 class C notes affirmed at 'Csf';
  -- $9,513,504 class D notes affirmed at 'Csf'.

The rating downgrade reflects the deterioration to the portfolio
since the last rating action in November 2009.  Approximately
45.6% of the portfolio has been downgraded since November 2009.

Defaulted collateral as defined by the trustee totals $27,313,131
or 42.0% of the portfolio.  The class A-2 and class B notes are
still receiving timely interest payments although part of the
interest to class A-2 and all interest to class B is being
fulfilled through the use of principal.  All classes of notes are
reliant on defaulted collateral to be paid off.  Therefore,
default is inevitable for all classes of notes and class A-2 has
been downgraded to 'Csf'.

Porter Square II is a structured finance collateralized debt
obligation that closed on Oct. 27, 2004.  The portfolio is
monitored by TCW Asset Management Company.  The portfolio is
composed of 51.1% residential mortgage-backed securities, 41.6%
CDOs, 6.2% commercial mortgage-backed securities, and 1.1% asset-
backed securities.


PORTER SQUARE: Fitch Cuts Rating on CDO III A-2 & B Notes to 'Dsf'
------------------------------------------------------------------
Fitch Ratings has downgraded two and affirmed three classes of
Porter Square CDO III, Ltd./Inc. notes:

  -- $145,197,619 class A-1 notes affirmed at 'Csf';
  -- $56,000,000 class A-2 notes downgraded to 'Dsf' from 'Csf';
  -- $48,000,000 class B notes downgraded to 'Dsf' from 'Csf';
  -- $15,397,081 class C notes affirmed at 'Csf';
  -- $25,086,023 class D notes affirmed at 'Csf'.

The rating downgrades reflect the default in the payment of
interest to class A-2 and class B notes.  These classes are non-
deferrable and accordingly, have been downgraded to 'Dsf'.

Porter Square III entered an Event of Default on Oct. 1, 2009,
when the class A overcollateralization test fell below 100%.
Acceleration of maturity occurred on Dec. 23, 2009; consequently,
all interest and principal after the applicable fees and expenses
is going to pay the interest due to and to pay down class A-1.

Defaulted collateral as defined by the trustee totals $136,152,400
or 72.5% of the portfolio.  All classes of notes are reliant on
defaulted collateral to pay off.  Default is inevitable for all
notes.  The class C and class D notes are deferring interest.

Porter Square III is a structured finance collateralized debt
obligation that closed on Oct. 25, 2005.  The portfolio is
monitored by TCW Asset Management Company.  The portfolio is
composed of 71.8% residential mortgage-backed securities and 28.2%
CDOs.


PRETSL COMBINATION: Moody's Cuts Rating on XXVI-2 Certs. to C (sf)
------------------------------------------------------------------
Moody's Investors Service announced that it has downgraded two
combination note securities whose underlying components are
significantly linked to bank and insurance trust preferred CDO
tranches.

Issuer: PreTSL Combination Series P XXVI-1 Trust

  -- PreTSL US$500,000 Combination Series P XXVI-1 Certificates
     (current rated balance of $441,703.81), Downgraded to A1
     (sf); previously on April 28, 2009 Downgraded to Aa1 (sf)

Issuer: PreTSL Combination Series P XXVI-2 Trust

  -- PreTSL US$11,500,000 Combination Series P XXVI-2
     Certificates (current rated balance of $1,342,262.35),
     Downgraded to C (sf); previously on April 28, 2009 Downgraded
     to Ca (sf)

                        Ratings Rationale

PreTSL Combination Series P XXVI-1 Trust and PreTSL Combination
Series P XXVI-2 Trust, issued on June 21, 2007, are combination
note securities whose ratings are based primarily on the credit
quality of the underlying securities and the legal structure of
the transaction.

The rating actions are a reflection of the change in the ratings
of the underlying securities backing the combination notes.
PreTSL US$500,000 Combination Series P XXVI-1 Certificates is
composed of a treasury strip, and the Class A-1 Notes and
Subordinate Income Notes issued by Preferred Term Securities XXVI,
Ltd. while PreTSL US$11,500,000 Combination Series P XXVI-2
Certificates is composed of the Class C-1 Notes and Subordinate
Income Notes issued by Preferred Term Securities XXVI, Ltd.  As
of the last rating action on April 28, 2009, the Class A-1 Notes
and Class C-1 Notes were rated A1 (sf) and Ca (sf) respectively.
The current ratings for the Class A-1 Notes and Class C-1 Notes
are Ba1 (sf) and C (sf) respectively.

The transaction portfolio collateralizing the underlying tranches
issued by the TRUP CDO, Preferred Term Securities XXVI, Ltd., is
mainly composed of trust preferred securities issued by small to
medium sized U.S. community banks and insurance companies that are
generally not publicly rated by Moody's.  To evaluate their credit
quality, Moody's derives credit scores for these non-publicly
rated assets and evaluates the sensitivity of the rated
transactions to their volatility, as described in Moody's Rating
Methodology "Updated Approach to the Usage of Credit Estimates in
rated Transactions", October 2009.  The effect of the 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.

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, 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 CDOROM 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.  CDOROM 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.


PRUDENTIAL SECURITIES: Moody's Takes Actions on 1999-NRF1 Notes
---------------------------------------------------------------
Moody's Investors Service upgraded the rating of one class,
downgraded three classes and affirmed three classes of Prudential
Securities Secured Financing Corporation, Commercial Mortgage
Pass-Through Certificates, Series 1999-NRF1.

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

  -- Cl. F, Upgraded to Aaa (sf); previously on April 15, 2009
     Upgraded to A1 (sf)

  -- Cl. G, Affirmed at Baa3 (sf); previously on Nov. 1, 2007
     Upgraded to Baa3 (sf)

  -- Cl. H, Downgraded to B2 (sf); previously on Oct. 23, 2006
     Upgraded to Ba2 (sf)

  -- Cl. J, Downgraded to Caa2 (sf); previously on March 25, 1999
     Definitive Rating Assigned B1 (sf)

  -- Cl. K, Downgraded to C (sf); previously on April 15, 2009
     Downgraded to Caa3 (sf)

  -- Cl. L, Affirmed at C (sf); previously on April 15, 2009
     Downgraded to C (sf)

                        Ratings Rationale

The upgrade is due to the significant increase in subordination
due to loan payoffs and amortization.  The pool has paid down by
54% 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 and concerns about refinance risk
associated with loans approaching maturity in an adverse
environment.  Twelve loans, representing 69% of the pool, have
either matured or mature within the next six months.  Three of
these loans, representing 41% 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
29.6% of the current balance.  At last review, Moody's cumulative
base expected loss was 12.3%.  Moody's stressed scenario loss is
32.5% 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 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 6 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 April 15, 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 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 92% to $78.8
million from $928.9 million at securitization.  The Certificates
are collateralized by 23 mortgage loans ranging in size from less
than 1% to 23% of the pool, with the top ten loans representing
76% of the pool.  The pool contains 14 conduit loans representing
45% of the pool.  The remaining pool consists of one defeased loan
(4% of the pool) and eight specially serviced loans (51% of the
pool).

Five 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 deal
performance.

Eighteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $11.8 million (25% loss severity
overall).  Eight loans, representing 51% of the pool, are
currently in special servicing.  Most of the loans were
transferred to special servicing due to maturity default.  The
largest specially serviced loan is Louisville Marriott East Loan
($17.9 million - 23%), which is secured by a 254 room hotel
located in suburban Louisville, Kentucky.  The hotel's performance
has been negatively impacted by new competition in the area.  The
loan transferred to special servicing in January 2009 for imminent
default and is now real estate owned.  The remaining seven
specially serviced loans are secured by a mix of property types.
Moody's has estimated an aggregate $21.9 million loss (55%
expected loss on average) for the specially serviced loans.

Based on the most recent remittance statement, Classes J through
M have experienced cumulative interest shortfalls totaling
$1.8 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 90%
of the pool's performing conduit loans.  Excluding specially
serviced loans, Moody's weighted average LTV is 65% compared to
74% at Moody's prior review.  Moody's net cash flow reflects a
weighted average haircut of 11% to the most recently available net
operating income.  Moody's value reflects a weighted average
capitalization rate of 10.3%.

Excluding specially serviced loans, Moody's actual and stressed
DSCRs are 1.77X and 2.35X, respectively, compared to 1.51X and
1.77X 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 loans.  The performing conduit component, which
represents 45% of the pool, is stable and is performing in line
with Moody's expectations.


SALOMON BROTHERS: Moody's Downgrades Ratings on Five Classes
------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five classes
and affirmed six classes of Salomon Brothers Commercial Mortgage
Trust 2001-C1, Commercial Mortgage Pass-Through Certificates,
Series 2001-C1:

  -- Cl. A-3, Affirmed at Aaa (sf); previously on Jan. 3, 2002
     Assigned Aaa (sf)

  -- Cl. X, Affirmed at Aaa (sf); previously on July 31, 2001
     Definitive Rating Assigned Aaa (sf)

  -- Cl. B, Affirmed at Aaa (sf); previously on Dec. 13, 2006
     Upgraded to Aaa (sf)

  -- Cl. C, Affirmed at Aa1 (sf); previously on Dec. 13, 2006
     Upgraded to Aa1 (sf)

  -- Cl. D, Affirmed at Aa2 (sf); previously on Dec. 13, 2006
     Upgraded to Aa2 (sf)

  -- Cl. E, Downgraded to A3 (sf); previously on Dec. 13, 2006
     Upgraded to A1 (sf)

  -- Cl. F, Downgraded to Ba1 (sf); previously on Dec. 13, 2006
     Upgraded to Baa1 (sf)

  -- Cl. G, Downgraded to Ca (sf); previously on Oct. 1, 2009
     Downgraded to Ba3 (sf)

  -- Cl. H, Downgraded to C (sf); previously on Oct. 1, 2009
     Downgraded to Caa1 (sf)

  -- Cl. J, Downgraded to C (sf); previously on Oct. 1, 2009
     Downgraded to Ca (sf)

  -- Cl. K, Affirmed at C (sf); previously on Oct. 1, 2009
     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.  Eighty-two loans, representing 68% of the pool,
mature within the next six months.  Seventeen of these loans,
representing 15% 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
8.8% of the current balance.  At last review, Moody's cumulative
base expected loss was 5.6%.  Moody's stressed scenario loss is
10.7% 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 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 57 compared to 73 at last review.

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 1, 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 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 44% to
$530.1 million from $952.7 million at securitization.  The
Certificates are collateralized by 118 mortgage loans ranging in
size from less than 1% to 3% of the pool, with the top ten loans
representing 22% of the pool.  Nineteen loans, representing 20% of
the pool, have defeased and are collateralized with U.S.
Government securities.

Thirty-two loans, representing 28% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of 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.

Sixteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $38.9 million (37% loss severity).
These losses have resulted in 100% loss for Classes L through P
and a 41% principal loss for Class K.  Twelve loans, representing
10% of the pool, are currently in special servicing.  The largest
specially serviced loan is Westford Technology Park II Loan
($10.5 million -- 2.0% of the pool), which is secured by a 105,000
square foot office property located in Westford, Massachusetts.
The loan was transferred to speical servicing in July 2010 due to
monetary default but is current.

The remaining specially serviced loans are secured by a mix of
property types.  The master servicer has recognized appraisal
reductions totaling $12.1 million for nine of the specially
serviced loans.  Moody's has estimated an aggregate $28.3 million
loss (55% expected loss on average) for the specially serviced
loans.

Moody's has assumed a high default probability for 11 poorly
performing loans representing 14% of the pool and has estimated a
$12.7 million loss (17% expected loss based on a 55% probability
default) from these troubled loans.

Based on the most recent remittance statement, Classes J through K
have experienced cumulative interest shortfalls totaling $744,893.
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 68%
of the pool.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 72% compared to 79% 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 9.7%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.43X and 1.54X, respectively, compared to
1.34X and 1.42X 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 9% of the pool
balance.  The largest loan is the Van Ness Post Centre Loan
($16.9 million -- 3.2% of the pool), which is secured by a 109,000
square foot mixed use property and an adjacent 144-space parking
garage located in San Francisco, California.  The loan matures in
May 2011.  The loan is on the watchlist due to a decrease in DSCR
and low occupancy.  Moody's LTV and stressed DSCR are 109% and
1.01 X, respectively, compared to 97% and 1.14X at last review.

The second largest loan is the Ironwood Apartments Loan
($15.3 million -- 2.9% of the pool), which is secured by a 288-
unit multifamily property located in Houston, Texas.  The property
was 92% leased as of December 2009, the same as last review.  The
loan is currently on the watchlist due to a low DSCR.  The loan
matures in February 2011.  Due to poor performance, 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 133% and
0.75X, respectively, compared to 155% and 0.64X at last review.

The third largest loan is Union Square Marketplace Shopping Center
Loan ($14.1 million -- 2.7% of the pool), which is secured by a
189,000 square foot retail center located approximately 20 miles
southeast of Oakland in Union City, California.  The property was
96% leased as of December 2009, the same as last review.  The loan
matures in January 2011.  Moody's LTV and stressed DSCR are 59%
and 1.8X, respectively, compared to 81% and 1.3X at last review.


SCHOONER TRUST: DBRS Confirms B Rating on 2006-6 Class K Certs.
---------------------------------------------------------------
DBRS has confirmed these ratings of all 14 classes of Schooner
Trust Commercial Mortgage Pass-Through Certificates, Series 2006-
6:

Class A-1 at AAA
Class A-2 at AAA
Class B at AA
Class C at A
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 XC at AAA
Class XP at AAA

The ratings reflect the slightly increased credit enhancement to
the bonds from a balance reduction of approximately 8.5% since
issuance, the healthy weighted-average debt service coverage
ration (DSCR) of 1.53x for the pool and the defeasance of three
loans in the pool, representing 4.07% of the current transaction
balance.

There are currently five loans, representing 6.6% of the
transaction, on the servicer's watchlist; one of these loans is in
the Top Ten, representing 3.08% of the pool.  Prospectus ID#6,
Alder Crossing Shopping Centre, is on the servicer's watchlist for
the occupancy decline since issuance by approximately 25% as of
March 2010.  The property is located in Surrey, British Columbia
and is anchored by a grocery store tenant with 40% of the NRA on a
lease through 2015.  The YE2009 DSCR is healthy at 1.37x and the
loan per square foot is reasonable at $204, given the good
location on King George Highway in the southern portion of the
city and the age of the centre, which was constructed in 2004.

Only one of the other four loans on the servicer's watchlist
individually comprises greater than 1.0% of the pool: Prospectus
ID #14, 2150 Islington Avenue, with 1.97% of the current
transaction balance.  This loan is collateralized by an office
property in Toronto and is on the watchlist for an occupancy
decline to 71% at YE2007, down from 91% at issuance.  The
September 2010 rent roll shows the property remaining at 71%
occupancy.  As of October 28, 2010, Altus InSite shows the
property with 7% of the NRA available; DBRS has requested
confirmation of the current occupancy from the servicer and will
continue to monitor the loan.  The DSCR for the two years of
reduced occupancy was quite healthy, with the YE2008 DSCR at 1.16x
and the YE2009 DSCR at 1.26x; furthermore, the loan per square
foot of $51 is considered reasonable given the location and age of
the asset, which was constructed in 1992.

One of the remaining three loans on the servicer's watchlist will
be placed on the DBRS HotList.  An industrial property in Vaughn,
Ontario, Prospectus ID #66, 50 & 70 Snidercroft Road (comprising
0.43% of the current transaction balance), is on the servicer's
watchlist due to the Poor condition of the properties as noted
during the servicer's 2009 site inspection.  The buildings were
cited for numerous structural issues as well as two environmental
issues in an unsound refuse container for toxic chemicals and the
storage of discarded tires at the property.  The environmental
issues have been addressed, according to correspondence from the
borrower to the servicer, with the structural issues to be
addressed by year-end 2010.  DBRS would also note that 56.7% of
the NRA between the two buildings is set to expire between
November 2010 and April 2011.  A leasing update has been requested
from the servicer; DBRS will continue to monitor the upcoming
rollover as well as the maintenance issues at the property.  The
YE2009 coverage is quite healthy at 1.74x and the leverage is low,
with a current loan amount of $14 per square foot.

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.

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 Confirms B Rating on 2007-8 Class K Certs.
---------------------------------------------------------------
DBRS has confirmed these ratings of all 15 classes of Schooner
Trust, Series 2007-8 Commercial Mortgage Pass-Through
Certificates, Series 2007-8:

Class A-1 at AAA
Class A-2 at AAA
Class A-J at AAA
Class B at AA
Class C at A
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 XP at AAA
Class XC at AAA

All classes were confirmed with a Stable trend.

The ratings reflect the increased credit enhancement to the bonds
from a collateral reduction of approximately 9.63% since issuance,
the healthy weighted-average debt service coverage ratio (DSCR) of
1.53x for the pool and the strong performance of the ten largest
loans in the pool, which had a straight average debt yield of
10.9% for 2009.

There is one loan on the servicer's watchlist, representing 1.19%
of the transaction balance, Prospectus ID#24, 1599 Hurontario
Street.  The property is a Class B office property located just
south of Queen Elizabeth Way in Mississauga, Ontario.  This loan
is on the watchlist for a low DSCR at YE2009 of 0.08x; this figure
is representative of reduced cash flow at the property due to a
decline in occupancy after losing the property's largest tenant
with 44% of the NRA in 2008.  After a few smaller tenants also
vacated, the property occupancy was at 38% for much of 2009 before
rebounding to 69% in the final months of the year and up to 93% as
of August 2010.  Altus InSite showed 3% available for lease as of
November 2, 2010.  The property performance should improve in the
coming year; the borrower has invested heavily in the property
since 2008, replacing the roof and renovating common areas at the
property.

There is one small loan in special servicing in the pool,
Prospectus ID#66, Bonsor Commercial, representing 0.18% of the
transaction balance.  This loan transferred to the special
servicer in October 2009 for payment default; since that time, the
special servicer has secured a judgment against the borrower and
is pursuing rights against the Guarantor.  The loan is secured by
a small retail property comprised of 6,995 sf in Burnaby, British
Columbia.  The property is currently listed for sale by the
borrower in the range of $2 million; however, the special servicer
is pursuing a Conduct of Sale order to facilitate the direct sale
of the property by the special servicer through their choice of
broker.  The property is currently 50% occupied and the
outstanding advances, as of the October 2010 remittance report,
total $147,000, putting the trust's total exposure to this loan at
$1.03 million.  As such, if a loss is experienced, it should be
minimal and sufficiently absorbed by the unrated Class M.

DBRS applied a net cash flow stress of 20% across all the 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.

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.


SEQUOIA ALTERNATIVE: Moody's Downgrades Ratings on Two Tranches
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of two
tranches from Sequoia Alternative Loan Trust 2006-1.  The
collateral backing this deal primarily consists of first-lien,
adjustable rate Alt-A residential mortgages.

                        Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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: Sequoia Alternative Loan Trust 2006-1

  -- Cl. A-1, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

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


SOLOSO CDO: S&P Downgrades Ratings on Two Classes to 'D'
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D (sf)'
on the class A-1LA and class A-1LB notes from Soloso CDO 2007-1
Ltd., a cash flow collateralized debt obligation transaction
backed mainly by bank trust preferred securities.  Concurrently,
S&P affirmed its 'AAA (sf)' ratings on the class P-1 and P-2 combo
notes.  The 'AAA (sf)' rated notes are fully backed by U.S.
Treasury principal strips.

S&P's rating actions follow the receipt of an event of default
notice dated Oct. 19, 2010, from the trustee subsequent to an
interest shortfall that occurred on the class A-1LA and A-1LB
notes on the Oct. 7, 2010, payment date.  Consequently, S&P
lowered its ratings on these classes of notes to 'D (sf)' since
these two tranches are nondeferrable.

The rating actions are consistent with S&P's published criteria
for ratings on CDO transactions that have triggered an EOD due to
an interest shortfall on a nondeferrable tranche.

S&P will continue to monitor this transaction and take rating
actions as S&P see appropriate.

                         Ratings Lowered

                     Soloso CDO 2007-1 Ltd

                                    Rating
                                    ------
             Class             To                From
             -----             --                ----
             A-1LA             D                 CCC-
             A-1LB             D                 CCC-

                        Ratings Affirmed

                      Soloso CDO 2007-1 Ltd

                      Class         Rating
                      -----         ------
                      P-1 combo     AAA
                      P-2 combo     AAA


SOUNDVIEW HOME: Moody's Downgrades Ratings on Three Tranches
------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three
tranches from Soundview Home Loan Trust 2006-WF1.  The collateral
backing this deal primarily consists of first-lien, fixed and
adjustable rate Alt-A residential mortgages.

                        Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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 2006-WF1

  -- Cl. A-2, Downgraded to Caa1 (sf); previously on Jan. 14, 2010
     B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-3, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. A-4, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade


STARM MORTGAGE: Moody's Downgrades Ratings on 10 Tranches
---------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 10
tranches from STARM Mortgage Loan Trust 2007-4.  The collateral
backing this deal primarily consists of first-lien, adjustable
rate Alt-A residential mortgages.

                        Ratings Rationale

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

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

The above mentioned approach "Alt-A RMBS Loss Projection Update:
February 2010" is adjusted slightly when estimating losses on
pools left with a small number of loans.  To project losses on
pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 19% and 21% for
the 2005, 2006 and 2007 vintage respectively).  This baseline rate
is higher than the average rate of new delinquencies for the
vintage to account for the volatile nature of small pools.  Even
if a few loans in a small pool become delinquent, there could be a
large increase in the overall pool delinquency level due to the
concentration risk.  Once the baseline rate is set, further
adjustments are made based on 1) the number of loans remaining in
the pool and 2) the level of current delinquencies in the pool.
The fewer the number of loans remaining in the pool, the higher
the volatility and hence the stress applied.  Once the loan count
in a pool falls below 75, the rate of delinquency is increased by
1% for every loan less than 75.  For example, for a pool with 74
loans from the 2005 vintage, the adjusted rate of new delinquency
would be 10.10%.  If current delinquency levels in a small pool is
low, future delinquencies are expected to reflect this trend.  To
account for that, the rate calculated above is multiplied by a
factor ranging from 0.2 to 2.0 for current delinquencies ranging
from less than 2.5% to greater than 50% respectively.
Delinquencies for subsequent years and ultimate expected losses
are projected using the approach described in the methodology
publication.

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.

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: STARM Mortgage Loan Trust 2007-4

  -- Cl. 1A1, Downgraded to Caa2 (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1A2, Downgraded to C (sf); previously on Jan. 14, 2010 Ca
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2A1, Downgraded to Caa1 (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2A2, Downgraded to Caa1 (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2A3, Downgraded to C (sf); previously on Jan. 14, 2010 Ca
     (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2X, Downgraded to Caa1 (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3A1, Downgraded to Caa1 (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3A2, Downgraded to C (sf); previously on Jan. 14, 2010 Ca
      (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4A1, Downgraded to Caa1 (sf); previously on Jan. 14, 2010
     B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4A2, Downgraded to C (sf); previously on Jan. 14, 2010 Ca
     (sf) Placed Under Review for Possible Downgrade


TCW HIGH: Moody's Upgrades Ratings on Four Classes of Notes
-----------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by TCW High Income Partners,
Ltd./TCW High Income Partners Corp.:

  -- US$25,000,000 Class II-A Senior Secured Floating Rate Notes
     due 2013 (current outstanding balance of $3,379,845),
     Upgraded to Aaa (sf); previously on June 11, 2010 Upgraded to
     Aa2 (sf);

  -- US$31,000,000 Class II-B Senior Secured Fixed Rate Notes due
     2013 (current outstanding balance of $4,191,008), Upgraded to
     Aaa (sf); previously on June 11, 2010 Upgraded to Aa2 (sf);

  -- US$10,000,000 Class III-A Mezzanine Secured Floating Rate
     Notes due 2013, Upgraded to Ba1 (sf); previously on June 11,
     2010 Upgraded to Caa2 (sf);

  -- US$23,000,000 Class III-B Mezzanine Secured Fixed Rate Notes
     due 2013, Upgraded to Ba1 (sf); previously on June 11, 2010
     Upgraded to Caa2 (sf).

                        Ratings Rationale

According to Moody's, the rating actions taken on the notes result
primarily from the delevering of the Class II Notes, which have
been paid down by approximately 84% or $38.9 million since the
last rating action in June 2010.  A substantial proportion of this
repayment is attributable to sales of the underlying securities in
the portfolio in addition to scheduled principal proceeds.  For
example, in August 2010, the collateral manager has sold
approximately $15 million of bonds at an average price close to
par.  As a result of the delevering, the overcollateralization
ratios have increased since the last rating action in June 2010.
As of the latest trustee report dated September 16, 2010, the
Senior, the Class III and the Junior Par Value Tests are reported
at 849.7%, 158.6% and 117.0%, respectively, versus May 2010 levels
of 220.3%, 128.9% and 104.0%, respectively.

Moody's also notes that the credit profile of the underlying
portfolio has been relatively stable since the last rating action.
Based on the September 2010 trustee report, the weighted average
rating factor is 4154 compared to 4009 in May 2010, and securities
rated Caa1 and below make up approximately 34.8% of the underlying
portfolio versus 32.7%% in May 2010.  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." The deal also experienced
a decrease in defaults.

While the transaction has benefited from delevering, Moody's noted
that the portfolio includes a number of investments in securities
that mature after the maturity date of the notes.  Based on the
trustee report dated September 16, 2010, securities that mature
after the maturity date of the notes make up approximately 18.7%
of the underlying portfolio versus 11.7% in May 2010.  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 $56.8 million, defaulted par of $15.9 million,
weighted average default probability of 22.5% (implying a WARF of
4650), a weighted average recovery rate upon default of 21.2%, and
a diversity score of 25.  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.

TCW High Income Partners, Ltd./TCW High Income Partners Corp.,
issued in August of 2001, is a collateralized bond obligation
backed primarily by a portfolio of senior unsecured bonds.

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% (3720)

  -- Class II-A: 0
  -- Class II-B: 0
  -- Class III-A: +2
  -- Class III-B: +2
  -- Class IV: 0

Moody's Adjusted WARF + 20% (5580)

  -- Class II-A: 0
  -- Class II-B: 0
  -- Class III-A: -1
  -- Class III-B: -1
  -- Class IV: 0

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% (23.2%)

  -- Class II-A: 0
  -- Class II-B: 0
  -- Class III-A: +1
  -- Class III-B: +1
  -- Class IV: 0

Moody's Adjusted WARR - 2% (19.2%)

  -- Class II-A: 0
  -- Class II-B: 0
  -- Class III-A: 0
  -- Class III-B: 0
  -- Class IV: 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 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) 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 bond 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.


TEXAS PUBLIC: Fitch Upgrades Rating on $86.2 Mil. Bonds From 'BB+'
------------------------------------------------------------------
Fitch Ratings upgrades to 'BBB' from 'BB+' approximately
$86.2 million of outstanding revenue financing system bonds issued
by the Texas Public Finance Authority (the authority) on behalf of
Texas Southern University (TSU or the university).  At the same
time, Fitch assigns a 'BBB' rating to these series of TSU bonds
issued by the authority:

  -- $31.5 million revenue financing system bonds series 2010.

The series 2010 bonds (the bonds) are expected to price via
negotiated sale on or about the week of Dec. 13, 2010.  Proceeds
of the bonds will fund the construction and equipping of a new
technology center on the university's campus, partially fund a
debt service reserve fund, with the remainder to be cash funded
from the receipt of federal funds and insurance related to
Hurricane Ike, and to pay various costs of issuance.

The Rating Outlook is revised to Positive from Negative.

Rating Rationale:

  -- The upgrade to 'BBB' primarily reflects the measured progress
     made by senior leadership at TSU, including the board of
     regents and management team, in implementing needed internal
     controls and other best practices necessary to preserve the
     university's financial integrity and ensure compliance with
     the requirements of external accreditation bodies.

  -- TSU's unique niche as the only historically black college and
     university within the state of Texas (the state, general
     obligation bonds rated 'AAA' by Fitch), its urban location
     and professionally focused program offerings, and broad
     geographic draw compared to its public university
     counterparts, helped support the rebound in student headcount
     during fall 2009 and fall 2010.

  -- Reflecting both its niche and role within the state's public
     higher education system, state support for both operations
     and capital has historically been significant and provides a
     level of credit stability; state appropriations for
     operations accounted for 36% of total revenues in fiscal
     2010.

  -- TSU's more limited ability, as compared to other state public
     institutions, to materially raise tuition and fees without a
     loss in enrollment may limit its financial flexibility in
     dealing with potentially significant state funding reductions
     during the next biennium.

  -- Despite the issues related to governance and internal
     controls that have since been addressed, TSU has been able to
     maintain a generally stable, positive operating margin over
     the past five fiscal years, and a modest, though adequate,
     financial cushion relative to both operating expenditures and
     financial leverage.

What Could Trigger An Upgrade:

  -- Ability to manage potential declines in state funding and/or
     modest enrollment volatility while sustaining operating
     performance at or above a break-even level.

  -- Modest growth in available funds, or cash and non-permanently
     restricted, expendable investments, which provide a financial
     cushion necessary to manage the uncertainty regarding state
     funding and enrollment.

  -- Additional debt, while none is currently expected, supported
     by a commensurate rise in resources available for its
     repayment.

Security:

RFS debt is secured by a broad pledge of all unencumbered revenues
of the university, excluding state appropriations and restricted
gifts.  RFS debt classified as tuition revenue bonds, including
the series 2010 bonds, are also eligible to receive an
appropriation equal to debt service.  Other security provisions
offering varying degrees of protection include a cash funded debt
service reserve fund equal to maximum annual debt service and an
additional bonds test.

Credit Summary:

Established in 1947, TSU is a public, four-year, liberal arts
institution and is the second-largest, single-campus African
American university in the country.  TSU's 145-acre campus is
located approximately three miles from downtown Houston.

As of June 2010, TSU's accreditation was fully restored, following
an 29-month monitoring period during which the university submit
quarterly compliance updates to the Southern Association of
Colleges and Schools (SACS or the association), the regional
accrediting association for southern states.  TSU's accreditation
was originally placed on probation in fiscal 2007 as a result of
various issues stemming from lax governance and a lack of
meaningful internal controls.  In response to the sanction, the
governor of the state replaced the BOR in phases through the
spring of 2009, while at the same time installing a new, highly
experienced management team.  Since joining the university, the
new BOR and management team has worked diligently to strengthen
various administrative and financial management practices, build a
university-wide culture of accountability, and create systems and
infrastructure which facilitate effective communication and
governance.  In Fitch's view, these important changes are viewed
favorably as they help reduce the risk that compliance violations
which lead to the probationary action in fiscal 2007 will again
resurface.  Probationary accreditation and/or a lack of
accreditation has extremely negative implications for a
university's enrollment base as it can result in a loss of student
financial aid.  In the case of TSU, its years of probationary
accreditation coincided with a period of enrollment volatility and
extremely limited demand flexibility.  Further exacerbating this
situation was the dependence of a significant 85%-90% of the
university's student body upon some form of financial assistance
to defray the cost of attendance.

With accreditation now fully restored, student demand, measured by
both headcount and applications, has begun to rebound.
Application volume is up 25.8% from fall 2007 to fall 2010, while
full-time equivalent enrollment has grown 8% since its low point
in fall 2008.  Matriculation rates have also returned to the mid-
30% range, which is particularly noteworthy given the university's
abandonment of open enrollment policies beginning in fall 2008 and
focus on significantly increasing student quality.  While TSU's
historically high cost of attendance has fallen in line with
state-wide averages for competing institutions as of fall 2010,
the price sensitive nature of the university's market coupled with
the high financial aid needs of its student body effectively
limits ongoing, significant increases in tuition and fees without
corresponding increases in tuition discounting.  As of fall 2010,
tuition discounting was approximately 29%, which is somewhat high
for a public university.

Despite an environment of volatility, TSU has produced positive
operating margins for the past five years, averaging 6.5%.  These
results are driven by the university's well-diversified revenue
streams, including approximately equal inflows from tuition and
auxiliaries (30.3%), grant and contract revenue (31.9% and state
appropriations (36%) based on fiscal 2010 unaudited results, which
the university may need to rely in to manage declines in state
appropriations in the next biennium.  These positive operations
have contributed to the university's ability to rebuild its
liquidity levels, which had declined to $39.2 million in fiscal
2009, and returned to $55.4 million in fiscal 2010.  The
university's strong operations and adequate liquidity levels
provide comfort regarding the university's moderately high debt
burden, with MADs totaling 8.6% of total unrestricted revenues.
Operations have provided an average of 1.7x actual debt service
coverage over the past five years, while current available funds
provide 2.9x pro-forma MADS coverage.


WACHOVIA BANK: Moody's Downgrades Ratings on 17 2006-C24 Certs.
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of 17 classes and
affirmed six classes of Wachovia Bank Commercial Mortgage Trust,
Commercial Pass-Through Certificates, Series 2006-C24:

  -- Cl. A-2, Affirmed at Aaa (sf); previously on April 5, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-PB, Affirmed at Aaa (sf); previously on April 5, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on April 5, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-1A, Affirmed at Aaa (sf); previously on April 5, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-P, Affirmed at Aaa (sf); previously on April 5, 2006
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-C, Affirmed at Aaa (sf); previously on April 5, 2006
     Definitive Rating Assigned Aaa (sf)

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

  -- Cl. A-J, Downgraded to Baa3 (sf); previously on Sept. 29,
     2010 Aa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. B, Downgraded to Ba1 (sf); previously on Sept. 29, 2010
     A1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. C, Downgraded to Ba2 (sf); previously on Sept. 29, 2010
     A2 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. E, Downgraded to B3 (sf); previously on Sept. 29, 2010
     Baa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. F, Downgraded to Caa1 (sf); previously on Sept. 29, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. G, Downgraded to Caa2 (sf); previously on Sept. 29, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

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

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

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

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

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

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

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

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

  -- Cl. Q, Downgraded to C (sf); previously on Sept. 29, 2010 Ca
     (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 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 29, 2010, Moody's placed 17 classes on review for
possible downgrade.  This action concludes Moody's review.

Moody's rating action reflects a cumulative base expected loss of
10.5% of the current balance.  At last full review, Moody's
cumulative base expected loss was 2.1%.  Moody's stressed scenario
loss is 24.6% 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.

The principal methodology used in these ratings was "CMBS: Moody's
Approach to Rating Fusion Transactions" published in April 2005.
Other methodologies and factors that may have been considered in
the process of rating this issuer can also be found on Moody's
website.  In addition to methodologies and research available on
moodys.com, Moody's publishes a weekly summary of structured
finance credit, ratings and methodologies, available to all
registered users of Moody's website, at
www.moodys.com/SFQuickCheck.

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, 2007.  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.

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 20% to $1.61
billion from $2.00 billion at securitization.  The Certificates
are collateralized by 114 mortgage loans ranging in size from less
than 1% to 13% of the pool, with the top ten loans representing
51% of the pool.  Two loans, representing 0.4% of the pool, have
defeased and are collateralized by U.S. Government securities.
One loan, representing 1% of the pool, has an investment grade
credit estimate.

Twenty-nine 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.

Three loans have been liquidated from the pool since
securitization, resulting in an aggregate $8.0 million loss (58%
loss severity on average).  Currently 12 loans, representing 11%
of the pool, are in special servicing.  The largest specially
serviced loan is the Grandeville on Saxon Loan ($27.5 million --
1.7% of the pool), which is secured by a 316-unit multifamily
property located in Orange City, Florida.  The loan was
transferred to special servicing in August 2010 due to monetary
default and is currently 90+ days delinquent.  The remaining 11
specially serviced loans are secured by a mix of property types.
The master servicer has recognized an aggregate $64.4 million
appraisal reduction for seven of the specially serviced loans.
Moody's has estimated an aggregate loss of $89.5 million (59%
expected loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for 13 poorly
performing loans representing 12% of the pool and has estimated a
$39.1 million loss (20% expected loss based on a 40% probability
default) from these troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 87% and 54% of the non-defeased performing
pool, respectively.  Excluding specially serviced and troubled
loans, Moody's weighted average LTV is 110% compared to 108% at
last full 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 9.0%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.18X and 0.91X, respectively, compared to
1.23X and 0.92X at last full 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 20 compared to 44 at Moody's prior full review.

The loan with a credit estimate is the Branmar Shopping Center
loan ($15.5 million -- 1.0%), which is secured by a 156,000 square
foot retail center located in Wilmington, Delaware.  The center is
anchored by Super Fresh and Walgreen's.  The center was 92% leased
as of April 2010, compared to 98% at last full review.
Performance remains stable despite a decrease in occupancy.  The
loan has amortized 5% since last full review and matures in
September 2015.  Moody's current credit estimate and stressed DSCR
are Baa3 and 1.39X, respectively, compared to Baa3 and 1.41X last
full review.

The top three performing conduit loans represent 26% of the pool
balance.  The largest loan is the Regency Portfolio Loan
($213.0 million -- 13.2%), which is secured by ten retail
properties (originally 13) totaling 1.4 million square feet.  The
remaining properties are located in seven states, with the largest
concentrations in California (37%) and Illinois (25%).  The
portfolio was 84% occupied as of December 2009, compared to 93% at
last full review.  Moody's LTV and stressed DSCR are 120% and
0.80X, respectively, compared to 110% and 0.92X at last full
review.

The second largest loan is the 1818 Market Street Loan
($122.0 million -- 7.6%), which is secured by a 983,160 square
foot Class A office building located in Philadelphia,
Pennsylvania.  Property performance has declined since last review
due to rising vacancy.  The property was 76% leased as of May 2010
compared to 94% at last review.  The loan has five months
remaining in a 60-month interest only period and will amortize on
a 360-month schedule maturing in March 2016.  Moody's LTV and
stressed DSCR are 127% and 0.77X, respectively, compared to 120%
and 0.86X at last full review.

The third largest loan is the Forum at Peachtree Parkway Loan
($84.0 million -- 5.2% of the pool), which is secured by a 389,159
square foot retail center located in Norcross, Georgia.  The
center's major tenants include Belk, Wakefield Beasley and Barnes
& Noble.  The center was 89% leased as of May 2010, compared to
90% at last full review.  The loan is interest-only for its entire
ten-year term maturing in March 2016.  Moody's LTV and stressed
DSCR are 114% and 0.80X, respectively, compared to 110% and 0.88X
at last full review.


WACHOVIA BANK: Moody's Reviews Ratings on 11 2006-C28 Certs.
------------------------------------------------------------
Moody's Investors Service placed 11 classes of Wachovia Bank
Commercial Mortgage Securities Trust Commercial Mortgage Pass-
Through Certificates, Series 2006-C28 on review for possible
downgrade:

  -- Cl. A-M, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 19, 2009 Downgraded to Aa2 (sf)

  -- Cl. A-J, Baa1 (sf) Placed Under Review for Possible
     Downgrade; previously on Nov. 19, 2009 Downgraded to Baa1
     (sf)

  -- Cl. B, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 19, 2009 Downgraded to Baa3 (sf)

  -- Cl. C, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 19, 2009 Downgraded to Ba3 (sf)

  -- Cl. D, B3 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 19, 2009 Downgraded to B3 (sf)

  -- Cl. E, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 19, 2009 Downgraded to Caa1 (sf)

  -- Cl. F, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 19, 2009 Downgraded to Caa2 (sf)

  -- Cl. G, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 19, 2009 Downgraded to Caa3 (sf)

  -- Cl. H, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 19, 2009 Downgraded to Ca (sf)

  -- Cl. J, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 19, 2009 Downgraded to Ca (sf)

  -- Cl. K, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Nov. 19, 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 November 19, 2009.

                   Deal And Performance Summary

As of the October 18, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 2% to $3.53 billion
from $3.60 billion at securitization.  The Certificates are
collateralized by 207 mortgage loans ranging in size from less
than 1% to 7% of the pool, with the top ten loans representing 43%
of the pool.

Forty-eight 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.

The pool has not experienced any realized losses to date.
Currently, 25 loans, including two of the pool's top five loans,
are in special servicing.  The special serviced loans represent
18% of the pool.  The largest specially serviced loan is the
Montclair Plaza Loan ($190.0 million -- 5.4% of the pool), which
is secured by a 875,000 square foot regional mall located in
Montclair, California.  The mall is anchored by Macy's, Sears and
JC Penney.  The loan was transferred to special servicing in
January 2010 for monetary default and the loan is 60 days
delinquent.  The sponsor is General Growth Properties.  The
remaining 24 specially serviced loans are secured by a mix of
property types.  The master servicer has recognized an aggregate
$205.3 million appraisal reduction for the specially serviced
loans.

Based on the most recent remittance statement, Classes H through
NR have experienced cumulative interest shortfalls totaling
$8.18 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.


WCP WIRELESS: Fitch Rates Class C Notes at 'BB-sf'
--------------------------------------------------
Fitch Ratings rates WCP Wireless Site Funding LLC, WCP Wireless
Site RE Funding LLC, & WCP Wireless Site Non-RE Funding LLC's
secured wireless site contract revenue notes, series 2010-1:

  -- $222,000,000 class A 'Asf'; Outlook Stable;
  -- $55,000,000 class B 'BBB-sf'; Outlook Stable;
  -- $50,000,000 class C 'BB-sf'; Outlook Stable.


WESTERLY HOSPITAL: Moody's Junks Ratings on Series 1994 Bonds
-------------------------------------------------------------
Moody's Investors Service has downgrade to Caa1 from B2 the long-
term rating assigned to Westerly Hospital's Series 1994 bonds
($9.3 million outstanding), issued by Rhode Island Health &
Educational Building Corporation.  The outlook remains negative.
The two-notch rating downgrade reflects the thin cash position at
the end of FY 2010 (unaudited) that is largely supported by two
bank lines of credit that the bank can call at any time if
unrestricted cash falls below the required collateral amount.  In
the event that the bank were to demand payment or not extend the
lines, very little liquidity would remain available for the fixed
rate bondholders given the thin cash reserves.  The rating outlook
remains negative reflecting Moody's expectations for continued
operating challenges and liquidity pressures.  While management is
endeavoring to improve performance, it is Moody's opinion that
given the financial challenges, there would be further rating
pressure should Westerly have a payment default.

                        Ratings Rationale

Legal Security: The Series 1994 Bonds are secured by a lien on the
hospital's gross receipts.  Negative mortgage lien. Debt service
reserve fund maintained.

Interest Rate Derivatives: None

                            Challenges

* Weak (unaudited) cash position as of September 30, 2010, with
  $14.8 million; when removing the lines of credit and a
  $4.6 million promissory note all at the same local bank,
  unencumbered cash declines to a weak $4.8 million management
  reports that there is $3.5 million of earnings on the permanent
  endowment which is available for debt service with board
  approval; this has not been used before; when including these
  funds, unencumbered cash would be $8.3 million

* Large amount of obligations beyond the Series 1994 bonds of
  $9.3 million in the form of two bank lines and a promissory note
  totaling $9.7 million all with one local bank; the bank requires
  that all of these obligations be collateralized by a minimum of
  $10 million from unrestricted investments and $1.4 million in
  real estate (120% collateral requirement); $10 million
  represents a high 68% of Westerly's total unrestricted cash as
  of September 30, 2010; the bank can call the lines of credit if
  unrestricted cash falls below the required collateral amount

* Large exposure to equities (60%) equities with no more than 6%
  allowed in any one company and no more than 20% allowed in any
  one industry.  Four managers are utilized along with an outside
  investment advisor.  No change to the investment allocation is
  anticipated

* Operating loss of $800 thousand in FY 2010 was significantly
  unfavorable to budgeted expectations of $2.6 million; revenues
  declined 1.4% in FY 2010 from FY 2009; five year history of
  operating losses places further pressure on the ability to
  increase liquidity

* Volume declines in seven out of the last ten years continuing in
  fiscal year 2010 with 5% decline in admissions offset by an
  increase in outpatient observation patients who reside on an
  inpatient unit, 12% decline in surgical volumes, 4% decline in
  emergency room visits, and 15% decline in newborns admissions

* Large underfunded pension liability that continues to pressure
  Westerly's cash position although the pension plan is frozen

                            Strengths

* Market leader with over 70% market share in a favorable service
  area; no competition within in a 30 minute drive ;plans to
  expand outpatient services into north Stonington, CT may
  generate additional revenue and cash flow

* Fully funded debt service reserve fund; all fixed rate debt

                   Recent Developments/Results

The downgrade to Caa1 from B2 and the maintenance of the negative
outlook reflects Westerly's thin liquidity position compounded
with continued weak financial performance.  At unaudited fiscal
year end 2010 unrestricted cash and investments was $14.8 million
or 63.8 days, a 37% decline compared to FYE 2005 when unrestricted
cash and investments was a much higher $23.5 million or 125 days.

Moody's primary concern and key driver to the rating downgrade
reflects the presence of two lines of credit and a promissory note
from one local bank, Washington Trust (not rated by Moody's).  The
bank requires that Westerly maintain 120% of collateral for amount
of lines available to the hospital (totals $5 million) and the
$4.6 million promissory note outstanding.  Management recently
negotiated with the bank that $1.4 million in off campus
properties can be used for collateral with the balance,
$10 million, in unrestricted cash and investments.  The
$3.5 million line of credit expires on June 1, 2012, and the bank
can call both lines of credit (totaling $5.0 million) at any time
leaving very little for the Series 1994 bondholders or for working
capital needs.  When removing the $10 million collateral from cash
the remaining cash and investments declines to a weak $4.8 million
or 20.7 days cash; this also reduces cash to debt at FYE 2010 by
more than half to 21.7% from 67%.  When adding the $3.5 million of
accumulated earnings on the endowment, pro forma cash would be
$8.3 million or 35.8 days; board approval is needed to use these
funds and it has not been used before.

Furthermore, the cash position has been variable.  Over the past
four months, unrestricted cash has ranged from a low point of
$11.9 million, a 19% decline from the end of FY 2009 to the
present amount of $14.7 million.  The increased pension liability
adds further pressure on Westerly's cash position.  Based on the
interim statements, the pension liability at the end of FY 2010
increased to $20.4 million from $16.3 million at the end of FY
2009.

A further credit concern is Westerly's investment policy.  60% of
Westerly's cash is invested in equities with no more than 6%
allowed in any one company and no more than 20% allowed in any one
industry.  Four managers are utilized along with an outside
investment advisor.  Management anticipates no change to the
investment allocation.  This policy makes the hospital's cash
balance susceptible to variability in investment returns.  With
the declines in cash over the last six years and a volatile
market, Moody's believe Westerly has reached a point that minimal
investment losses could result in a rapid decline in liquidity.

Contributing to the decline in cash position are the operating
losses Westerly has reported annually for the past ten years.  In
FY 2010 Westerly is reporting an operating loss of $800 thousand
(-0.9% operating margin) similar to the $883 thousand operating
loss (-1.0% operating margin) recorded in FY 2009.  FY 2010
results were materially off budget as a $2.9 million gain was
expected.  The primary driver to the operating losses is the
variability in volumes, with declines in admissions recorded in
seven out of the last ten years.  FY 2010 represents another year
of volume declines with inpatient medical/surgical admissions down
5% offset by an increase in outpatient observation patients who
reside on an inpatient unit, outpatient surgeries down 12%,
emergence room visits down 4%, and newborn admission down 15% from
the prior year period.  Management attributes the declines to the
economy and physician departures.  As a result, revenues are down
1.4% in FY 2010 from FY 2009 although management responded with a
1% decline in expenses achieved through cost saving initiatives
including reducing supply costs, overtime, and the use of
temporary employees.  At this time, the budget for FY 2011 is not
available.

Westerly has a debt service reserve fund that is fully funded with
cash.  There are no new debt plans and capital spending in FY 2010
was $3.5 million funded with cash flow and leases.  Future capital
spending will be a function of cash flow performance.  In addition
to the bonds, lines of credit and promissory note, Westerly also
has $4.5 million in capital lease obligations per the FY 2009
audit.  The average age of plant is very high at 16.5 years.

                             Outlook

The negative rating reflects Moody's expectations for continued
operating challenges and liquidity pressures.  While management is
endeavoring to improve performance, it is Moody's opinion that
given the financial challenges, there would be further rating
pressure should Westerly have a payment default.

                 What could change the rating -- Up

Unlikely given the negative outlook; however, over the longer term
a consistent trend of improving operating performance that Moody's
believe is sustainable, material increase in unencumbered
liquidity and increased volumes

                What could change the rating -- Down

Bankruptcy filing or payment default, further decline in cash
reserves

                          Key Indicators

Assumptions & Adjustments:

  -- Based on financial statements for The Westerly Hospital and
     Subsidiary

  -- First number reflects audit year ended September 30, 2009

  -- Second number reflects unaudited year ended September 30,
     2010

  -- Investment returns normalized at 6% unless otherwise noted

* Inpatient admissions: 4,789; 4,543

* Total operating revenues: $89.1 million; $88.5 million

* Moody's-adjusted net revenue available for debt service: $6.4
  million; $6.8 million

* Total debt outstanding: $21.7 million; $22.1 million

* Maximum annual debt service: $2.25 million; $2.25 million

* MADS Coverage with reported investment income: 2.28 times; 2.63
  times

* Moody's-adjusted MADS Coverage with normalized investment
  income: 2.84 times; 3.02 times

* Debt-to-cash flow: 4.32 times; 4.01 times

* Days cash on hand: 60.8 days; 63.8 days

* Cash-to-debt: 65.7%; 67.0%

* Operating margin: -1.0%; -0.9%

* Operating cash flow margin: 5.5%; 5.8%

Rated Debt (debt outstanding as of 9/30/2009):

  -- Series 1994 ($9.3 million outstanding) rated Caa1

The last rating action with respect to Westerly Hospital was on
January 16, 2009, when a municipal finance scale rating of B2 was
assigned and affirmed and the outlook was negative.  That rating
was subsequently recalibrated to B2 on May 7, 2010.


WIREFREE PARTNERS: S&P Withdraws 'BB-' Rating on $138.5 Mil. Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its rating on Wirefree
Partners III LLC's $138.5 million PCS spectrum lease-backed notes
series 2005-1 after the issuer sold all licenses to lessees and
used the proceeds to redeem the notes in full.

The Wirefree securitization was backed by lease agreements for
Personal Communication Services spectrum and PCS spectrum
licenses.  As the issuer announced in June of this year, the
lessees exercised their lessee purchase option pursuant to the
lease agreements, which constitutes a mandatory redemption event.
The payment date for the mandatory redemption event was Nov. 2,
2010, at which time the issuer repaid all the notes in full.

                        Rating Withdrawn

                    Wirefree Partners III LLC
   $138.5 million PCS spectrum lease-backed notes series 2005-1

                                Rating
                                ------
               Class       To              From
               -----       --              ----
               Notes       NR              BB- (sf)

                          NR - Not rated.


* Fitch Downgrades Ratings on 229 Bonds in 155 RMBS Deals
---------------------------------------------------------
Fitch Ratings has downgraded 229 bonds in 155 U.S. RMBS
transactions to 'Dsf'.  The downgrades indicate that the bonds in
question have incurred a principal write-down.  The bonds that
Fitch is downgrading to 'Dsf' were all previously rated 'Csf',
indicating an expected default.  The action is limited to just the
bonds with write-downs.  The remaining bonds in these transactions
have not been analyzed and the Recovery Ratings have not been
updated as part of this review.

Of the 155 transactions affected by these downgrades, 61 are
Prime, 50 Alt-A and 44 are Subprime.  The majority of the bonds
(71%) have a Recovery Rating of 'RR5' or 'RR6' indicating that
minimal recovery is expected.  Some 29% of the bonds have Recovery
Ratings of either 'RR2' or 'RR3', which indicates anywhere from
50%-90% of the outstanding balance is expected to be recovered.

The downgrades are part of Fitch's ongoing surveillance process.
Fitch will continue to monitor these transactions for additional
defaults.

The spreadsheet also details Fitch's assignment of Recovery
Ratings to the transactions.  The Recovery Rating scale is based
upon the expected relative recovery characteristics of an
obligation.  For structured finance, Recovery Ratings are designed
to estimate recoveries on a forward-looking basis while taking
into account the time value of money.


* Moody's Reviews Ratings on Tranches From Three Subprime RMBS
--------------------------------------------------------------
Moody's Investors Service has placed tranches with an outstanding
balance of $112 million from three subprime residential mortgage-
backed securities deals on review for possible downgrade.  These
three deals were not included in the analysis for Moody's review
action announcement released on April 8 for pre-05 RMBS.  Actions
were prompted by continued performance deterioration in these
vintages.

                          Review Action

To determine which tranches to place on review, Moody's compared
the tranches' credit enhancement from subordination plus one and a
half years of excess spread 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 85% for 60-day delinquencies,
95% for 90+day delinquencies, 100% for loans in foreclosure, and
100% for real estate owned, each applied with a severity
assumption of 70%.  Tranches without enough credit enhancement to
sustain current ratings based on this calculation have been placed
on review for possible downgrade.

          Revision of Loss Methodology for Seasoned RMBS

In the coming months, Moody's will update its loss projection
methodology for seasoned RMBS, and will release a report detailing
the updated methodology.

Complete rating actions are:

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2004-
IN1

  -- Cl. M-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Aug. 13, 2004 Assigned Aa2 (sf)

  -- Cl. M-2, A2 (sf) Placed Under Review for Possible Downgrade;
     previously on Aug. 13, 2004 Assigned A2 (sf)

  -- Cl. M-3, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Aug. 13, 2004 Assigned A3 (sf)

  -- Cl. M-4, Baa2 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 3, 2009 Downgraded to Baa2 (sf)

  -- Cl. M-5, Baa3 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 3, 2009 Downgraded to Baa3 (sf)

  -- Cl. M-6, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 3, 2009 Downgraded to Ba2 (sf)

  -- Cl. B, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 3, 2009 Downgraded to Ca (sf)

Issuer: Bear Stearns Asset-Backed Securities Trust 2002-1

  -- Cl. 1-A5, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on April 23, 2002 Assigned Aaa (sf)

  -- Cl. 2-A, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on April 23, 2002 Assigned Aaa (sf)

  -- Cl. M-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
     previously on April 23, 2002 Assigned Aa2 (sf)

  -- Cl. M-2, Baa2 (sf) Placed Under Review for Possible
     Downgrade; previously on June 5, 2009 Downgraded to Baa2 (sf)

  -- Cl. B, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on June 5, 2009 Downgraded to Ba3 (sf)

Issuer: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2004-CB8

  -- Cl. M-1, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on March 16, 2009 Downgraded to A1 (sf)

  -- Cl. M-2, Baa3 (sf) Placed Under Review for Possible
     Downgrade; previously on March 16, 2009 Downgraded to Baa3
     (sf)

  -- Cl. M-3, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on March 16, 2009 Downgraded to B1 (sf)

  -- Cl. B-1, Caa2 (sf) Placed Under Review for Possible
     Downgrade; previously on March 16, 2009 Downgraded to Caa2
     (sf)


* S&P Downgrades Ratings on 71 Certs. From 10 CMBS Transactions
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 71
classes of certificates from 10 U.S. commercial mortgage-backed
securities transactions due to interest shortfalls.  S&P lowered
its ratings on 51 of these classes to 'D (sf)' because S&P expects
these interest shortfalls to continue.

Forty-nine of the 51 classes that S&P downgraded to 'D (sf)' have
had accumulated interest shortfalls outstanding for five 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 advancing 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
respective 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)' 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 advancing, the recovery of
previously made advances deemed nonrecoverable, or the failure to
advance trust expenses when nonrecoverable declarations have been
determined.  Trust expenses may include, but are not limited to,
property operating expenses, property taxes, insurance payments,
and legal expenses.

     Banc of America Commercial Mortgage Inc. Series 2004-4

S&P lowered its ratings on the class H, J, K, and L certificates
from Banc of America Commercial Mortgage Inc.'s series 2004-4 due
to interest shortfalls resulting from ASERs related to the seven
loans that are currently with the special servicer, Orix Capital
Markets LLC, as well as special servicing fees.  S&P lowered its
rating on the class G certificates because S&P believes the class
is susceptible to future interest shortfalls.  As of the Oct. 12,
2010, remittance report, ARAs totaling $28.3 million were in
effect for seven loans.  The total reported ASER amount was
$138,779 and the reported cumulative ASER amount was $1.6 million.
Standard & Poor's considered the seven ASERs (totaling $141,261),
all of which were based on MAI appraisals, as well as current
special servicing fees in determining its rating actions.  The
reported interest shortfalls totaled $110,606 and have affected
all of the classes subordinate to and including class J.  Classes
J, K, and L have had accumulated interest shortfalls outstanding
for 11 months, and S&P expects these shortfalls to remain
outstanding for the foreseeable future.  Consequently, S&P
downgraded these classes to 'D (sf)'.

The collateral pool for the BACM 2004-4 transaction consists of 78
loans with an aggregate trust balance of $1.04 billion.  As of the
Oct. 12, 2010, remittance report, seven loans ($63.9 million;
7.0%) in the pool were with the special servicer.  The payment
status of these loans is: five ($54.9 million, 6.0%) are real
estate owned, one ($3.3 million, 0.4%) is in foreclosure, and one
($5.8 million, 0.6%) is more than 90 days delinquent.

      Banc of America Commercial Mortgage Inc. Series 2005-3

S&P lowered its ratings on the class F, G, H, J, K, L, M, and N
certificates from Banc of America Commercial Mortgage Inc.'s
series 2005-3 due to interest shortfalls primarily resulting from
ASERs related to seven of the 13 loans that are currently with the
special servicer, LNR Partners Inc., as well as special servicing
fees.  S&P lowered its rating on the class E certificates because
S&P believes the class is susceptible to future interest
shortfalls.  As of the Oct. 12, 2010, remittance report, ARAs
totaling $169.8 million were in effect for 12 loans.  The total
reported ASER amount was $678,213, and the reported cumulative
ASER amount was $5.7 million.  Standard & Poor's considered four
ASERs (totaling $395,169), all of which were based on MAI
appraisals, as well as current special servicing fees in
determining its rating actions.  The reported interest shortfalls
totaled $817,951 and have affected all of the classes subordinate
to and including class F.  Classes H, J, K, L, M, and N have had
accumulated interest shortfalls outstanding for eight (class H)
and nine (classes J-N) months, and S&P expects these shortfalls to
remain outstanding for the foreseeable future.  Consequently, S&P
downgraded these classes to 'D (sf)'.

The collateral pool for the BACM 2005-3 transaction consists of 88
loans with an aggregate trust balance of $2.0 billion.  As of the
Oct. 12, 2010, remittance report, 13 loans ($390.2 million; 20.4%)
in the pool were with the special servicer.  The payment status of
the delinquent loans is: One ($21.4 million, 1.1%) is REO, one
($132.0 million, 6.9%) is in foreclosure, three ($35.2 million,
1.8%) are more than 90 days delinquent, six ($177.8 million, 9.3%)
are matured balloons, and two ($23.8 million, 1.2%) are in their
grace periods.

      Banc of America Commercial Mortgage Inc. Series 2005-4

S&P lowered its ratings on the class F, G, H, J, K, L, M, N, and O
certificates from Banc of America Commercial Mortgage Inc.'s
series 2005-4 due to interest shortfalls primarily resulting from
ASERs related to 12 of the 22 loans that are currently with the
special servicer, ORIX, as well as special servicing fees.  As of
the Oct. 12, 2010, remittance report, ARAs totaling $86.9 million
were in effect for 12 loans.  The total reported ASER amount was
$343,437, and the reported cumulative ASER amount was
$2.9 million.  Standard & Poor's considered nine ASERs (totaling
$334,850), all of which were based on MAI appraisals, as well as
current special servicing fees in determining its rating actions.
The reported interest shortfalls totaled $421,293 and have
affected all of the classes subordinate to and including class G.
Classes G, H, J, K, L, M, N, and O have had accumulated interest
shortfalls outstanding for nine months, and S&P expects these
shortfalls to remain outstanding for the foreseeable future.
Consequently, S&P downgraded these classes to 'D (sf)'.

The collateral pool for the BACM 2005-4 transaction consists of
118 loans with an aggregate trust balance of $1.38 billion.  As of
the Oct. 12, 2010, remittance report, 22 loans ($288.2 million;
20.8%) in the pool were with the special servicer.  The payment
status of the delinquent loans is: four ($32.1 million, 2.3%) are
REO, four ($36.2 million, 2.6%) are in foreclosure, three
($121.9 million, 8.8%) are more than 90 days delinquent, two
($23.2 million, 1.7%) are matured balloons, one ($17.3 million,
1.3%) is 30 days delinquent, three ($46.3 million, 3.3%) are in
their grace periods, and four ($11.2 million, 0.8%) are current.

                          COMM 2005-C6

S&P lowered its ratings on the class F, G, and H certificates from
COMM 2005-C6 due to interest shortfalls resulting from ASERs
related to six of the 10 loans that are currently with the special
servicer, Helios AMC LLC, as well as special servicing fees.  As
of the Oct. 12, 2010, remittance report, ARAs totaling
$57.5 million were in effect for six loans.  The total reported
ASER amount was $270,232, and the reported cumulative ASER amount
was $2.7 million.  Standard & Poor's considered four ASERs
(totaling $222,278), all of which were based on MAI appraisals, as
well as current special servicing fees in determining its rating
actions.  The reported interest shortfalls totaled $325,606 and
have affected all of the classes subordinate to and including
class F.  Class H has had accumulated interest shortfalls
outstanding for 12 months, and S&P expects these shortfalls to
remain outstanding for the foreseeable future.  Consequently, S&P
downgraded this class to 'D (sf)'.

The collateral pool for COMM 2005-6 consists of 124 loans with an
aggregate trust balance of $1.9 billion.  As of the Oct. 12, 2010,
remittance report, 10 loans ($165.7 million; 9.0%) in the pool
were with the special servicer.  The payment status of these loans
is: four (60.0 million, 3.2%) are REO, two ($57.3 million, 3.1%)
are more than 90 days delinquent, one ($15.5 million, 0.8%) is 30
days delinquent, two ($26.3 million, 1.4%) are in their grace
periods, and one ($6.6 million, 0.4%) is current.

           GE Commercial Mortgage Corp. Series 2005-C4

S&P lowered its ratings on the class H, J, K, L, M, N, O, and P
certificates from GE Commercial Mortgage Corp.'s series 2005-C4
due to interest shortfalls resulting from ASERs related to 10 of
the 16 loans that are currently with the special servicer, Midland
Loan Servicers Inc. (Midland), as well as special servicing fees.
As of the Oct. 12, 2010, remittance report, ARAs totaling
$91.5 million were in effect for 10 loans.

The total reported ASER amount was $416,534, and the reported
cumulative ASER amount was $3.7 million.  Standard & Poor's
considered nine ASERs, all of which were based on MAI appraisals,
as well as current special servicing fees in determining its
rating actions.  The reported interest shortfalls totaled $490,980
and have affected all of the classes subordinate to and including
class J.  Classes J, K, L, M, N, O, and P have had accumulated
interest shortfalls outstanding for six (classes J and K), seven
(class L), eight (classes M, N, and O), and 11 (class P) months,
and S&P expects these shortfalls to remain outstanding for the
foreseeable future.  Consequently, S&P downgraded these classes to
'D (sf)'.

The collateral pool for the GECM 2005-C4 transaction consists of
162 loans with an aggregate trust balance of $2.24 billion.  As of
the Oct. 12, 2010, remittance report, 16 loans ($525.5 million;
23.4%) in the pool were with the special servicer.  The payment
status of these loans is: one ($3.8 million, 0.2%) is in
foreclosure, eight ($127.7 million, 5.7%) are more than 90 days
delinquent, two ($35.6 million, 1.6%) are 60 days delinquent, one
($71.3 million, 3.2%) is a matured balloon, two ($164.0 million,
7.3%) are less than 30 days delinquent, and two ($123.0 million,
5.5%) are current.

JPMorgan Chase Commercial Mortgage Securities Trust 2007-CIBC19

S&P lowered its ratings on the class F, G, H, J, K, L, M, N, and P
certificates from JPMorgan Chase Commercial Mortgage Securities
Trust 2007-CIBC19 due to interest shortfalls resulting from ASERs
related to 21 of the 26 loans that are currently with the special
servicer, LNR, as well as interest not advanced and special
servicing fees.  As of the Oct. 12, 2010, remittance report, ARAs
totaling $165.8 million were in effect for the 26 loans in special
servicing.  The total reported ASER amount was $714,357, and the
reported cumulative ASER amount was $4.9 million.  Standard &
Poor's considered 14 ASERs (totaling $521,469), all of which were
based on MAI appraisals, as well as interest not advanced
($78,666) and current special servicing fees, in determining its
rating actions.  The reported interest shortfalls totaled $852,997
and have affected all of the classes subordinate to and including
class F.  Classes J, K, L, M, N, and P have had accumulated
interest shortfalls outstanding for 10 (classes J and K) and 11
(classes L, M, N, and P) months, and S&P expects these shortfalls
to remain outstanding for the foreseeable future.  Consequently,
S&P downgraded these classes to 'D (sf)'.

The collateral pool for the JPMC 2007-CIBC19 transaction consists
of 234 loans with an aggregate trust balance of $3.18 billion.  As
of the Oct. 12, 2010, remittance report, 26 loans ($358.9 million;
11.3%) in the pool were with the special servicer.  The payment
status of these loans is: six ($49.2 million, 1.5%) are REO, two
($60.9 million, 1.9%) are in foreclosure, and 18 ($248.9 million,
7.8%) are more than 90 days delinquent.

             LB-UBS Commercial Mortgage Trust 2004-C4

S&P lowered its ratings on the class K, L, M, and N certificates
from LB-UBS Commercial Mortgage Trust 2004-C4 due to interest
shortfalls resulting from ASERs related to three of the seven
loans that are currently with the special servicer, LNR, as well
as special servicing fees.  S&P lowered its rating on the class J
certificate because S&P believes the class is susceptible to
future interest shortfalls.  As of the Oct. 18, 2010, remittance
report, ARAs totaling $11.8 million were in effect for three
loans.  The total reported ASER amount was $61,029, and the
reported cumulative ASER amount was $190,440.  Standard & Poor's
considered two ASERs, both of which were based on MAI appraisals,
as well as current special servicing fees, in determining its
rating actions.  The reported interest shortfalls totaled
$83,546 million and have affected all of the classes subordinate
to and including class L.  Classes M and N have had accumulated
interest shortfalls outstanding for eight months, and S&P expects
these shortfalls to remain outstanding for the foreseeable future.
Consequently, S&P downgraded these classes to 'D (sf)'.

The collateral pool for the LB-UBS 2004-C4 transaction consists of
85 loans with an aggregate trust balance of $988.6 million.  As of
the Oct. 18, 2010, remittance report, seven loans ($81.6 million;
8.3%) in the pool were with the special servicer.  The payment
status of these loans is: five ($43.0 million, 4.4%) are in
foreclosure, and two ($38.6 million, 3.9%) are more than 90 days
delinquent.

             ML-CFC Commercial Mortgage Trust 2007-5

S&P lowered its ratings on the class H, J, K, L, M, N, and P
certificates from ML-CFC Commercial Mortgage Trust 2007-5 due to
recurring interest shortfalls resulting from ASERs related to four
of the 23 loans that are currently with the special servicer,
CWCapital Asset Management LLC, as well as interest not advanced
on two loans and special servicing fees.  As of the Oct. 15, 2010,
remittance report, ARAs totaling $24.2 million were in effect for
six loans.  The total reported ASER amount was $24,143, and the
reported cumulative ASER amount was $584,653.  Standard & Poor's
considered the six ASERs, which were based on an MAI appraisals,
as well as interest not advanced ($77,160) and current special
servicing fees in determining its rating actions.  The reported
interest shortfalls totaled $490,039 and have affected all of the
classes subordinate to and including class H.  Classes H, J, K, L,
M, N, and P have had accumulated interest shortfalls outstanding
for two (class H), three (class J), six (classes K and L) and 11
(classes M, N, and P) months, and S&P expects these shortfalls to
remain outstanding for the foreseeable future.  Consequently, S&P
downgraded these classes to 'D (sf)'.

The collateral pool for the ML-CFC 2007-5 transaction consists of
323 loans with an aggregate trust balance of $4.30 billion.  As of
the Oct. 15, 2010, remittance report, 23 loans ($1.03 billion;
23.9%) in the pool were with the special servicer, including the
Peter Cooper Village and Stuyvesant Town loan, which is the
largest loan in the pool ($800 million, 18.6%).  The payment
status of these loans is: five ($54.9 million, 1.3%) are REO, 10
($885.9 million, 20.6%) are in foreclosure, seven ($83.6 million,
1.9%) are more than 90 days delinquent, and one ($4.5 million,
0.1%) is less than 30 days delinquent.

               Merrill Lynch Mortgage Trust 2006-C1

S&P lowered its ratings on the class G, H, J, K, L, M, N, and P
certificates from Merrill Lynch Mortgage Trust 2006-C1 due to
interest shortfalls resulting from ASERs related to 20 of the 23
loans that are currently with the special servicer, CWCapital, as
well as special servicing fees.  S&P lowered its rating on the
class F certificates because S&P believes the class is susceptible
to future interest shortfalls.  As of the Oct. 12, 2010,
remittance report, ARAs totaling $89.2 million were in effect for
22 loans.  The total reported ASER amount was $382,973, and the
reported cumulative ASER amount was $2.9 million.  Standard &
Poor's considered 16 ASERs, all of which were based on MAI
appraisals, as well as current special servicing fees in
determining its rating actions.  The reported interest shortfalls
totaled $481,888 and have affected all of the classes subordinate
to and including class G.  Classes H, J, K, L, M, N, and P have
had accumulated interest shortfalls outstanding for seven (classes
H and J) and 11 (classes K, L, M, N, and P) months, and S&P
expects these shortfalls to remain outstanding for the foreseeable
future.  Consequently, S&P downgraded these classes to 'D (sf)'.

The collateral pool for the MLMT 2006-C1 transaction consists of
244 loans with an aggregate trust balance of $2.4 billion.  As of
the Oct. 12, 2010, remittance report, 23 loans ($208.0 million;
8.7%) in the pool were with the special servicer.  The payment
status of these loans is: five ($53.8 million, 2.3%) are REO,
eight ($88.8 million, 3.7%) are in foreclosure, nine
($46.2 million, 1.9%) are more than 90 days delinquent, and one
($19.1 million, 0.8%) is in its grace period.

      Wachovia Bank Commercial Mortgage Trust Series 2003-C3

S&P lowered its ratings on the class J, K, L, M, N, and O
certificates from Wachovia Bank Commercial Mortgage Trust's series
2003-C3 due to current and potential interest shortfalls resulting
from ASERs related to four of the nine loans that are currently
with the special servicer, LNR, as well as special servicing fees
and interest not advanced on one loan.  The downgrade of the class
H certificates reflects a reduction in available interest to this
class resulting from the interest shortfalls.  As of the Oct. 15,
2010, remittance report, ARAs totaling $33.7 million were in
effect for seven loans.  The total reported ASER amount was
$85,713, and the reported cumulative ASER amount was $1.2 million.
Standard & Poor's considered the four ASERs, all of which were
based on MAI appraisals, as well as interest not advanced
($67,870) for one loan and current special servicing fees in
determining its rating actions.  The reported interest shortfalls
totaled $168,571 and have affected all of the classes subordinate
to and including class K.  Classes L, M, N, and O have had
accumulated interest shortfalls outstanding for five (classes L,
M, and N) and eight (class O) months, and S&P expects these
shortfalls to remain outstanding for the foreseeable future.
Consequently, S&P downgraded these classes to 'D (sf)'.

The collateral pool for the WBCMT 2003-C3 transaction consists
of 115 loans with an aggregate trust balance of $724.0 million.
As of the Oct. 15, 2010, remittance report, nine loans
($72.1 million; 10.0%) in the pool were with the special servicer.
The payment status of these loans is: five ($30.7 million, 4.2%)
are REO, two ($23.9 million, 3.3%) are more than 90 days
delinquent, one ($7.0 million, 1.0%) is 30 days delinquent, and
one ($10.5 million, 1.5%) is in its grace period.

                         Ratings Lowered

             Banc of America Commercial Mortgage Inc.
   Commercial mortgage pass-through certificates series 2004-4

                                                       Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From     Credit enhancement (%)  Current  Accumulated
-----  --        ----     ----------------------  -------  -----------
G      B+ (sf) BB (sf)          6.96            0            0
H      CCC (sf)B (sf)           5.17         (70,919)     277,444
J      D (sf)  CCC (sf)         4.46          25,040      275,444
K      D (sf)  CCC- (sf)        3.75          25,040      275,444
L      D (sf)  CCC- (sf)        3.03          25,040      275,444

             Banc of America Commercial Mortgage Inc.
   Commercial mortgage pass-through certificates series 2005-3

                                                       Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From     Credit enhancement (%)    Current  Accumulated
-----  --        ----     ----------------------    -------  -----------
E     B+ (sf)  BB (sf)          9.50           (5,563)           0
F     CCC (sf) BB-(sf)          8.38           9,539      100,539
G     CCC- (sf)B+ (sf)          6.82          128,764      261,764
H     D (sf)   B+ (sf)          5.41          117,060      782,737
J     D (sf)   B (sf)           4.00          117,060    1,066,848
K     D (sf)   CCC+ (sf)        3.30           50,291      452,620
L     D (sf)   CCC+ (sf)        2.73           40,231      362,076
M     D (sf)   CCC (sf)         2.17           40,231      362,076
N     D (sf)   CCC-(sf)         1.89           20,117      181,055

             Banc of America Commercial Mortgage Inc.
   Commercial mortgage pass-through certificates series 2005-4

                                                       Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From     Credit enhancement (%)    Current  Accumulated
-----  --        ----     ----------------------    -------  -----------
F     B- (sf)  BB+ (sf)          7.46         (2,724)      57,602
G     D (sf)   BB (sf)           6.17          76,940      401,580
H     D (sf)   BB- (sf)          4.46         102,586      935,658
J     D (sf)   B+ (sf)           3.88          31,088      279,795
K     D (sf)   B+ (sf)           3.31          31,084      279,759
L     D (sf)   B (sf)            2.74          31,084      279,759
M     D (sf)   B (sf)            2.45          15,542      139,880
N     D (sf)   B- (sf)           2.02          23,317      209,855
O     D (sf)   CCC+ (sf)         1.59          23,313      209,820

                          COMM 2005-C6
          Commercial mortgage pass-through certificates

                                                       Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To      From     Credit enhancement (%)   Current     Accumulated
-----  --      ----     ----------------------   -------    -----------
F     CCC (sf) B- (sf)           3.91          13,982       13,982
G     CCC- (sf)CCC (sf           2.53         112,908      214,400
H     D (sf)   CCC- (sf)         1.31         100,369    1,027,571

  GE Commercial Mortgage Corp. Commercial mortgage pass-through
                   certificates series 2005-C4

                                                       Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From     Credit enhancement (%)    Current  Accumulated
-----  --        ----     ----------------------    -------  -----------
H     CCC+(sf) B (sf)            5.18            (838)      22,915
J     D (sf)   B- (sf)           3.97          119,962     383,465
K     D (sf)   CCC+ (sf)         3.44           50,088     300,529
L     D (sf)   CCC (sf)          2.90           50,088     325,857
M     D (sf)   CCC-(sf)          2.50           37,568     285,220
N     D (sf)   CCC-(sf)          2.10           37,568     300,546
O     D (sf)   CCC-(sf)          1.83           25,044     236,616
P     D (sf)   CCC-(sf)          1.43           37,564     413,196

JPMorgan Chase Commercial Mortgage Securities Trust 2007-CIBC19
          Commercial mortgage pass-through certificates

                                                       Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To       From     Credit enhancement (%)   Current    Accumulated
-----  --       ----     ----------------------   -------    -----------
F     CCC+(sf) B (sf)            5.27          61,624       61,624
G     CCC-(sf) B (sf)            3.98         195,926      353,344
H     CCC-(sf) B- (sf)           2.95         156,741      318,675
J     D (sf)   B- (sf)           1.67         195,926      726,401
K     D (sf)   CCC+ (sf)         1.41          37,328      373,282
L     D (sf)   CCC+ (sf)         1.15          37,328      402,277
M     D (sf)   CCC (sf)          0.64          74,656      821,220
N     D (sf)   CCC (sf)          0.38          37,328      410,610
P     D (sf)   CCC (sf)          0.25          18,662      205,280

             LB-UBS Commercial Mortgage Trust 2004-C4
          Commercial mortgage pass-through certificates

                                                       Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From     Credit enhancement (%)    Current   Accumulated
-----  --        ----     ----------------------    -------   -----------
J     BB(sf)   BBB- (sf)         4.34               0            0
K     CCC+(sf) BB (sf)           2.74         (35,018)     200,500
L     CCC-(sf) BB- (sf)          2.38          15,470      124,157
M     D (sf)   B+ (sf)           2.02          15,465      124,122
N     D (sf)   B (sf)            1.67          15,465      124,122

             ML-CFC Commercial Mortgage Trust 2007-5
          Commercial mortgage pass-through certificates

                                                       Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To       From     Credit enhancement (%)   Current    Accumulated
-----  --       ----     ----------------------  -------     -----------
H     D (sf)   CCC- (sf)         2.01         119,673      240,122
J     D (sf)   CCC- (sf)         1.62          69,592      201,702
K     D (sf)   CCC- (sf)         1.37          46,399      277,176
L     D (sf)   CCC- (sf          1.11          46,399      336,879
M     D (sf)   CCC- (sf)         0.85          46,395      510,343
N     D (sf)   CCC- (sf)         0.72          23,197      255,171
P     D (sf)   CCC- (sf)         0.47          46,399      510,389

               Merrill Lynch Mortgage Trust 2006-C1
          Commercial mortgage pass-through certificates

                                                       Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To       From     Credit enhancement (%)    Current   Accumulated
-----  --       ----     ----------------------    -------   -----------
F     B- (sf)  B+ (sf)           4.81               0            0
G     CCC (sf) B (sf)            3.90          44,966       44,966
H     D (sf)   B- (sf)           2.86         117,322      502,581
J     D (sf)   B- (sf)           2.60          29,066      203,459
K     D (sf)   CCC+ (sf)         2.21          43,596      438,947
L     D (sf)   CCC (sf)          1.95          29,061      319,670
M     D (sf)   CCC- (sf)         1.69          29,066      319,721
N     D (sf)   CCC- (sf)         1.43          29,066      319,721
P     D (sf)   CCC- (sf)         1.17          29,061      319,670

             Wachovia Bank Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2003-C3

                                                       Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To       From     Credit enhancement (%)   Current    Accumulated
-----  --       ----     ----------------------   -------    -----------
H     BBB (sf) A (sf)            9.66               0            0
J     B+ (sf)  BB+ (sf)          6.58         (29,331)     115,347
K     CCC (sf) BB (sf)           5.29          38,914      194,568
L     D (sf)   B+ (sf)           4.32          29,182      145,910
M     D (sf)   B (sf)            3.99           9,727       48,637
N     D (sf)   CCC (sf)          3.02          29,186      145,931
O     D (sf)   CCC- (sf)         2.38          19,455      108,879


* S&P Takes Various Rating Actions on Three Market Value CDOs
-------------------------------------------------------------
Standard & Poor's Ratings Services took various rating actions on
three market value collateralized debt obligation transactions.
S&P lowered its ratings on the C and D tranches from Sankaty High
Yield Partners III and affirmed its rating on one tranche from the
same transaction.  At the same time, S&P affirmed its ratings on
two tranches from Blackrock Senior Income Series III PLC and left
its rating on one tranche from the same transaction on CreditWatch
with negative implications.  S&P also withdrew its ratings on one
tranche from Sankaty High Yield Partners III and five tranches
from Anchorage Crossover Credit Finance Ltd. following the
complete paydown of the notes.

The rating actions follow S&P's most recent monthly review of
market value CDO performance.  The downgrades and CreditWatch
placements reflect a decrease in the transactions'
overcollateralization levels.

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

                 Rating And Creditwatch Actions

                                           Rating
                                           ------
Transaction          Class       To                  From
-----------          -----       --                  ----
BlackRock Sr         C           CCC- (sf)/WatchNeg  CCC- (sf)/WatchNeg
  Incme Series III
Sankaty High         C           CCC- (sf)           CCC (sf)
  Yield Ptnrs III
Sankaty High         D           CC (sf)             CCC- (sf)
  Yield Ptnrs III
Sankaty High         B           NR                  BB- (sf)/WatchPos
  Yield Ptnrs III
Anchorage            A-1a 2006-1 NR                  AAA (sf)
  Crossover Crdt Fnce
Anchorage            A-1b 2006-1 NR                  AAA (sf)
  Crossover Crdt Fnce
Anchorage            A-2 2007-1  NR                  AAA (sf)
  Crossover Crdt Fnce
Anchorage            A-3 2007-1  NR                  AAA (sf)
  Crossover Crdt Fnce
Anchorage            A-4 2007-1  NR                  AAA (sf)
  Crossover Crdt Fnce

                        Ratings Affirmed

    Transaction                             Class      Rating
    -----------                             -----      ------
    BlackRock Senior Income Series III      D          CC (sf)
    BlackRock Senior Income Series III      E          CC (sf)
    Sankaty High Yield Partners III         E          CC (sf)

                           *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers"
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Wednesday's edition of the TCR.  Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com/

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

For copies of court documents filed in the District of Delaware,
please contact Vito at Parcels, Inc., at 302-658-9911.  For
bankruptcy documents filed in cases pending outside the District
of Delaware, contact Ken Troubh at Nationwide Research &
Consulting at 207/791-2852.

                           *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors" Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Frederick, Maryland,
USA.  Marites Claro, Joy Agravante, Rousel Elaine Tumanda, Howard
C. Tolentino, Joseph Medel C. Martirez, Denise Marie Varquez,
Philline Reluya, Ronald C. Sy, Joel Anthony G. Lopez, Cecil R.
Villacampa, Sheryl Joy P. Olano, Carlo Fernandez, Christopher G.
Patalinghug, and Peter A. Chapman, Editors.

Copyright 2010.  All rights reserved.  ISSN: 1520-9474.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.  Information contained
herein is obtained from sources believed to be reliable, but is
not guaranteed.

The TCR subscription rate is $775 for 6 months delivered via e-
mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Christopher
Beard at 240/629-3300.


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